THE STAG REPORT INTO THE DECISIONMAKING PROCESS OF THE LDF

SAVE FELIXSTOWE

THE STAG REPORT INTO THE DECISIONMAKING PROCESS OF THE LDF

In June and July 2006 the Local Development Framework Task Group Minuted their preference for Housing Option Six, meaning the building of 2720 new homes around Felixstowe and the Trimely Villages. They also concluded that all other Options were unsustainable. STAG studied the Minutes of the LDF Task Group and the accompanying documentation then, in September 2006 published the highly critical STAG Report. Copies of the STAG report were sent to every member of the LDF Task Group, John Gummer MP, Felixstowe Town Council and the Trimley St Mary and Trimley St Martin Parish Councils. Only one member of the LDF Task Group had the courtesy to acknowledge receipt of this Report.

Summary

The Local Development Framework Task Group is responsible for developing Suffolk Coastal District’s overall housing policy over the next 15 years in terms of the Regional Spatial Strategy. It is the belief of STAG that by using outdated, inaccurate and selective housing statistics, The Local Development Framework Task Group has reached a perverse conclusion regarding future housing needs which -

Ÿ	Ignores the facts with regard to housing statistics and land availability,

Ÿ	Grossly overstates the need for new houses, and

Ÿ	Unfairly and unnecessarily allocates Greenfield land around the villages of Trimley St Mary and Trimley St Martin for large scale housing development.

1 Introduction

In terms of The East Of England Plan (The Regional Spatial Strategy) there is a requirement to build, between the years 2004 and 2021, a total of 10,100 new houses, of which 7,050 (70%) are expected to be within that part of The Haven Gateway which lies within Suffolk Coastal District boundaries.

Document LPTG 04/06, Local Development Framework Core Strategy Options, prepared by Councillor AJA Smith, Convenor, Environment: Natural and Build, supported by Mr Stephen Brown, Planning, Policy And Development Manager at Suffolk Coastal District Council, outlines the six possible Options for future housing developments within Suffolk Coastal District.

2 The Six Housing Options

The various Options for housing development proposed within The Haven Gateway part of the District, according to Document LPTG 04/06 are -

Option One: The majority of major housing developments to be located on the fringes of Ipswich, thus requiring the use of Greenfield land. This Option assumes a “Moderate Growth” policy for Felixstowe growth - Scenario Two of the David Lock Consultancy Study, where a possible requirement for between 696 and 892 houses has been identified for Felixstowe.

Option Two: All major developments for the whole District are to be located within Felixstowe and the Trimley villages, also requiring the use of Greenfield land. Market towns within the District (Aldeburgh, Leiston, Saxmundham and Woodbridge) would be restricted to windfall developments and outstanding planning permissions.

Option Three: An even split of developments between the Ipswich fringes and Felixstowe plus the Trimley villages. This Option assumes David Lock’s Scenario Three - “Going for Growth”, with a possible requirement for between 1,293 and 1,795 houses for Felixstowe.

Option Four: Major developments to be spread throughout the District - Ipswich fringes, Felixstowe and the Trimley villages, and the market towns - with Greenfield sites allocated equally, with each location having the same percentage increase in their housing stocks.

Option Five: Similar to Option Four, but with smaller Greenfield site developments in those larger villages which are Key Service Centres with sustainable communities.

Option Six: A combination of the previous Options, but taking account of expected growth on the eastern fringe of Ipswich plus Felixstowe and the Trimley villages beyond the year 2021. This “Going for Growth” Option would supposedly require an additional 2,500 housing units to be located on large Greenfield sites. It should be noted that there is no requirement in the East of England Regional Spatial Strategy to extend the planning of housing needs beyond the year 2021.

See Paragraph 3.4 for the David Lock Options.

3 The Need for New Houses

The Balance of New Houses to Be Allocated throughout the District from 2004 to 2021 can be calculated using the following formula -

1. Houses already built during the relevant period,

2. Houses granted planning permission but not yet built,

3. Future small scale “windfall” developments,

4. Leaving a balance of houses, not yet built or granted planning permission, which should be allocated -

·	On small, urban Brownfield sites,

·	On larger Brownfield sites, and as a last resort

·	On Greenfield land.

