Before we felt able to complete our response to the “Blobs On Maps” LDF Consultation Document we asked Steve Brown at SCDC various questions. To his credit, in the knowledge that we were hostile stakeholders, he took the time and trouble to reply in detail.

STAG Question One : If all of the East Of Ipswich "blobs" were built on, how many new houses would this provide?

Steve Brown Answer : This is impossible to answer. The 'blobs' have not been drawn with precise boundaries in mind. They represent general locations, directions of growth or areas of search. Each is not drawn to scale. Please do not assume that, say, were area 1 chosen as the preferred option then housing would be 'best-fitted' within the dotted line. A site or sites would be identified within the area, based on detailed appraisal. If you want to do your own calculation then I suggest that as a general rule of thumb you apply a density of 30 dwellings per hectare. However, this would be a crude method of calculation that had no regard to landform, setting, constraints etc.

STAG Question Two : If all of the Felixstowe and Trimleys "blobs" were built on how many new houses would this provide?

Steve Brown Answer : As above

STAG Supplementary Question : Reference the Areas and our first two questions, in order to work out very housing possibilities can you give the approximate size of each Area, so that we can carry out our own calculation, as suggested by you?

Steve Brown Answer :I'm sorry I can't because the dotted lines have no meaning to me. They simply represent general areas that have not been drawn to scale. They have not been identified on the basis of a logic process whereby area Z consists of ten identified fields one of which may be allocated for housing. All ten fields cover 100 hectares therefore the total capacity of area Z is 3000 houses. I am suggesting to you that you might want to carry out your own calculation; to look at a map and think "area Z might consist of this field, that one and that one." You could then estimate your own theoretical capacity. But you cannot transfer that conclusion to one of the other areas, e.g. Area Y is about the same size as area Z therefore can also accommodate 3000 houses. I suggest that STAG does not get too involved in theoretical calculations that produce false and negative results. To think along such lines as "we'd better not go for area Z because we'll finish up with twice as many houses as we need." Think in general terms. Devise your own strategy. If there is to be expansion, in which direction should it occur? Into area X because of its proximity to schools and services? Into area Y because it has least impact on the existing road network? Avoid development within area Z because of the impact on the wider landscape? etc. In making such assessments it would be foolish to not think of the future beyond 2024. This might be to create a new 'edge' or limit to development through landscaping or the creation of green space, or to make longer term planning decisions on where Felixstowe/Trimleys should go should go beyond 2024 should further housing be justified in a future review. Once that strategic locational strategy has been established it will be time to get down to the detail of where within area X should the houses be located? What will be the precise location, access arrangements, phasing, infrastructure etc.? That is what the Council's thought process is.

STAG Supplementary Question : We are trying to be as specific as we can about Trimley Area 1. There seems to be confusion with some people seeming to think that Area 1 only represents the three small infill areas - Piggeries, Poultry Farm and "the area north of Flyover" put forward by Trimley St Martin Parish Council last year. STAG’s view - as evidenced by the consultation document statement "Area 3 alone will not accommodate the 1620 houses required", plus the stated LDF preference for large sites - is that Area 1 includes the three small Parish Council sites plus much more land, coming to a total which could accommodate at least 1620 houses. Therefore, all the Trimley/Felixstowe blobs taken together would accommodate 4 x 1620 plus Area 3 houses, say perhaps 7000 units.

Steve Brown Answer :Area 1 does indicate development beyond simply the first field east of the flyover as suggested by the Parish Council. This is because there is the ability to go beyond that and incorporate further land if this direction is perceived to be the best one for any future growth. Such a larger area might have benefits of creating a self-contained community with community facilities rather than just a housing estate. There might even be the opportunity to create new employment, subject to access and traffic of course. Hence the identification of the whole area north of the A14 as a genuine option rather than simply a very small part of it. Again, this is all hypothetical. Areas 1, 2, 4 and 5 could accommodate 50 houses or 1600 houses depending on where you drew the line. Only area 3 is finite because it is surrounded by roads and development. Even here, however, only a part of it could be developed if the preferred option is one of spreading the development around. Therefore, yes, all the Areas together could accommodate far more than 1600 dwellings if they were defined extensively enough. On the same basis, other than Area 3, each of the Areas could accommodate that number. On the other hand of course, 1600 dwellings could be accommodated within parts of all 5 Areas.

