ipswich.gov.uk

SITE ALLOCATION IP261 IS NOT SUSTAINABLE SOCIALLY BECAUSE:
1) THE SITE IS NOT SUITABLE WITH REGARD TO THE GYPSIES' OWN SAFETY:- a) There are many hazards nearby for unsupervised children: the A14 just up the bank from the site; the superstructure of the A14 bridge with its concrete pillars and sloping concrete sides where children already play and are in danger of falling into the path of traffic on Bramford Road; the railway line a short walk away; the river a short walk away; a large site full of derelict glasshouses with broken glass and unstable structures very nearby; the lure of the large recreation ground directly over the A14, and the old footpath at the north of the proposed site on the boundary, which has been a crossing point for pedestrians over the A14. As further evidence of the unsuitability of the site, we refer to the Gypsy and Traveller Accommodation Assessment p32, which includes among the main reasons that current sites do not meet the gypsies' needs: the lack of a play area for children, and the lack of safety of the site. b) There will be harmful effects on the health and wellbeing of the gypsies from the noise and poor quality air (traffic fumes) from the adjacent A14. The proposed Site Allocation therefore contravenes NPPF 109, which says that new development should not contribute to or be put at risk from, or be adversely affected by noise or air pollution. It contravenes Planning Policy for Traveller Sites clause 11e which obliges local authorities to consider the effect of noise and air quality on the health and wellbeing of the gypsies and travellers. The structure of caravans compared with houses does not allow for the possibility of insulating against noise. The likely noise level at this location is 70 Decibels, and Ipswich BC should not expect gypsies and travellers to live with noise pollution, or air pollution which would be unacceptable to the population in general. It contravenes Ipswich's policy CS11 Gypsy and Traveller Accommodation which says gypsy sites selected should be safe and free from pollution. It also contravenes policy DM26 which says that new development which could itself be significantly affected by the conduct of established or potentially noisy uses nearby will not be permitted: the A14 is adjacent.
2) THE PROPOSED USE OF THE SITE POSES DANGERS TO THE PUBLIC :- a) Reference to the map shows that there is a physical link to the existing 41-pitch gypsy site at West Meadows alongside the busy A14 which could mean that horses, pedestrians and children stray onto the A14 endangering their own lives and the lives of others. A member of the public was recently killed on the A14 in an accident involving a horse. Bramford already suffers a nuisance from horses left on private land in the village. The Ipswich land goes back beyond the proposed Site Allocation, giving scope for unauthorised expansion and unauthorised land uses even if only 5 pitches of the possible 20 are developed. Motorbikes may also use unsuitable routes overland between the gypsy sites.
b) This proposed development poses a real hazard to road safety. The location is hazardous because it is close to the A14 bridge which will limit views for oncoming traffic; it is close to the busy exit from Clarice House Health Club; it is opposite the entrance to Lumberjacks and the small and medium size commercial enterprises located there; Bramford Road via River Hill will become even busier as more traffic will use this route into Ipswich when the Fisons development of 176 residential dwellings and commercial units at Paper Mill Lane, Bramford is built; it is close to Bramford Road where two cars cannot pass because of parked cars; it is close to site IP029 (land opposite 674-734 Bramford Road) which is a proposed Site Allocation for 71 dwellings with their vehicles and associated extra traffic; there are dangers to the public from mud and debris on the road and large vehicle manoeuvring on sloping ground close to all these other road hazards. It is as if Ipswich are intent on locating the gypsies in the most dangerous place for the gypsies and the community.