3.1 The Misuse of Housing Statistics

Early in 2005 SCDC Planning Department produced the following summary of housing statistics for the District, as follows:

Housing Statistics E-mailed To STAG In January 2005

District Total

Completed Houses Between 2001 And 2004

1510

Planning Permissions Given In 2004

2810

Predicted Small Scale Windfall Developments

3980

Balance Of Housing To Be Allocated Over The Next 15 Years Throughout Suffolk Coastal District

1800

Total Housing Requirement to 2021

10100

It can be seen that 18 months ago Brownfield or Greenfield land needed to be found for only 1,800 houses over the next 15 years - 120 houses per annum - throughout the whole of Suffolk Coastal District.

In June 2006, in Annex 2 of LPTG 04/06, Options for the Distribution of Housing, these statistics were “updated”, as follows:

Housing Statistics Published In June 2006 - Recommended For Adoption By SCDC

District Totals

Felixstowe & Trimleys

Completed Houses Between 2001 and 2004

1460

Planning Permissions Given In 2004

2810

140

Predicted Small Scale Windfall Developments

Urban Capacity

2310

490

Balance Of Housing To Be Allocated Over The Next 15 Years Throughout Suffolk Coastal District

3620

(*) 2120

Total Housing Requirement To 2021

10200

2830

(*) As per Option Five - see A Flawed Decision making Process below.

Surprisingly, the statistics published in June 2006 use the same outdated and now presumably inaccurate figures to arrive at a much higher balance of new houses still to be allocated over the next 15 years to 2021. However, this Annex is fatally flawed since -

Ÿ	No account has been taken of houses completed from 2005 onwards, and

Ÿ	No account has been taken of planning permissions granted from 2005 onwards.

In addition, and even more disturbingly -

Ÿ	Predicted Small Scale Windfall Developments up to 2021, previously shown as 3,980 units, have now been completely omitted, and

Ÿ	A substantially smaller Urban capacity figure, also relating only up to the year 2004, of 2,310 houses has replaced Windfall Developments,

Ÿ	For Felixstowe the 2004 Urban capacity figure is only 490, which completely ignores David Lock’s more accurate 2006 conclusion that Brownfield and Greenfield separation sites could provide between 1,293 and 1,795 houses, depending on densities.

The end result is that, in only 18 months the number of houses to be allocated up to 2021 has now doubled, from 1,800 to 3,620. It is disappointing that with such a major issue, which will seriously affect the environment, economy and infrastructure of Suffolk Coastal District for the long term, it was not felt necessary to update these vital statistics. It is even more disappointing that none of the Councillors who attended the 5 June Local Development Framework Task Group Meeting appear to have queried this glaring omission.

If Windfall Developments were added back to the above statistics, even heavily discounted to allow for uncertainty, and out of date Urban Capacity figures for Felixstowe was replaced by more recent and more accurate David Lock findings, and Houses Completed and Planning Permissions Granted were brought up to date, it is highly probable that the Balance Of Housing To Be Allocated Over The Next 15 Years Throughout Suffolk Coastal District would be substantially reduced. An examination of Appendices to recent Local Development Framework Task Group Meetings has shed no light on why this has not been done. One can only speculate as to why The Local Development Framework Task Group and their advisors did not believe that accurate or up to date figures were thought to be necessary, and it could be said that such a failure amounts to negligence.

STAG’s Reinterpretation Of Option Five Statistics - With Estimates Where Appropriate

District Totals

Felixstowe & Trimleys

Completed Houses Between 2001 and 2004

1460

Completed Houses 2005 - 2006

(1) 600

(1) 100

Planning Permissions Given In 2004

(2) 2,220

140

Planning Permissions 2005 – 2006 : FOIA Request

(3) 815

(1) 100

Small Windfall Developments

(1)(4) 900

(1) 200

Urban Capacity - Excluding Felixstowe

1,820

Felixstowe - Brownfield Sites Available Per David Lock

892

Felixstowe - Green Separation Sites Per David Lock

903

Balance Of Housing To Be Allocated Over 15 Years

590

415

Total RSS Housing Requirement To 2021

10200

2830

Notes:

1. Figures in Italics are STAG estimates.

2. Planning Permissions for 2004 have been reduced by an estimated 600 units to take account of houses built in 2005-2006.

