Reproduced below, in full, is STAG’s detailed response to the “Blobs On Maps” consultation. Some may consider it to be excessive, and we would not disagree. However, last year almost every point raised by us was ignored because we submitted our response as a separate narrative Report rather than online. This year we will not make the same mistake - our response has been submitted online and will therefore be printed for all to see and will have to be replied to point by point. We also reproduce two maps - the Blob Map for the Felixstowe Peninsula which stakeholders were asked to consider along with STAG’s interpretation of the same information using the facilities of Google Earth.

STAG Consultation Responses Summary

It is STAG’s belief that a large scale development of 1620 houses on any of the Felixstowe Peninsula Blobs, or an accumulation of developments over several Blobs to arrive at a total of 1620 houses, would be an infrastructure disaster.

STAG further believes that a development of up to 4000 houses - the so called SuperBlob 6 on greenfield land between Trimley St Martin and Kirton - proposed by Felixstowe Town Council at an Extraordinary Meeting on 11 March, and endorsed on 2 April, would be an even greater infrastructure disaster.

The A14 over the Orwell Bridge and between Ipswich and Felixstowe is already obviously close to capacity. The current frequency of accidents means regular blockages on the A14 and through the Trimley villages. The frequent implementation of Operation Stack also means regular blockages on the A14 and through the Trimley villages. Since the A14 and Trimley High Road / Walton High Street are the only vehicular routes on and off the Peninsula it is only a matter of time before lives will be lost because emergency vehicles - ambulances and / or fire engines - fail to get through.

This situation - road blockages and endangerment to lives - will inevitably get much worse because of

(a) Additional private vehicles arising from houses currently under construction, houses still to be built for which planning permission has been granted, and houses still to be built on brownfield sites, and

(b) Extra lorries which will arise following the FSR at The Port Of Felixstowe.

This extra traffic could, in itself, make the A14 unsustainable, and it is STAG’s contention that the nearly 3000 private cars (1.8 per rural household) which will come from 1620 new houses could be the final straw which will lead to the A14 becoming East Anglia’s version of the M25.  This figure would be a staggering 7200 more cars with SuperBlob 6.

It is extremely disappointing that the LDF Task Group, in proposing 1620 new homes on the Felixstowe Peninsula, have taken no account of the adverse effects that their housebuilding proposals would have on the viability of the A14. This negligence - by both councillors and officials - could justifiably be described as gross incompetence, and is exceedingly disturbing, given the long term effects of the decisions they have been delegated to make on our behalf.

It is even more disappointing that two members of the LDF Task Group, including the Chairman, in their capacities as Felixstowe Town Councillors, have proposed up to 4000 extra houses on SuperBlob 6 with even more disastrous consequences.

LDF Consultation Outcome : STAG Predictions

Prediction One : On 11 March 2008, at a special meeting, the Conservative members of Felixstowe Town Council voted as a group to recommend Blob 4 as the most suitable location for 1620 houses on the Felixstowe Peninsula. This was proposed and seconded by councillors who are also members of Suffolk Coastal District Council. We predict, therefore, that Blob 4 will be adopted by the LDF Task Group.

Prediction Two : At the same meeting, Councillor M Ninnmey (A member of the LDF Task Group) proposed that SuperBlob 6 should also be recommended for consideration, being located on greenfield land north of Trimley St Martin between the A14, Kirton Road and Innocence Lane, and being - in Councillor Ninnmey’s words - large enough for 4000 houses to accommodate the needs of the whole District. This proposal was seconded by Councillor A Smith (Chairman of the LDF Task Group) and approved unanimously by all members of Felixstowe Town Council. STAG therefore predicts that SuperBlob 6 will be adopted for consideration for large scale housebuilding by the LDF Task Group.

