December 2020/ January 2021 bulletin

Sunnica, solar farm in West Suffolk –  Second Round of Public Consultation – Since SPS responded to the first round of public consultation in July 2019, we welcome the amendment to the Sunnica East site boundary which mitigates the impact upon the setting of the Freckenham Conservation Area. However, a number of concerns remain, primarily: failure to select a brownfield site in favour of a greenfield site, significant harm to the pattern of historic landscape, adverse impact upon the public right of way network, adverse impact upon residential amenity and visual amenity, and a lack of detail throughout the Preliminary Environmental Information Report. In particular this includes: insufficient information on size, scale and detail of the proposals, insufficient information on site selection, insufficient information on landscape and visual impact, inadequate use of embedded mitigation through good design, insufficient archaeological information, inaccurate or incomplete maps, visualisations and photomontages and no information regarding legacy benefits/environmental fund.

Sizewell B Relocation of Facilities – SPS continues to argue that this application is premature and should not be considered in isolation but should form part of the DCO application for Sizewell C. The rationalisation and reconfiguration that is necessary to facilitate Sizewell C means that SPS considers that this application should not be treated as a standalone matter. However, we acknowledge the recent unsuccessful judicial review of the council’s decision to approve a previous application. While we regret the loss of Coronation Wood, we welcome the amendment to EDF’s proposals which no longer propose to locate a car park on Pill Box Field, but rather to retain it as an undeveloped site and provide additional landscaping to enhance its landscape and biodiversity value. However we argue for greater planting to mitigate the landscape and visual impacts upon the special qualities of the wider Suffolk Coast and Heaths AONB.

Sizewell C Stage V Public Consultation – EDF submitted a further raft of documents within weeks of Registered Parties being invited to make their representations to the Planning Inspectorate. The changes were extensive, totally 15 separate areas including changes to the freight strategy and variations to the scheme as a result of detailed survey work being completed at an advanced stage. SPS argued strongly that it was unreasonable for EDF, after 10 years preparing this scheme, to make significant adjustments to the scheme after the DCO application has been submitted. Many of the issues to which the consultation related, including coastal defenses and traffic, were matters that have been raised by the community over many years. In particular the SPS raised concern about the lack of detail regarding the proposed acquisition of Pakenham Fen as offset mitigation for loss of wetland habitat at Sizewell.

MHCLG Consultation – Supporting Housing Delivery and Public Sector Infrastructure –  SPS has responded to the Government’s consultation on further relaxation of permitted development rights which will permit retail units to be converted to dwellings without requiring planning permission. The SPS has registered its concern that this relaxation would include all sizes of retail unit as well as those within conservation areas. The SPS is concerned that this would raise a number of risks for our beleaguered high streets including accelerating the decline of our retail centres, harming the architectural quality of some of our best historic high streets, giving rise to substandard homes with limited amenity and access to outdoor space, while eroding local democracy by further deregulation of planning control. 

East Suffolk Historic Environment Supplementary Planning Document  – The SPD provides guidance on the implementation of planning policy related to the historic environment. It will replace a number of existing documents, and will provide comprehensive guidance on a range of topics including conservation areas, listed buildings and non-designated heritage assets, sustainable construction and renewable energy. Technical guidance is given on making changes and alterations to historic buildings, including extensions, development within the setting of a historic building and also gives advice on how to go about appropriate maintenance and repair. It also includes guidance and information about shopfronts and historic gardens. SPS welcomes this updated guidance and was pleased to give comprehensive feedback on a number of specific technical and policy related points.

Suffolk Streets public consultation –The Councils of Suffolk have been working to improve the design of new development through the Suffolk Design initiative. As part of this programme, the County Council commissioned Stantec to produce a new Street Guide to update guidance for residential streets. SPS was consulted by Suffolk County Council on the emerging guidance which will assist with the design of new residential developments, showing how best to create sustainable transport layouts that promote walking and cycling. SPS welcomes this important initiative and made a detailed response to the emerging document. In particular we made comments relating to its status and the need for it to be adopted as Supplementary Planning Guidance if it was to carry adequate weight in decision making, the need to ensure the Road Adoption Team within the Highways Department was brought into negotiations at the very earliest stage to ensure that the schemes would be adopted by the council, the need for a much clearer recognition and commitment to sensitive management of change in the historic environment and the importance of conserving its character and appearance and finally how the guidance lacked sufficient emphasis on the importance of green infrastructure and the value of trees within our streets.