3. Information on recent Planning Permissions have been obtained by STAG under the Freedom Of Information Act.

4. We have heavily discounted this figure to take account of future uncertainty.

Our estimated figures are indicative only and have no factual basis. However, they do show that the statistics which have been used for decision making purposes could be wildly inaccurate and merit closer examination and updating before final, and irrevocable decisions are made. The STAG Table shows that Housing Allocations over the next 15 years could be radically altered if only minor adjustments are made to our estimated figures. For example, we have estimated Small Scale Windfall Developments at 900 units in total. However, if Small Scale Windfall Developments of only 100 houses per year actually materialised - a possibly conservative figure for the whole of Suffolk Coastal District - this would total 1,500 new windfall houses throughout the District over the 15 year period and bring the Balance of Housing to Be Allocated down to NIL. This omission, coupled with the omission of Brownfield and green separation land availability highlighted by David Lock in and around Felixstowe casts severe doubt on the validity of any decision taken by The Local Development Framework Task Group.

3.2 A Flawed Decision Making Process

At the meeting of The Local Development Framework Task Group on 5 June 2006 a preference was expressed for Option Six, which extended the period beyond the year 2021 and increased the number of houses from 10,200 to 11,400. The Balance of Houses to Be Allocated within Felixstowe and the Trimley villages was increased from 2,120 to 2,720 units. This preference was expressed despite the facts that: -

·	 The housing statistics were out of date,

·	 These statistics omitted windfall developments,

·	 No account had been taken of David Lock’s Brownfield land availability findings for Felixstowe, and

·	 Vital information to aid the decision making process, including a Housing Needs Survey, had not yet been produced.

Prior to the 28 July meeting of The Local Development Framework Task Group, a document entitled ‘A Core Housing Strategy For The Suffolk Coastal District’ was published, which stated: “The Council’s preferred Option in respect of the distribution of houses across the district is one where new housing is not constrained to the urban fringe of Ipswich but also located at Felixstowe and other sustainable settlements thereby enabling other communities to benefit. Option Five satisfies this without being inconsistent with the RSS.”

However, at their 28 July Meeting The Local Development Framework Task Group chose to ignore the Option Five recommendation and once again resolved to endorse Option Six, since “other Options would be unsustainable.” This decision was made despite an acknowledgement that Regional Spatial Strategy requirements would be exceeded, and a reminder from Mr. Stephen Brown that the Trimley villages were Key Service Centres in their own right.

To illustrate how much housing needs have been exaggerated we have compared Option Six Statistics with STAG’s recalculated figures, which we believe are more realistic.

Option Six Statistics For The Whole District

District Totals

Felixstowe & Trimleys

Completed Houses Between 2001 and 2004

1460

Completed Houses 2005 - 2006

600

Planning Permissions Given In 2004

2810

2210

Planning Permissions 2005 - 2006

815

Small Windfall Developments

900

Urban Capacity

2310

1820

Felixstowe - Brownfield Sites Available Per David Lock

892

Felixstowe - Green Separation Sites Per David Lock

903

Balance Of Housing To Be Allocated Over 15 Years

4820

1800

Total RSS Housing Requirement To 2021

11400

As can be seen from our Table, Option Six contains the same inaccurate, selective and outdated housing figures as Option Five, but the Balance Of Houses To Be Allocated Over 15 Years has increased from 3,620 to 4,820 units.

It was minuted that by adopting Option Six “for Felixstowe/Trimleys ... allocations could be made as a first phase or phases.” In other words, rather than waiting until all Brownfield sites within the District have been used for house building - the responsible, and sensible course of action to take - The Local Development Framework Task Group have created a spurious justification for building up to 2,720 houses in Felixstowe and around the Trimley villages. Since the findings of David Lock with regard to Brownfield land availability have been ignored, the only place where such a large number of unnecessary houses can be built is on Greenfield land around the Trimley villages.