STAG would point out that, in view of their voting performance in Felixstowe, it would be unreasonable to expect Councillors Smith and Ninnmey to speak against or vote against Blob 4 and SuperBlob 6 in the LDF Task Group. We have to also express our disappointment that neither gentleman, nor any other Felixstowe Councillor, saw fit to question the infrastructure implications of either of these Blobs, nor of their adverse effects on traffic congestion. In addition, as Chairman of the LDF Task Group Councillor Smith has frequently expounded the need for homes to be situated close to major areas of employment. SuperBlob 6, as described by Councillor Ninnmey and voted on by Felixstowe Town Council, is intended to serve the housing needs of the whole District. By voting for SuperBlob 6 Councillor Smith has voted in contradiction of his own and the LDF Task Group’s stated policies.

STAG’s Predictions presuppose that Councillors Smith and Ninnmey remain as members of the LDF Task Group - see Point Eleven below regarding LDF Task Group impartiality.

The LDF Task Group’s Lack Of Vision

It is a government requirement that houses, for sustainability reasons, have to be built in large numbers as close as possible to major centres of employment, and it has been claimed that this requires a large number of houses - 1620 - to be built on greenfield land close to Felixstowe / Walton / the Trimley villages. STAG believes that implicit within any government requirement is a need to use common sense with regard to the location of these large housing estates. So far as the Felixstowe Peninsula is concerned, common sense says -

(a) Avoid building on greenfield land where more suitable sites are available elsewhere (not necessarily on the Peninsula),

(b) Do not deliberately make traffic worse on the A14 - a route of local, national and international importance that is already at or close to capacity, and

(c) Do not rely on expansion of the Port Of Felixstowe as a justification for large scale housebuilding, since this expansion will not necessarily attract substantial numbers of new jobs to the area.

It is disappointing that members of the LDF Task Group have had neither the common sense to ask questions regarding any of these matters nor the courage and integrity to suitably answer them.

STAG’s Preferred Option

Given that common sense dictates that the Felixstowe Peninsula is unsuitable for large scale housebuilding it is STAG’s belief that the only housebuilding on the Felixstowe Peninsula should be limited to

(a) Brownfield sites already identified as part of the recent LDF study,

(b) Planning permissions that have already been granted, and

(c) Small infill developments already identified by the Trimley St Mary and Trimley St Martin Parish Councils.

It is STAG’s belief that all large scale housing developments would be more suitably situated on the Ipswich fringes, and we would especially favour Blob 4, which encompasses “spoiled” agricultural land around Adastral Park, for the following main reasons -

(a) Although technically greenfield land its previous use makes it more suitable for housebuilding than agricultural purposes,

(b) Proximity to an area of potentially increased employment at BT, plus other areas of employment at Martlesham, Kesgrave, Rushmere, Warren Heath and eastern Ipswich, and

(c) Proximity to the A12, thus alleviating traffic congestion problems.

SuperBlob 6 Unsustainability

At an Extraordinary Meeting of Felixstowe Town Council on 11 March - subsequently endorsed on 2 April - a proposal was agreed for a new “eco community” on greenfield land bounded by the A14, Kirton Road and Innocence Lane, which was described as being able to serve the housing needs of the whole District. This “SuperBlob” should be rejected out of hand by the LDF Task Group for the following reasons -

(a) The number of houses proposed is grossly in excess of projected needs as stated by the LDF Task Group as well as any other reasonably foreseeable housing needs,

(b) Any arguments that such a SuperBlob would allow existing villages to grow naturally, and would allow planning for the long term future are fatuous and irrelevant,

(c) The number of extra cars associated with this number of new houses would cause congestion on local roads and the A14,

(d) The location of SuperBlob 6, and its stated purpose of serving the needs of the whole District, contravenes the LDF Task Group stated policy of sustainability, whereby settlements should be located as close as possible to major areas of employment.

LDF Task Group - Proofs Of Commitment

Proof One : The LDF Task Group have often stated their preference for brownfield sites, and STAG believes that this should be stated as a “First Principal” within every document they produce. As a statement of overriding policy it should additionally be stated categorically and without exception that no building on any greenfield sites will be allowed until all brownfield sites identified as being suitable for housebuilding have been used for this purpose.

Proof Two : The LDF Task Group must state as a matter of principal that no large scale housebuilding will be allowed on the Felixstowe Peninsula until there is substantial proof of need by way of -

(a) Verifiable extra demand for houses as a result of changing population demographics, and

(b) Verifiable significantly increased employment at the Port Of Felixstowe.