c) The proposed Site Allocation does not prevent existing development, such as the adjacent Health Club and the commercial development opposite on lower ground, from being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air or water pollution (NPPF109). We are concerned that pollution is likely to occur as the site is large enough to allow gypsy business activities to be carried out, which is recommended in policy CS11b. 3) IT REPRESENTS AN UNREASONABLE CONCENTRATION OF GYPSY SITES NEAR BRAMFORD:- a) It does not represent a fair or rational allocation of sites across Ipswich or the Ipswich Policy Area. The proposed Site Allocation contravenes the recommendation in the 2013 Gypsy and Traveller Accommodation Assessment, page 18, relating to Ipswich Borough Council, which states that there should be more equity in distribution of provision of sites across the authorities. Bramford already has 95% (ninety five percent) of the Ipswich gypsy sites next to Bramford's boundary, on the Bramford side of the A14 at West Meadows. The proposed site IP261 is within walking distance (less than 1.5Km) from West Meadows, and there is also a gypsy site with planning permission in Bramford itself, 2Km away. b) Bramford is only a small corner of Mid Suffolk District Council's large administrative area, and is also adjacent to Ipswich Borough, but Bramford already has 29% (twenty nine percent) of the total existing gypsy sites over the whole of Ipswich and Mid Suffolk. Therefore, there is already a disproportionately high concentration of gypsy sites close to Bramford.
c) Ipswich BC have put forward no other alternative proposed gypsy sites. Ipswich BC Policy DM41 which is mentioned in the Site Allocation notification, makes clear that the land at River Hill is the only land allocated for the first 5 pitches. Ipswich has to provide 5 pitches by 2017, a further 6 by 2022, and a further 7 over the next 5 years, totalling 18 by 2027. River Hill site is large enough to provide for expansion. It appears to be Ipswich Borough Council's intention that all 18 pitches should be provided on the River Hill site by 2027. In fact they specifically consider in their section on alternative uses of the River Hill site (see Appendix D Alternatives in the Site Allocations Sustainability Appraisal): "allocating a larger area of the site for a greater number of G&T pitches (approx 20 pitches on up to 1 hectare)".
d) The government's Planning Policy for Traveller Sites clause 12 says that the scale of gypsy sites in rural or semi-rural settings should not dominate the nearest settled community, and clause 9d says that in producing their Local Plan, councils should relate the number of pitches or plots to the circumstances of the specific size and location of the site and the surrounding population's size and density. The proposed addition of 5-18 or even 20 pitches to the nearby 43 pitches around Bramford is unreasonable in this policy context.
4) IT HAS A HARMFUL EFFECT ON LOCAL AMENITY:- a) The proposal does not protect local amenity and environment, contrary to Planning Policy for Traveller Sites 9e. It would destroy a tract of greenfield countryside, replacing it with an unattractive development, as acknowledged in Appendix F, ET10, of the Site Allocations Sustainability Appraisal, which says: "IP261 has the potential to impact landscape character since it is identified as countryside and a Gypsy and traveller site would have mobile homes, touring caravans, cars, amenity blocks, etc". The Gypsy and Traveller Liaison Officer has confirmed that each pitch can consist of one or more static caravans, a touring caravan, amenity block and parking for various vehicles. Five such pitches are initially considered for this site, but Ipswich contemplate up to 20 pitches as stated above. The proposed Site Allocation would result in traffic problems restricting free movement to and from Ipswich, and would damage local ecology. b) It does not guard against the unnecessary loss of social and recreational facilities (NPPF70). Ipswich BC have been presented with the opportunity to enhance the western approach to Ipswich by selling the parcel of land in question to the adjoining owner, Clarice House Health Club, for use as a landscaped public park with an exercise area available to everyone, at no expense to Ipswich BC. This would have the double benefit of enhancing the green rim around Ipswich and contributing substantially to Ipswich BC's "Aim HW2", which is "to improve the quality of life where people live and encourage community participation". c) It does not provide a safe and accessible environment where the fear of crime does not undermine the quality of life or community cohesion (NPPF 69). We are concerned the site would have a significant adverse impact on the physical and social infrastructure of local settlements contrary to CS11c. 5) IT DOES NOT SUPPORT INTEGRATION:- a) The proposal does not promote integration and community relations as required in clause 11 Planning Policy for Traveller Sites. Although this site is located on Ipswich land, we are concerned the gypsy families will not integrate in Ipswich when concealed behind a major bridge and A14 trunk road which places them apparently in Bramford. The new gypsy residents are more likely to look to their gypsy neighbours to the north and across the village. Permitting Bramford village to be surrounded by gypsy sites will not help to achieve integration. b) With small, well separated sites, the gypsies can integrate more easily, but this proposed Site Allocation, even if limited to 5 pitches, defeats that object especially in view of the large site at West Meadows. It does not support community cohesion as required by CS11b. 6) IT IGNORES LOCAL PERCEPTIONS OF IDENTITY:- a) The constraints listed on the Site Allocation details for the River Hill site include the need to maintain the separation of Bramford village from Ipswich, but this proposal does the opposite. It would link the village to the town, whereas the Hyder Consulting Sustainability Appraisal document says at p19 that "when allocating sites for development, it is important to maintain the gap between Ipswich and adjacent villages to preserve local distinctiveness". Villagers are adamant that the town and village be kept separated. We note that Ipswich Borough Council intend to use their "separation" policy for their proposed Northern Fringe development, which they say "will maintain appropriate physical separation" of village from town. The same policy should be applied to the separation of Bramford from Ipswich. b) The proposal does not take account of local experience and perceptions. The public perception is that this site is in Bramford not in Ipswich, as the A14 is the physical boundary. Ipswich Borough Council appears to be aiming to unburden itself of its obligation to find gypsy sites in Ipswich by locating the site out of sight of Ipswich behind the A14 bridge in an area regarded as Bramford.