This apparent determination to build on Greenfield land via Option Six is highly disturbing, especially since this preference was expressed despite the following “Negative Implications” for Option Six being highlighted in the accompanying Annex 2 -

·	Contrary to the Regional Spatial Strategy (RSS),

·	Allocating housing over and above that set out in the Regional Spatial Strategy could cause problems of blight,

·	There is no guarantee that the level of development set out or the locations identified would be agreed at the sub-regional level in the longer term,

·	Potential highway and other restraints,

·	Allocating such significant amounts of Greenfield land may have an adverse effect on other sites being brought forward, particularly Brownfield sites,

·	Lack of allocations in other areas could result in long term stagnation and decline and lack of willingness by others to invest.

3.3 A Dangerous Exaggeration of Housing Needs

It must be noted that there was a major misstatement - hopefully inadvertent - of future housing needs for Felixstowe and the whole of Suffolk Coastal District on page 3 of the Minutes of The Local Development Framework Task Group Meeting on 5 June 2006: “What was clear from the David Locke (sic) report was that a 23% increase in the number of dwellings in Felixstowe was required in order to meet the needs of the current population, and this was assumed to represent the district as a whole.”

Since “the district as a whole” has not been subjected to a regeneration study, and “the district as a whole” will not benefit from employment initiatives or investments in either tourism or infrastructure, the phrase “in order to meet the needs of the current population” logically implies a “Do Minimum” Scenario. Therefore, this claimed increase of 23% “in order to meet the needs of the current population .. in .. the district as a whole” is clearly wrong and grossly exaggerated.

The David Lock Report specifically states that only 311 houses are needed for Felixstowe in a “Do Minimum” Scenario. Furthermore, Annex 2 of LPTG 04/06 - Options for the Distribution of Housing - shows that over the next 15 years the number of houses to be allocated over the whole District is 3,360, or only 6.9%.

It is extremely disappointing that this obvious error was not recognised by councillors or officials, since it was not corrected at the subsequent Meeting of The Local Development Framework Task Group on 26 July 2006. Any representative of SCDC - either elected or employed - who uses this erroneous statistic as a basis for future planning discussions or decisions will be grossly negligent, in breach of their duty of care, and possibly liable to legal action.

3.4 The David Lock Options For Felixstowe Growth

According to David Lock’s Local Strategy for Felixstowe Peninsula, there are four Scenarios envisaged for the future of Felixstowe -

Ÿ	Scenario One: Do Minimum: With no new employment initiatives, no investment in tourist facilities, and minimum road and rail infrastructure spending there is a possible requirement for only 311 new houses.

Ÿ	Scenario Two: Moderate Growth: With no new employment initiatives and modest investment in tourism and infrastructure there would be a possible requirement for between 696 and 892 new homes.

Ÿ	Scenario Three: Going For Growth: With upgraded road and rail infrastructure, investment in the Town Centre, in an Enterprise Park, and a number of Tourism and Leisure initiatives there would be a possible requirement for between 1,293 and 1,795 new houses.

Scenario Four: Sustainable Large Scale Growth: This takes account of supposed job expansion at The Port of Felixstowe, plus promotion of Felixstowe as a Tourism and Leisure centre, Town Centre regeneration, and substantial infrastructure investment, there would be a possible requirement for between 2,353 and 3,395 new houses.

Important Note: Wherever David Lock Associates have identified a possible requirement for new homes they have also identified specific Brownfield sites within Felixstowe, or Greenfield separation sites on the edge of Felixstowe where these homes could be located..

4 STAG’s Position

STAG - Save Trimley Against Growth - is an action group originally set up to oppose “The Trimley Vision”, in which Trinity College, Cambridge, as major landowners on the Felixstowe Peninsula, have expressed a wish to build up to 1,500 houses around Trimley St Martin, as well as a supermarket. Since the Six Options presented in Document LPTG 04/06 and the preference for Option Six expressed by The Local Development Framework Task Group will undoubtedly have a severe impact on the future of both Trimley St Martin and Trimley St Mary, STAG believes it is a “stakeholder” in this matter and is thus entitled to make its views known.

