Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document

Bramford Parish Council object to the allocation of site IP261 Land at River Hill, adjacent to Bramford, for a permanent Gypsy and Traveller site, under Ipswich Borough Council's policy DM41.
The proposal is unsustainable socially, economically and environmentally. The proposal and the conduct of Ipswich BC also fail to meet the requirements of the Statement of Community Involvement.
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, 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.
THE REQUIREMENTS FOR ECONOMIC, SOCIAL AND ENVIRONMENTAL SUSTAINABILITY IN PLANNING POLICY FOR TRAVELLER SITES CLAUSE 11 ARE NOT MET (WITH THE EXCEPTION OF 11g)
a) It does nothing to promote peaceful and integrated co-existence between the site and the local community (11a).
b) The site is effectively in Bramford, where there is no access to health services (11b).
c) The primary school in Bramford has no spare capacity and there is no secondary school (11c).
d) The development of a permanent site poses a threat of environmental damage contrary to 11d.
e) The proposal ignores the effect on the gypsies' health from the noise and fumes from the A14 (11e).
f) The proposal would place undue pressure on local road infrastructure in Bramford (11f).
g) If the site allows for living and working in the same location (11h), there is concern that damage to the environment will occur.
h) There is only one aspect which complies with the sustainability requirements in this policy: the site is not itself in a flood area (11g).
SITE CONSTRAINTS IDENTIFIED BY IPSWICH BOROUGH COUNCIL:
Although Ipswich Borough Council has not considered any possible alternative gypsy sites, they have considered alternative uses for the River Hill site: to retain the existing use as grazing land, or to develop the site for housing or to allocate more of the site for up to 20 gypsy pitches. Ipswich BC themselves identify the following site constraints for River Hill in their Site Allocations Sustainability Appraisal Appendix D: use as a gypsy site may cause disturbance to land and lead to drainage problems, and result in potential contamination of land if there are business activities on the site. Ipswich BC also identify problems of extra traffic, poor visibility for traffic, and the impact on air quality, noise and access constraints. They state that allocating a larger area of the site for a greater number of pitches would increase negative impacts on soil and drainage, and increase traffic and air quality impacts but would provide more homes for gypsies and travellers.
IS THERE AN ALTERNATIVE SITE?
No alternative gypsy sites are offered by Ipswich BC. However, the proposed Northern Fringe development is a suitable location for gypsy sites as it will have all the infrastructure and facilities listed in Ipswich's Gypsy and Traveller Accommodation policy CS11, delivered within the required timeframe. Incorporating 18 gypsy pitches in 3 sites on the Northern Fringe development in a scheme of over 3000 houses (the Northern Fringe is divided into 3 regions) from the outset would we consider cause less friction than imposing it on an existing development now or later. The gypsy sites could be counted towards the 35% affordable housing proportion to which Ipswich is committed. The GTAA clause 2.3 says that public sites for gypsies are a direct equivalent to social housing among bricks and mortar tenants.
The Northern Fringe is in fact an opportunity for Ipswich BC to demonstrate how to successfully establish Gypsy and Traveller sites which work well because they comply with all the necessary requirements for the gypsies' welfare and the gypsies would be integrated from the outset. Instead, Ipswich BC have selected an unsafe site by putting forward the River Hill proposal, while the site clearly does not comply with the required standards.
A number of the other Site Allocations in Ipswich or sites elsewhere in the Ipswich Policy Area may comply with all the requirements of CS11. However, in the Public Meeting held on 13 February 2014, Ipswich Borough Council provided no evidence that they had considered any alternatives to the River Hill site. It is the responsibility of Ipswich BC to put forward sites which are socially, economically and environmentally sustainable and which comply with the NPPF, the government's Planning Policy for Traveller Sites, the Gypsy and Traveller Accommodation Assessment, Ipswich's policies CS11 Gypsy and Traveller Accommodation, CS16 Green Rim, CS6 clause 8.74 Ipswich Policy Area, DM26 Protection of Amenity, and the Statement of Community Involvement. On all these points, the River Hill allocation fails.
IPSWICH BC HAVE NOT COMPLIED WITH THEIR OBLIGATIONS UNDER THE NPPF AND THEIR OWN STATEMENT OF COMMUNITY INVOLVEMENT BECAUSE:
a) Ipswich Borough Council's Statement of Community Involvement states that where a Development Document identifies a proposal relating to a specific area of land, the Council will post notices in prominent locations within the area. They did not post such a notice at River Hill. Communication originating from Ipswich, directed to the community and the Parish Council, has been non-existent.
b) Policy CS6, Ipswich Policy Area, says at 8.74 that neighbouring authorities including Parish Councils will have the opportunity to comment at all stages of production of the Local Plan (which starts with consultations with the local community about where housing should be built). Bramford Parish Council received no direct notification from Ipswich Borough Council of the proposal to allocate a site which affects us.
c) Policy 6a of Planning Policy for Travellers requires Councils to pay particular attention to early and effective community engagement with settled and traveller communities. There has been no engagement with the community of Bramford.
d) Local authorities are obliged by Planning Policy for Traveller Sites 9c to co-operate on planning issues that cross administrative boundaries, and this issue crosses Ipswich Borough and Mid Suffolk District. NPPF says Local Plans should be based on co-operation with neighbouring authorities. Joint working on areas of common interest is to be diligently undertaken for the mutual benefit of neighbouring authorities (NPPF 178, 179), and planning authorities will be expected to demonstrate evidence of having effectively co-operated to plan for issues with cross-boundary impacts when their Local Plan is submitted for examination by the government (NPPF 181, 182). Ipswich BC has either failed to inform MSDC, or MSDC has failed to inform us.
e) Ipswich BC have made a mockery of the consultation process by failing to put forward any alternative gypsy sites when they published their consultation document. Any further consultation on the remainder of the 18 pitches is equally meaningless until other sites are put forward for consultation. If these sites are to be in the Ipswich Policy Area as suggested in clause 5.19 of policy DM41, then those sites cannot be supported in or adjacent to Bramford which already has adjacent to it 95% of Ipswich gypsy sites and 29% of gypsy sites in the whole of Mid Suffolk. We remind Ipswich BC that GTAA clause 6.5 says that the location where the need arises is not necessarily the same location where the need can be met.
f) One of the requirements of "soundness" for the independent planning inspector to consider is that the contents of the Ipswich BC's plan are justified. The definition of Justified in NPPF 182 is "the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence". Limiting the selection to one site cannot be justified as a decision unless Ipswich can demonstrate to the satisfaction of consultees that the site has been considered against all other possible alternative sites and that all those sites, wherever they occur, have been dismissed using robust evidence which clearly and conclusively demonstrates their unsuitability under the requirements listed in the various planning policies referred to in this objection document.
g) A few years ago, Ipswich imposed onto Bramford's skyline, the tall building known as Landmark House. There was no notification to Bramford Parish Council, either by Ipswich or MSDC, and no consideration of the effect on the village. That building has permanently marred the village of Bramford, and there is great local resentment which was conveyed to Ipswich and MSDC.
h) The fact that Bramford is a village and is within the Ipswich Policy Area should not allow Ipswich free rein to impose any inappropriate developments on Bramford.
Bramford Parish Council's response to IP261 follows a Public Meeting on 13 February 2014 attended by over 300 people when Bramford residents and businesses voiced their opposition to Site Allocation IP261 and their dismay at the conduct of Ipswich Borough Council. Mid Suffolk District Councillors also confirmed the lack of notification to MSDC by Ipswich BC.
We have sent a separate email response about policy DM41, and a response as to whether the DPD is sound.