THE PROPOSAL IS NOT SUSTAINABLE ECONOMICALLY BECAUSE: -
a) We are concerned it will adversely affect local businesses. These include Clarice House Health Club and Day Spa, established for over 20 years and employing over 40 people. One of its attractions is its setting in parkland. Development of a gypsy site on land which adjoins Clarice House to the right and to the rear is contrary to NPPF 28 which requires Local Plans to promote the retention and development of local services and community facilities in villages, such as shops and sports venues. Opposite the site is a timber merchant which also sells garden hardware. There are several small and medium size commercial enterprises on the same development. NPPF 70 says that planning policies should ensure that established shops, facilities and services are able to develop and to be retained for the benefit of the community. The local businesses will make their own representations.
b) The proposal contravenes policy DM26, protection of amenity, which says that development that could lead to significant adverse effects on the amenity or environment of neighbouring uses - clearly including local businesses - will not be permitted.
c) Given the sloping nature of the site and its configuration and location, doubts must arise over whether the site is capable of being cost effectively drained and serviced as required by policy CS11.
THE PROPOSAL IS NOT SUSTAINABLE ENVIRONMENTALLY BECAUSE:
a) NPPF 114 says that local authorities should plan positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure (green rims, ecological networks). Policy CS16 relating to Green Infrastructure says Ipswich BC will work with partners to improve green infrastructure provision and link radial ecological networks with a publicly accessible Green Rim around Ipswich. Both the Ipswich Key Diagram, and Ipswich Local Plan plan 1 "Green corridors" show a Green Rim separating Bramford from Ipswich. Yet Ipswich BC propose an incursion into this Green Rim with consequent degradation of the ecological network of the Gipping Valley by developing a gypsy site which as Ipswich themselves acknowledge in their site constraints, may lead to soil contamination.
b) The ecology of the River Hill site IP261 and the Green Rim have been ignored by Ipswich BC in the River Hill Site Allocation. This contrasts with Ipswich BC's treatment of site IP029, land opposite 674-734 Bramford Road, which is just the other side of the A14 and on the opposite side of Bramford Road to this site, so shares similar characteristics. Site IP029 is said by Ipswich BC to have potential wildlife interest - a reptile survey will be needed, with mitigation where appropriate, and the design and layout for that housing site would need to support the wildlife corridor function of the railway and A14. Ipswich BC's comments made in 2007 for site IP029 said that the area next to the A14 "should be open space in recognition of the proximity of the A14 and railway line and the importance of this site in creating the Green Rim around the town". Yet no such constraints regarding ecology and the Green Rim are mentioned in relation to the River Hill site.
c) Bramford lies within Mid Suffolk district. MSDC's Core Strategy p18, Suffolk Vision, refers to establishing a network of open spaces and green corridors across the subregion. MSDC are known to discourage coalescence between villages, and therefore would not favour the joining up of Bramford and Ipswich by building over the Green Rim.