STAG Question Three: If planning applications are received on either of the groups of "blobs" for more houses than are needed according to the Consultation Document ( 970 and 1620 respectively ), would applications for excess houses be rejected? If so, on what basis would the rejections be decided? If not, why not?

Steve Brown Answer : The stages in the process from here onwards will be, as part of the overall Core Strategy, to identify the preferred general location (to be the subject of public consultation and examination by an independent inspector). This will be followed by the identification within a subsequent document - Site Specific Allocations and Policies - of the precise site(s) where development will take place, again with public consultation and examination. The choice of site(s) will be related directly to the numbers of dwellings to be provided. The Council has the ability, if it so wishes, to combine these two stages by identifying the site(s) in the Core Strategy alone, arguing that the allocation is a strategic one but this has yet to be decided. If a planning application, regardless of size, was submitted before the process was completed the Council could argue that it was premature unless the applicant put forward a reasoned case that a decision must be made and the land released early. If the site(s) had been allocated and a planning application was submitted which was at variance with the allocation the Council could argue that it was not in conformity with the Development Plan and legitimately refuse it. The caveat again would be a reasoned justification for the making of a decision contrary to planning policy. The principles behind prematurity and consistency with planning policy are set out in the government's Planning Policy Statement 1 dealing with general principles.

http://www.communities.gov.uk/publications/planningandbuilding/planningsystem

STAG Question Four : If planning applications are received with regard to greenfield land not within any of the "blobs" would these applications be rejected?

Steve Brown Answer : If a planning application was submitted for a site not allocated then it would be contrary to the Development Plan. At this stage, of course, suggestions (not applications) are invited for other potential areas.

STAG Question Five : With regard to sustainability, have any studies been done on whether fewer, or shorter, car journeys are undertaken by residents of sustainable communities than are undertaken by residents of unsuatainable communities.

Steve Brown Answer : The Council has not undertaken such studies. It is, to a considerable extent, applying established principles set out in national and regional policy in respect of delivering sustainable development. It is not devising its own policy whereby sustainability is at the forefront of decision making and a reduction in journeys by private car contributes to that. I draw your attention again to PPS1 and also the East of England Plan.

http://www.communities.gov.uk/publications/planningandbuilding/planningpolicystatement
http://www.eera.gov.uk/category.asp?cat=120&id=SXE12B-A77F5420

STAG Question Six : Is the housing needs split between East Of Ipswich and Felixstowe and The Trimleys cast in stone (970 and 1620)? Are there any circumstances in which it would be possible to vary these figures while still keeping the same grand total?

Steve Brown Answer : The east of Ipswich figures are based on the East of England Plan which sets a specific housing target for that part of the Ipswich Policy Area within Suffolk Coastal. That is not to say that it could not be increased if the Council was to have a robust argument for doing so but it certainly would be unlikely to be acceptable to the Secretary of State if it was reduced. The Felixstowe/Trimley figures are still, as you know, the subject of debate. There is a target in the East of England Plan for Suffolk Coastal outside of the Ipswich Policy Area and at this stage the Council considers that a large proportion should be located at the highest order centre. The potential number of houses, together with an indication as to where they might be located in general terms, will be the subject of a further consultation later this year.

STAG Question Seven : Have any surveys been done on traffic volumes on the A14 and Felixstowe for (a) current traffic figures (b) with dock expansion and (c) with the extra houses planned up to 2024?

Steve Brown Answer : The District Council has not carried out any surveys but is working with the County Council as highway authority with responsibility for the local road system and Highways Agency with responsibility for the A14 trunk road on carrying out some surveys and modelling of the impact of the proposed scenarios. That will occur later this year and provide an input into the decision making process. Traffic predictions on the volumes to be created by the port expansion were presented to the public inquiry.