Proof Three : The LDF Task Group must reinforce its commitment to affordable housing by defining what it means by “affordable” and stating categorically that no exceptions will be made, for any reason whatsoever, to its commitment that one third of all new homes will be affordable.

Proof Four : In addition, as proof of their commitment to building on brownfield sites, and in recognition of the very real possibility of future brownfield sites becoming available, it should be stated that, as a matter of policy, there will be a five year moratorium on giving approval to significant building on any greenfield land to allow for such brownfield sites to become available.

Proof Five : The LDF Task Group received well deserved criticism in 2006 and 2007 when they issued a consultation document which used housing statistics that were three years old and therefore substantially out of date. The LDF Task Group must therefore make a commitment that statistics for houses completed, planning permissions granted and outstanding, brownfield or urban capacity sites available for housebuilding, and windfall housing built on infill sites, will be updated whenever a significant stage in the consultation process is about to take place, in order that stakeholders can make meaningful and fully informed decisions. The LDF Task Group should also make a commitment that, in any case, these figures will be updated every three years and prior to any Public Inquiry.

Proof Six : The LDF Task Group have made much of the principal of sustainability in their deliberations and as a result, housebuilding has been prevented in many villages and hamlets. The concept of sustainability is theoretical and unproven and the LDF Task Group should carry out studies to prove that fewer and shorter car journeys are undertaken in sustainable communities compared to unsustainable communities.

Proof Seven : The recommendation that 1620 new houses are needed on the Felixstowe Peninsula has been made without any consideration of the traffic congestion effects on the A14 and Trimley High Road / Walton High Street. Before any proposals for large scale housebuilding on the Felixstowe Peninsula are finalised full traffic studies should be independently undertaken to assess the road capacity -

(a) Currently,

(b) With Port expansion and known housing expansion, and

(c) With 1620 more houses as a result of housebuilding on Blobs 1 to 5, and

(d) With 4000 more houses as a result of housebuilding on SuperBlob 6.

Proof Eight : A risk assessment should also be undertaken with regard to the possibility of lives being lost as a result of ambulances, fire engines or police vehicles being delayed or prevented from answering life threatening emergencies as a result of -

(a) Increased traffic arising from any of the above scenarios, and

(b) Traffic blockages as a result of the implementation of Operation Stack during any of the above scenarios, and

(c) A major incident or emergency at the Port which requires partial or complete evacuation.

Proof Nine : Before any final recommendations are made about housebuilding on the Felixstowe Peninsula, the LDF Task Group should satisfy itself that all major infrastructure demands can be met, including but not limited to - power, sewage, water supplies, drainage, and key associated personnel, including doctors, dentists, teachers, social services, etc.

Point One : Democracy In Action

The LDF Task Group meeting on 17 January 2008 to decide on the location of the Blobs on maps was the most important of the series. However, only 5 committee members bothered to turn up. It is disappointing that

(a) So few councillors were interested in discussing a consultation document regarding a policy that will affect the District for many years to come, and

(b) The meeting was not rescheduled to allow for greater participation.

Point Two : Consultation In Action

At this 17 January meeting most of the “backbench” councillors who attended and several of the committee members who bothered to attend were highly critical of the maps presented to the meeting and the Blobs on these maps. Criticisms included - the maps were not to scale, they were misleading, they did not show infrastructure, etc.

It is disappointing that the views of SCDC councillors were so cynically and deliberately ignored when the consultation document was subsequently published with unaltered maps. This indicates that the views of stakeholders are unlikely to be taken into account if they are not deemed to fit in with predetermined views.

Point Three : Blob Inadequacy - Deliberate Confusion?

Following on from the previous point, it is STAG’s view that the “less is more” philosophy with regard to the vagueness and obvious inaccuracies of the shapes and locations of the Blobs (Phil Ridley’s description) on the abstract and highly misleading maps presented as part of the current consultation process means that they are totally unfit for purpose with regard to helping stakeholders make informed decisions regarding preferred locations, if any, for large scale housing developments.

