Letter to the East Anglian Daily Times
Orford Deserves Better
22nd January 2007
Dear Mr Ridley
Planning Applications C/06/2321/FUL – Land North of Esmond House, Ipswich Road, Orford, Woodbridge – Erection of 11 Dwellings for local needs
1. The Suffolk Preservation Society (the Society) thanks the District Council for consulting it on the above application and appreciates the opportunity to comment on the proposed development. Set out below are the comments and responses of the Society. These will be circulated to all members of the North Development Control Committee Members, before the site visit on the 31st January and the application is determined.
Principle of Affordable Housing
2. The Society supports the proposal to provide additional affordable housing in the village. This is clearly essential to the future of the village and the community. It looks to the District Council and LPA to ensure the very best site is used and a scheme of the highest quality design and sustainability standards is provided.
Site Selection
3. The selection of the site appears clouded in mystery and subterfuge to outsiders and is not at all transparent. Clearly, in addition to the five sites specifically mentioned, there are other sites in and around the village which, from my inspection and understanding of the Society, appear to have clear advantages to the proposed site.
4. In order for the community and the Society to be assured that the proposed site is the best one, then all factual information relating to the selection of this site and the de-selection of others must be placed into the public domain. Until this happens, then it is impossible for the Council, as LPA, to make a proper informed decision or for any consultees to reply comprehensively. Surely the simple answer is to make available to all, the information made available to a select few on the other sites? Otherwise the Council is likely to be accused for withholding essential information, something the Society is sure it would wish to avoid.
5. It appears that sites within the village envelope, which appear available, have not been selected for various reasons. The Society and we suspect the local community, will need to be satisfied that these sites cannot be brought forward for affordable housing, in total or part, by the Council, utilising all of the powers available to them.
6. The Society might, if it is necessary, support the Council using its CPO powers to acquire accesses and egresses to a site more suited than the proposal and potentially less visually damaging. We understand there is such a site at the end of Peacocks Pyghtle. Why is the Council not using powers that the Secretary of State has suggested they use to bring the site forward?
7. The proposed site is outside the village envelope and is therefore an exceptions site. The Council’s own Local Plan states in policy AP37 in relation to such sites:-
Exceptionally, the District Council may be prepared to permit a small residential development to meet a particular local need for housing, for those whose incomes are too low to buy in the private market, and for whom there is insufficient rented accommodation which cannot be provided in any other way, on a site which abuts the physical limits boundary of a village, subject to the following criteria:-
(i) an proposal will be considered in relation to the scale and character of a village, the availability of services and facilities, highway safety, effect on the surrounding countryside and residential amenity. Proposals likely to set a precedent for ribbon development on the edge of villages will be resisted;
(ii) the local need for housing shall first have been quantified within an area to be agreed by the District Council;
(iii) the site shall be developed by a social need housing agency and subject to a legal agreement with the District Council, which provides for the permanent controls and management to ensure the retention of proposal for local need.
8. When considered against these criteria the current proposal fails on three accounts, these being:-
i. The Society suggests that the need can be provided in another way, potentially less damaging to the village;
ii. The proposal is not appropriate to the character of the immediate surroundings or AONB and this is highlighted in more detail in paragraphs 9 to 11 below and;
iii. It will set a precedent to other development and in fact the proposed layout specifically allows for future development of the adjoining field or a part of it.
Given that it fails important parts of the Council’s own criteria, the Society suggests it is not appropriate or desirable to approve it.
Design and Detailing
9. In addition to AP37 the proposal has to be considered against Local Plan policies AP19 and AP21. Having considered the proposal against the Council’s design policies and advice the Society has concluded that while they appear initially acceptable, on closer examination there are several design inconsistencies which warrant the proposal unacceptable. These include, for example:-
i. the modern highway access egress splay onto Ipswich Road out of character with the village;
ii. the width of the road;
iii. the inconsistency with the design approach of the adjacent affordable housing site;
iv. the excessive use of rendered elevations;
v. the inappropriate use of black weatherboarding usually only found on agricultural buildings;
vi. the modern unimaginative layout;
vii. the regular window pattern and general fenestration treatment;
viii. the dominance of provision for the motor vehicle both in terms of the placement of spaces for car parking and the design of the central estate road;
ix. the layout provides clearly for future development to the north-west and;
x. The weak landscaping scheme on the north-west boundary – it should be structural and far more significant and permanent.
10. This is effectively an estate road layout slightly disguised with sympathetic house types. It is neither Orford nor does it reflect the character of the AONB as required by AP21.
11. If this site was to be developed the Society would strongly suggest that both in order to reflect the materials of the immediate surroundings and this part of the village and more importantly, to harmonise with the adjoining affordable housing development, brick is used as the dominant external material and not render. The Society finds it difficult to understand the use of render in the proposal other than on the basis of reducing the cost. This is not acceptable on this critical site. Does the Council/LPA really want to approve a proposal that clearly can be substantially improved upon? Is this the standard they wish to be responsible for? Surely, with the Council’s involvement and public funding, this proposal should be setting the very best of examples to others. Can those involved really say it does?
Future development or the next phase
12. The potential problem with exception sites like this one is that they can leave the door open to further development. This should be avoided.
However, this proposal clearly makes provision for the possible development of the remaining part of the field to the north-west. Such provision is unnecessary, undesirable and has importantly stifled the layout of the proposal in the Society’s view.
13. The Council, Flagship Housing and land owner need to make their respective positions clear with regard to future development of the remainder of the field or part of it. Is further development an option at any time in the future?
Conclusions
14. The Society has recent, detailed and first hand experience of securing well designed affordable housing and I have attached details of the exemplar scheme at Elmswell now under construction. Orford, in the Society’s view, deserves nothing less but clearly less is on offer. Elmswell has established a new bench mark for affordable housing and this proposal falls well short of that proposal in design and, it appears, sustainability terms.
15. The clandestine way the site has been selected has not aided the debate about its suitability. There is now no reason why all the information relating to the other site options should not be made available to all those who are interested and concerned. Until this happens, then any decision on this proposal will be viewed with great suspicion.
16. Providing affordable housing in the village, which the Society without reservation supports, offers an opportunity to achieve something truly great and outstanding. Regretfully this proposal is neither great nor outstanding and is fundamentally flawed in some aspects to the point where planning permission ought to be withheld.
17. The Society offers to work positively with the local community, Flagship Housing and Council to achieve a better proposal, if is allowed to do so.
Yours sincerely
Richard Ward DipTP MRTPI
Director