It is STAG’s belief that there is a broadly comparable need for housing throughout the District - in villages and market towns as well as the Ipswich fringes and Felixstowe. We also believe that Trimley St Mary and Trimley St Martin should be regarded as villages in their own right and not as extended suburbs of Felixstowe. Indeed, surveys conducted by both Parish Councils have conclusively shown that the Trimley villagers overwhelmingly want to retain their separate identities. Therefore, the Trimley villages, on their own, deserve to retain their unique characters and identities and, as such, they have no more than the same small-scale housing needs as the other villages in the District. This position is expressly stated in Appendix 1 to LPTG 05/06 Settlement Hierarchy, in which both Trimley villages are designated as Key Service Centres where the scale of housing development should be limited to -

Ÿ	Allocations in the form of minor extensions to the village to meet local needs, and

Ÿ	Within the defined physical limits development in the form of Groups and Infill.

STAG strongly agrees that more homes should be built if there is a demonstrable need for them, especially affordable housing for first time buyers, low paid key workers and the generally less well off. But we also strongly believe that land for housing should be allocated fairly across the whole District to satisfy the needs of the whole District, and should not be concentrated on Greenfield land around either of the Trimley villages.

All conurbations within Suffolk Coastal District have a similar need for smaller houses and affordable housing, therefore it follows that where it is absolutely necessary to allocate Greenfield land for housing this allocation should be in small parcels with minimal environmental impact fairly distributed throughout the District, and there should be no areas allocated for large scale Greenfield housing developments concentrated in any particular place.

4.1 STAG’s Conclusion

STAG have reluctantly come to the conclusion that there seems to be a deliberately contrived policy by The Local Development Framework Task Group to “load the dice” to ensure that Greenfield land around the Trimley villages is included in future plans for large scale housing developments, even though there is no necessity to do so, because -

Ÿ	The requirement for new houses “to meet the needs of the current population” has been grossly exaggerated at 23%,

Ÿ	Statistics on which future housing needs decisions have been taken have not been updated since 2004 for houses built and houses given planning permission,

Ÿ	Predicted windfall housing developments over the next 15 years - previously estimated at 3,980 units - have been omitted from the statistics used to justify the various Options,

Ÿ	David Lock’s estimate that up to 1,795 houses could be built on Brownfield and Greenfield infill sites in and around Felixstowe has been ignored in favour of a much lower, and out of date ‘Urban Capacity 2004’ figure of 490 units,

Many of the assumptions made with regard to substantial job creation at The Port Of Felixstowe and elsewhere and thus supposed extra housing needs arising from a “Going For Growth” aspiration are mere estimates whose validity - or otherwise - will not be known for many years to come - possibly approaching the year 2021 and beyond,

Ÿ	The erroneous assumption has been made that most if not all of these supposed new employees will want to relocate to Felixstowe,

Greenfield land around the villages of Trimley St Mary and Trimley St Martin has been earmarked for large scale housing developments despite the fact that within the Settlement Hierarchy both villages are classified as Key Service Centres where the scale of housing development should be limited to ‘Minor extensions to the village to meet local needs.’

Ÿ	There is no policy requirement in the Regional Spatial Strategy to extend the Local Development Strategy beyond the year 2021, despite this being adopted as part of Option Six.

Ÿ	There has been no convincing attempt to justify any need to extend the Local Development Strategy beyond the year 2021 when Option Six was agreed upon at the 5 June Meeting and endorsed at the 26 July Meeting,

Ÿ	The assertion that Option Six is the only sustainable Option is perverse, in view of the acknowledged Negative Implications, especially since it contradicts the recommendation to adopt Option Five,

Ÿ	There is no justification for making housing allocations on Greenfield land around the Trimley Villages as a first phase.

5 Land Priorities for Housing Allocations

In considering the suitability of locations for house building throughout the District three basic Principles and Priorities should be strictly applied: -

Principle and Priority One: Wherever new homes are to be built it should be an absolute priority that Brownfield land is used in preference to Greenfield sites.

Principle and Priority Two: Brownfield land is a renewable resource, and Brownfield sites may become available for house building over the next fifteen years which are currently not identified. Such “unknown” Brownfield sites will include -

Ÿ	Schools which close as a result of demographic changes to the population,

Ÿ	Hospitals which close as a result of changes in government policy,

Ÿ	Factory closures, housing demolitions, land clearances and other Brownfield sites which cannot currently be identified or predicted.