Local Plan consultations – SPS also responded to two local plan consultations before Christmas.  Read our responses on the  West Suffolk Local Plan Issues and Options consultation  and the Babergh and Mid Suffolk Joint Local Plan pre-submission consultation here

Ipswich Co-op buildings – SPS has responded to a consultation on plans for a new primary school in central Ipswich.  We support the proposed change of use of the land but have urged for a revised approach to the site which will retain the distinctive frontages of the locally listed Co-op buildings on Carr Street.  We also urged that in the event of total redevelopment any replacement buildings reflect the scale of the surrounding buildings to maintain a strong streetscape. The scheme is contrary to the Ipswich Local Plan which, in promoting the redevelopment of this part of the town, specifically requires the retention of the historic Carr Street facades.

Chilton Woods Reserved Matters (Infrastructure) Taylor Wimpey have submitted a reserved matters application regarding the infrastructure for the housing development site in advance of the Design Code for the site being agreed.  SPS is disappointed with this approach, considering that it is vital that the applicant engages with local groups and the community on a holistic approach to the design of the whole site. The submission of this application in advance of the consultation on the design code ending suggested an apparent disregard for the views of the local community and we consider this approach will deliver a standardised large housing estate development rather than the exemplar sustainable community which was promised at the outline application stage. 

Reydon Campsite, Ramsholt Campsite – SPS has raised concerns regarding separate applications for two campsites within the Suffolk Coast and Heaths AONB, in terms of their impacts on the landscape and the introduction of lighting and human activity into remote locations. Although tourism is vital to the ecomony of the area and is therefore  encouraged, it is also important to maintain the scenic beauty and tranquility of the AONB which draws visitors to the Suffolk Coast.

Needham Market 279 dwellings – SPS strongly objected to the development of a greenfield site to the west of Needham Market which, due to its rising topography would be particularly prominent on the rural edge of the town. It has not been allocated within the emerging Neighbourhood or Local Plans. A previous application for 152 dwellings was refused due to highway issues and the the site was considered to be an unsustainable location. It is not considered that the current application adequately addresses these points.

In addition, SPS has made representations on applications for development in Brent Eleigh; Higham; Stoke by Nayland; Erwarton

Lowestoft Post Office – SPS are disappointed to report that the proposed redevelopment of this listed building has been approved. Whilst the demolition of part of the redundant building was considered to represent a low level of harm, the failure of the scheme to bring back the upper floors of the post was considered to represent a missed opportunity for securing a sustainable use of the heritage asset. SPS also remains concern about the design of the dense development of new dwellings to the rear of the property. Such short-term thinking by East Suffolk Council is a matter of real regret.

Queensbury Lodge Stables, Newmarket – SPS welcomed the decision to refuse the application for 123 houses on a site that formed part of the setting of Fitzroy Stables, a designated heritage asset that is in a very poor neglected condition. The proposals were contrary to adopted local plan policy and we argued would harm the character and appearance of the Newmarket Conservation Area.

Shadingfield chicken sheds – SPS was disappointed by East Suffolk’s decision to approve this application for intensive poultry rearing which we argued would have negative landscape and heritage impacts. However, this decision was later challenged in the courts and the decision was subsequently quashed.

Sizewell B Facilities – As noted above the application to rationalise parts of the EDF estate to facilitate Sizewell C was approved by East Suffolk Council. Attempts to challenge the decision in the courts was unsuccessful, to the dismay of SPS and many others in the local community.  This scheme gave consent for the removal of Coronation Wood which was felled at the end of 2020.