STAG would also question whether or not the vagueness and inaccuracy of these maps and Blobs, which ignored widespread criticism, was deliberately intended to deceive and confuse.

There are numerous instances of inaccuracy which make it difficult for stakeholders to see the Blobs within their topographical context or to reach meaningful conclusions regarding their validity, but a few examples will suffice :

(a) Neither of the maps show the location of large scale housing already in progress - via outstanding planning permissions or brownfield site already identified,

(b) Blob 4 on the East Of Ipswich “map” is so far from being to scale that its inaccuracy could be seen as deliberately intended to disguise its housebuilding potential

(c) Blob 1 on the Felixstowe and Trimley “map” is probably in the wrong place

(d) Old Felixstowe has been omitted from this map,

(e) Significant amenities, which could be encroached on by blobs, have been omitted, such as playing fields, golf courses, nature trails, lakes and ponds.

(f) Felixstowe blob 5 is claimed to have no impact on the road network (Table 3) when 1620 houses placed here would, arguably, have the most impact on A14 congestion.
Therefore, there can be no certainty that specific locations nominated by stakeholders will actually be within the boundaries of the blobs, which are known only to the officials who drew them up.

Point Four : Important Traffic Issues Ignored

The future sustainability of the A14 with regard to traffic congestion has not been taken into account -

(a) There will be substantially more lorries as a result of Port expansion,

(b) There will be more private cars as a result of more houses currently in progress, and

(c) There will be more frequent implementation of Operation Stack.

The Haven Gateway Ipswich A14 Corridor Study prepared by Messrs Atkins - Table 3.3 - notes various A14 related problems and issues which currently exist, and will get worse with increased traffic, including -

(a) Capacity limitations on the Orwell Bridge,

(b) Junction capacity limitations at White House interchange,

(c) Junction capacity limitations at Sproughton interchange,

(d) Junction capacity limitations at Copdock interchange,

(e) Junction capacity limitations at Seven Hills interchange,

(f) Incidents on the Orwell Bridge, including accidents and high winds, and

(g) Impact of A14 diversions through Ipswich.

Prior to the LDF Task Group meeting of 17 January 2008 Council Leader Ray Herring and every member of the LDF Task Group received a letter from Trimley St Martin Parish Council pointing out the problems of traffic congestion, including endangerment to life, and the adverse impact of more housing. This very important issue had not been addressed at any of the previous LDF Task Group meetings.

In addition, Trimley St Martin Parish Council had specifically asked the three District Councillors who represent the Trimley Villages to raise this matter, namely Sherrie Green, Graham Harding and Richard Kerry, a member of the LDF task Group.

Sadly, not one councillor paid any attention to this serious issue, which severely calls into question their understanding of problems facing the Felixstowe Peninsula and their competence at making important decisions that will affect the whole District.

This incompetence is illustrated by the fact that no traffic surveys have been done on the A14, no councillors or officials thought it necessary to do a traffic survey prior to recommending 1620 houses, and a traffic survey will only - very belatedly - be done later this year.

STAG Question  : “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”.

Point Five : The Sustainability Myth

The number of houses needed to be built on large scale developments has been overstated by a refusal to allow infill developments in so called unsustainable villages and hamlets. This “Disneyland” policy purports to be environmentally friendly by minimising car use, but no studies have been done to show that it actually works.

Disturbingly, the members of the LDF Task Group have accepted this sustainability policy without having the common sense to question its validity.

STAG Question : “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.”

Point Six : The Affordability Myth

It is claimed as a certainty and without any qualification whatsoever that one third of all new homes built will be “affordable”. Unfortunately, at three meetings attended by STAG members the LDF Task Group have attempted to define the meaning of “affordability” and have failed miserably on each occasion. If what constitutes an “affordable” house cannot be defined by members of the LDF Task Group it is extremely misleading of them to make this claim. It is also misleading for them not to point out the various circumstances where developers can avoid building affordable homes and still gain planning permission for large scale housing developments.