Principle and Priority Three: Large areas of Greenfield land should not be allocated for housing until it can be demonstrated with absolute certainty that all suitable Brownfield land sites are exhausted.

Within Suffolk Coastal District as a whole the only area which has been subjected to a detailed regeneration study - by David Lock Associates - is Felixstowe. If the economic regeneration of Felixstowe takes place - to a greater or lesser degree - it is possible that there may be little or no release of Brownfield land through school and hospital closures, but without intervention to regenerate the rest of the District it is likely that schools and hospitals will close elsewhere over the 15 year period. These closures, plus the release of other Brownfield sites, will lessen any need for the development of Greenfield land.

The Local Development Framework Task Group has selectively relied on the findings of the consultancy exercise conducted into the regeneration of Felixstowe by David Lock Associates. David Lock’s Scenario Three - “Going for Growth” appears to have been used as a basis for the preferred Option Six. David Lock’s Scenario Three envisages, among other things, for Felixstowe on its own -

Ÿ	A population increase of between 2,800 and 3,900 people,

Ÿ	Extra employment created in a new Enterprise Park, despite the fact that the Blofield Business Park, which was granted Planning Permission in 1999, has been a resounding failure,

Ÿ	Plus other minor growth,

Ÿ	Plus town centre retail expansion,

Ÿ	A resultant possible requirement for between 1,173 and 1,613 new homes.

However, a major flaw with The Local Development Framework Task Group’s Option Six is that a “Going for Growth” strategy has been applied to The Haven Gateway as a whole. This is unrealistic since there are no aspirations for “Growth” anywhere other than for Felixstowe itself - no road and rail infrastructure improvements, no Enterprise Parks, no plans to fund Tourism or Leisure facilities, and so on.

Although not stated specifically in Documents presented to The Local Development Framework Task Group, it is assumed that Option Six includes provision for large numbers of new homes as a result of expansion of employment at The Port of Felixstowe. This expansion in employment related population and thus a supposed need for large numbers of homes has been used to justify Option Six’s large scale housing developments on Greenfield land around the Trimley villages. This is despite the fact that David Lock Associates specifically state that 860 of these jobs - and thus presumably houses - should be located across The Haven Gateway.

It is STAG’s position that -

1. There is sufficient Brownfield land and green separation land in and around Felixstowe to satisfy all of Felixstowe’s “Going For Growth” housing needs for the foreseeable future.

David Lock’s Felixstowe Peninsula Local Strategy Report has identified a number of large and small Brownfield and Greenfield separation sites in and around Felixstowe on which could be built between 1,293 and 1,795 houses, depending on densities. Therefore all reasonably predictable housing needs for the foreseeable future can be fully satisfied without encroaching in any way on Greenfield land.

2. In addition, STAG believes that David Lock’s assumption whereby jobs created are broadly equated to housing needs is fatally flawed and grossly overstates the actual need for future house building.

Up to 820 new jobs may be created at the Port, including 620 arising from the South Reconfiguration Scheme, and there may also be created an additional 860 Port-related jobs across the Haven Gateway. According to David Lock this equates to between 600 and 1,500 homes in the Haven Gateway. However, only 600 of these homes will be required within Felixstowe. In addition, this predicted increase in headcount of 820 at the Port depends on the fulfilment of future growth predictions which cannot be guaranteed, and the prospects of a further 860 Port-related jobs should be viewed with even less economic certainty. It is probable that some of these new Port and Port-related jobs will be filled by people currently living in the area. In addition, many more will be filled by people who will be willing to commute to work every day. (There are many factors which discourage people from relocating, including - convenience of children’s schooling, constraints of spouse employment, economic uncertainty, proximity to friends and relations.) Therefore the number of new houses required for employees who want or need to relocate will, in reality, be substantially less than the envisaged 600 to 1,500, including 600 on the Felixstowe Peninsula.

In the foreseeable future therefore, it must logically be concluded that there is absolutely no need for large scale housing developments on Greenfield land around either of the Trimley villages.

