The Core Strategy Options Document invited responses from ‘stakeholders’ by way of a Questionnaire. STAG was op the view that this Questionnaire was ‘loaded’ and did not properly address the important issues involved. Therefore, our response was in narrative form and is published here in full.

It is STAG’s belief that the consultation process during February and March 2007 for the proposed Local Development Framework is neither transparent nor unbiased, and it is our belief that, despite claims to the contrary, the LDF Task Group has already made up its mind and will eventually favour Option 6.
We also believe that the issues involved are too complicated to be answered by a Questionnaire which does not address all the issues satisfactorily and in sufficient depth and we have prepared this narrative response in addition to the completed  Questionnaire.
The accusation made by STAG in our Report of September 2006 that the intention of the LDF Task Group has always been to build large scale housing developments on greenfield land around the Trimley Villages is reinforced for the following reasons, as detailed in our narrative Response :

STAG predicts there will be numerous submissions from stakeholders and other interested parties who are opposed to changing the status of the Trimley Villages within the Settlement hierarchy and who also oppose large scale housing developments on greenfield land around the Trimley Villages.  STAG also predicts that these views will be ignored and the LDF Task Group will recommend the adoption of Option 6 despite its disadvantages not just for the Trimley Villages but also for the whole Felixstowe Peninsula.

Note 1 : SCDC do not customarily calculate houses built on a calendar year basis - January to December - but from April to March. Thus the figure of 1460 shown above for 2001 to 2004 is understated by 9 months. In his FOIA reply to STAG Stephen Brown provided a total of 1443 units built for the 2005 and 2006 calendar years. Therefore we have added an estimated 200 units to take account of this missing 9 month period.

One : Bias By The Local Development Framework Task Group
In the Minutes of their July 2006 Meeting the members of the LDF Task Group state : “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. This meant that RSS requirements would be exceeded but the Council would be able to plan the district beyond 2021, particularly relevant in the Ipswich Policy Area and Felixstowe/Trimleys where allocations could be made as a first phase or phases thereby enabling the increase to be spread over a longer period.”

Option 6 envisages “Going For Managed Growth” beyond the year 2021, with 4820 rather than 3620 houses being built on allocated land, including 2720 units allocated to Felixstowe and the Trimley Villages. This figure of 2720 units is over and above the brownfield land for 490 units which has been identified within Felixstowe and the Trimley Villages. Therefore, it follows that all of these new homes will be allocated to greenfield land - primarily surrounding Trimley St Mary and Trimley St Martin. (See below “Inaccurate And Out Of Date Housing Statistics”)

Option 6 was Minuted as being the LDF Task Group’s preferred choice despite the following Negative Implications being conceded by them :

If the members of the LDF Task Group clearly expressed their written preference a few months ago, despite the severe disadvantages of Option 6, it is difficult to conceive how they can now have an open mind with regard to the outcome of the current consultation process. In addition, if Options 1 to 5 were previously “unsustainable” they surely cannot now be considered with an unbiased mind.

Even more disturbingly, the phrase “where allocations could be made [on greenfield land] as a first phase or phases” contradicts claims made by Councillor Andy Smith that no greenfield land would be used for housebuilding until all brownfield land had been exhausted.

Two : Bias By Councillor Andy Smith
At a Public Meeting in Trimley St Martin on 14 March 2007 Councillor Smith clearly stated that he was not in favour of large scale infill developments in the gardens of Felixstowe, nor did he want any infill development in a garden next to his own home.  (Should there be any doubt about Councillor Smith’s words, it should be noted this Public Meeting was recorded by Felixstowe TV and STAG have a copy of this recording.)

In January 2005 Stephen Brown, Planning Resources Manager at SCDC, produced statistics to STAG showing that infill or windfall developments on small sites between 2004 and 2021 were predicted to total 3980 units. In addition, following a Freedom Of Information Act request in February 2007, Mr Brown disclosed to STAG that actual infill developments across the District had historically averaged over 100 units per year.

While the availability of land for infills may diminish in future, this source of land for housebuilding will continue to be available and should not be dismissed so lightly by Councillor Smith, since it is possible that between 2006 and 2021 more than 1000 houses could be built on infill or windfall sites across the District.

At an extraordinary meeting of Felixstowe Town Council  on 19 March, Councillor Smith is quoted as saying : “There are distinct advantages to having the significant majority of housing in one place because the infrastructure and community development would be better - there would be a chance to provide shops, community facilities and a primary school if necessary.”

Councillor Smith is not only Deputy Chairman of SCDC but also Chairman of the LDF Task Group, and for someone in such positions of authority and wielding such influence these views surely render him liable to accusations of predetermination which should require him to declare a prejudicial interest, thus barring him from speaking on or being involved in the decision making process regarding housing Options.

Three : Inaccurate And Out Of Date Housing Statistics
When the LDF Task Group first published their six Options last year STAG was severely critical of the fact that the housing statistics used were out of date. It is extremely disappointing that the Core Strategy Consultation Document, published in February 2007, contains these same, discredited statistics which use housing information as at 1 April 2004. Using the Freedom Of Information Act STAG easily obtained statistics for houses built more recently and outstanding planning permissions as at 31 December 2006, and we cannot understand why the LDF Task Group did not do the same. No business would make long term decisions based on old and inaccurate information. No SCDC councillor would make important personal decisions based on old and inaccurate information. The decisions to be made by SCDC on long term housing needs will have an impact on the environment, infrastructure, economy and quality of life for generations to come and STAG are appalled that such discredited information is being presented to stakeholders as part of this consultation process.

STAG have incorporated the up to date housing information, obtained via our FOIA request, into a Table which compares our estimate of the current housing position with that used by the LDF Task Group in its Core Strategy Issues And Options Consultation Document.