If the LDF Task Group really are seriously making the claim that one third of new homes will be affordable they should -

(a) Define exactly what is meant by “affordable” within the context of housebuilding up to the year 2024, and

(b) Make it absolutely clear that this percentage is guaranteed, is non negotiable with developers, and will not be reduced under any circumstances whatsoever.

Point Seven : The Housing Needs Myth

It has been claimed that substantial numbers of new houses are needed in the vicinity of Felixstowe in order to accommodate new employees as a result of expansion at Felixstowe Docks. What has not been stated is that, according to David Lock, only a proportion of these jobs will actually arise at the Docks, with approximately 50% occurring elsewhere within the Haven Gateway.

It is sad, therefore, that none of the LDF Task Group members have seen through, or questioned, this myth. With the global technology available today, throughput expansion does not necessarily mean an equivalent expansion in headcount either at the Docks or anywhere else in the District.

With full employment in the District it is difficult to see where substantial numbers of new recruits will come from. It has not been conceded that substantial numbers of new employees - if they arise - realistically may not want to relocate to Felixstowe, and such aspirations towards social re-engineering cannot be achieved simply by building more houses.

Point Eight : The Availability Of Land Myth

It has been falsely claimed that there is a scarcity of suitable land for housebuilding both on the Felixstowe Peninsula and elsewhere in the District, which necessitates the use of greenfield land for large scale housebuilding purposes. However, this false and misleading claim ignores the following

(a) Land that will become available in the short term as a result of reasonably certain school closures,

(b) Land that is available within Felixstowe - previously identified by David Lock - which will be suitable for housebuilding when suitable flood defences are put in place.

(c) “Spoiled” agricultural land that is currently available.

Stephen Brown statement to STAG : “In respect of sites that you would consider to have an ambiguous status and may be 'brownfield', there are lots of them on the edges of towns and villages all of which have not been included in the urban capacity study. In your locality, of course, there is the mushroom farm, the sports ground, and allotments.”

Point Nine : Hidden Statistics Regarding Housing Availability

Certain important statistics which would aid stakeholders in making informed decisions and  submissions have been omitted, including -

(a) The housing densities used - houses per hectare - in the figures presented.

If housing densities were increased without compromising quality of life, how many more homes could be built without encroaching on greenfield land?

(b) The number of long term empty houses throughout the District.

If there was a proper and effective policy with regard to taking such properties into public ownership, or of requiring owners to make effective use of them, how many extra homes would become available without encroaching on greenfield land?

Point Ten: The Destruction Of Felixstowe

Felixstowe is a tourist resort of both local and national significance, and its promotion has the potential to bring significantly more income to the town. Felixstowe’s tourism and leisure importance - and future potential - was highlighted by David Lock Associates in 2006. This tourist potential has been totally ignored by the LDF Task Group who have completely failed to consider or acknowledge the fact that the attractiveness of the Felixstowe Peninsula is its countryside - not its housing estates.

Point Eleven : LDF Task Group Impartiality

It is essential that the deliberations of the LDF Task Group are not only open, transparent and unbiased, but seen by the general public to be open, transparent and unbiased.

On 11 March at an Extraordinary Meeting of Felixstowe Town Council, specially convened to discuss their response to the LDF Consultation Document, Councillor M Ninnmey, a member of the LDF Task Group, proposed a new SuperBlob 6 as a possible location for up to 4000 new houses on the Felixstowe Peninsula to satisfy the needs of the whole District. This Motion was seconded by Councillor A Smith, Chairman of the LDF Task Group. The motion was then passed unanimously by Felixstowe Town Council.

Although Councillors Ninnmey and Smith properly declared interests as SCDC Councillors and LDF Task Group Members, and spoke at this Meeting as Felixstowe Town Councillors, there will always and inevitably be a public perception that their views as Town Councillors and LDF Task Group members cannot be separated.

A reasonable person, in possession of all of the facts, would reasonably conclude that Councillors Ninnmey and Smith were dead set in their views regarding SuperBlob 6. Therefore, on the grounds of predetermination, and to preserve not only the integrity of the LDF Task Group’s consultation and decisionmaking process, but the public perception of this process, it is essential that Councillors Ninnmey and Smith take no further part in these deliberations.