6 Conclusions

SCDC Planning Department have previously given the impression of supporting large scale house building on Greenfield land owned by Trinity College, Cambridge, around Trimley St Mary and Trimley St Martin. (For example, at a meeting in January 2005 between Stephen Brown, SCDC Planning, Policy And Development Manager and representatives of STAG, and various presentations made by Stephen Brown to Trimley St Mary and Trimley St Martin Parish Councils.) Since David Lock Associates have now identified suitable Brownfield and Greenfield separation sites for up to 1,795 new homes in and around Felixstowe there is now no need - at least for the foreseeable future - to build houses in large numbers around either of the Trimley villages. Suffolk Coastal District Council, as a matter of planning policy, must now categorically state that for the foreseeable future planning applications for large scale house building on Greenfield land around either of the Trimley villages will be opposed in principle.

Should Suffolk Coastal District Council include a substantial allocation of Greenfield land anywhere in the District for large scale housing development as being part of a recommended Option, this will be generally viewed by the electorate as -

Perverse,

Ÿ	Not required by the Regional Spatial Strategy,

Ÿ	In ignorance of the facts with regard to the current and future availability of suitable Brownfield sites, and

Ÿ	Failing in their duty of care to take sufficient account of demonstrable uncertainties regarding the accuracy, timing and achievability of estimated increases in employment.

In addition, if any support is shown towards large scale house building on Greenfield land in the vicinity of either of the Trimley villages, as well as being perverse, unnecessary and at odds with the facts, such an Option will also be seen as showing undue favouritism towards Trinity College, Cambridge.

7 Recommendations

1. On no account should particular areas of Greenfield land be earmarked for large scale housing development around the Trimley villages or anywhere else within Suffolk Coastal District until all currently identified Brownfield sites have been utilised.

2. Any large allocations of Greenfield land for house building around the Trimley villages or anywhere else within Suffolk Coastal District should be postponed for a number of years on the basis that -

·	 David Lock associates have identified sufficient Brownfield and Greenfield infill sites to satisfy all of Felixstowe’s housing needs for the foreseeable future, and

·	 Since Brownfield land is a renewable resource; it is probable that over a period of time currently unforeseen Brownfield sites, such as schools, hospitals and other locations, are likely to become available for house building purposes.

3. No Greenfield land anywhere should be allocated specifically to accommodate Port and Port-related employment until such time as it can be conclusively demonstrated that -

 Port expansion will in fact give rise to large scale employment, and

 A substantial percentage of these new employees will categorically want to relocate their homes to either Felixstowe or the Haven Gateway.

8 Questions for Councillors

No assumptions or estimates used to justify any Option should be assumed to be factual. Before accepting any Option, Councillors are duty bound, as elected representatives of the people, to ask the following questions -

1. Why have figures for houses built and planned not been updated?

2. Why have David Lock’s estimates of Brownfield land availability been ignored?

3. Why have windfall developments been omitted from historical statistics?

4. Why go beyond the year 2021 when there is no need to do so?

5. What is the likelihood of substantial numbers of jobs being created at the Port, especially in view of probable competition from Bathside Bay and the Thames Gateway?

6. What is the likelihood of substantial numbers of jobs being created via an Enterprise Park, especially since the Blofield Business Park has been a resounding failure?

7. If jobs are actually created via (5) and (6) above, when in the distant future will these jobs materialise and what will the real numbers be?

8. If substantial numbers of jobs are created, how many of the “new” employees will want to live in Felixstowe, and how many will be happy to commute?

9. If there is “reasonable doubt” today with regards to any of the above job justifications for building large numbers of houses on Greenfield land around the Trimley villages then why today is house building on Greenfield land around the Trimley villages being recommended?

Addendum

It is worth noting that in April 2006, villagers from Dolton in Devon, in a High Court action, defeated their local Council’s plans to build houses on Greenfield land on the grounds that the Council had -

Ÿ	Failed to follow its own policies and procedures with regard to the allocation of affordable homes,

Ÿ	Made no assessment of local housing needs, and

Ÿ	Had not waited for the results of a Parish Survey.

The number of houses involved at Doulton was only 14, and the Dolton Residents Action Group received £7,500 compensation from the Council to cover their legal costs. The issue in Suffolk Coastal District involves perhaps thousands of houses over a 15 year period, and our councillors and paid officials should bear this High Court action in mind during their ongoing deliberations.

“We have no plans to build houses round the Trimley Villages.”