SAFE – Supporters Against Fressingfield Expansion

Breaking News

Three new important documents are now available for consultation:-

Babergh and Mid Suffolk Joint Local Plan. –   Click here to view . Public Consultation closes on 30th September 2019.

Fressingfield in the Diss Express – “Development plans met with opposition but council’s support” To read the story, please click the link – This external link leads to the Diss Express website

A New Planning Application for housing in School Lane -(DC/19/03513) –  Click here to view. This new  Application reduces the number of houses in the previous Application from 18 to 12 and includes 7 bungalows. Public consultation closes on 25 August 2019 – Consultation has now been extended to 3rd September 2019, because of a delay in displaying the Planning Notices

SAFE has sent an objection which is shown below. Others wishing to comment should quote the Planning Number and send them to

planningyellow@baberghmidsuffolk.gov.uk

Members of SAFE will be sending in individual comments.

Objection to Planning Application DC/19/03513- Land West of School Lane Fressingfield

We object to this application because

  • it would not deliver sustainable housing because

its location would not reduce travel in accordance with the draft Local Plan

the increased travel that will be caused will be car dependent because the very limited public bus service (Saturdays only) is to be cut

this will increase CO2 emissions overall and emissions from transport in particular

  • there are existing constraints on flooding, pollution and road safety acknowledged by SCC and MSDC in their decision to refuse three further applications in the village (1432/17, 1449/17 and 1648/17). Committee report attached.
  • The cumulative impact of the proposal alongside the approval of a Baptist Chapel with substantial car parking on the adjacent site (3872/17) and a new scout hut with 26 houses (4410/16) will severely aggravate these constraints
    These amount to significant adverse impacts which are not capable of mitigation.

The new Application for the School Lane site reduces the numbers of houses from 18 to 12. The Application is submitted by the developer, but the ownership is clearly with the Trustees of the Baptist Chapel.

All of the reports, other than the Planning Statement, are way out of date and were commissioned by the Baptist Trustees to support the Application for the building of the new chapel. The dates of the reports are as follows:-

Ecology Survey – January 2015

Newt Survey – June 2016

Flood Risk Assessment – March 2015

Tree Inspection – May 2016

How can reports which are so out of date be relied upon to support this Application?. This is especially relevant as much has happened in the intervening four years and new information is available.

Ecology and Newt Survey.

In 2017 there were four separate sightings of greater crested newts in Post Mill lane. The newts were photographed and Suffolk Wildlife were notified. Post Mill is approximately 150metres from the Application site. In 2018 three greater crested newts were discovered in a greenhouse at the Old Vicarage. The newts are around in the village. This is not reflected in the out of date survey.

Flood Risk Assessment

This is an area of major concern. Since March 2105 there have been a number of instances of flooding and egress of sewage in Low Road. Anglia Water confirmed at a meeting in October 2018 where the senior Planning Officer, Vincent Pearce was present together with the Ward Councillor, that the problems relate to rain water entering the foul sewer. Until this meeting the cause of the problems was unknown. Households cannot be forced to remove rain water connections to the sewer and most households to not know if they have such a connection. More new houses will take up more of the capacity within the foul sewer thereby reducing the capacity for surface water. Whilst the house numbers have reduced from 18 to 12 in this Application 12 more large homes discharging into the foul sewer will be significant.This will increase the likelihood of off- site flooding, contrary to the NPPF. The Director of Public Health has described this issue as a health hazard and reported the matter to Public Health England. None of this is addressed in the Plandescil Report dated March 2015 as the issue was not known. This report cannot therefore be relied upon to support this Application in the assertion that the development with not result in off site flooding.

Surface Water Drainage Strategy

The Application form for this development clearly identifies the surface water drainage being discharged through a SuDS. This is highly unlikely! Paragraph 3.5 in the Plandescil Report dated March 2015 states ” Infiltration drainage would be the preferred method of disposing of surface water runoff, however the presence of Lowestoft superficial deposits underlying the site will reduce the infiltration potential of the ground.” Whilst the Report is old the ground conditions will not have changed. Subsequently during design development of the Chapel Scheme it was confirmed that SuDS were not feasible and water discharges ultimately to the Beck. The system depends on holding excess water in underground crates and controlling the flows at times of heavy rainfall by means of an attenuated system. Anglia Water have agreed a maximum flow rate of 5 litres per second for the entire site.

It is impossible to ascertain what is assumed for the site in terms of the surface water drainage. There is no information on run off rates. Whilst the housing numbers have fallen the introduction of 7 bungalows will increase the footprint of the buildings and roof runoff. The Plandescil Report of March 2015 shows the drainage from the housing site linking up with the drainage for the chapel site. This immediately raises a number of issues. We understand that the drainage Condition in relation to the Chapel has yet to be discharged. We know that the SCC Flood and Water Management Officer raised major objections over the drainage strategy, which we believe remain unresolved. Under a Freedom of Information Application we received copies of emails where the Water Management Officer states” There is a significant risk to worsening the existing flood risk in Fressingfield. ”

We have always been concerned that the rate of 5 litres per second is for the whole site. How is this ” allowance “to be apportioned between two owners?. How is it to be monitored?. We have been informed that the housing site is 4 ins lower than the chapel site, this could possibly exacerbate an already difficult situation.

In summary we are very concerned at the complete lack of any updated information on this within the Application and the very real potential for an increase in off site flooding.

Housing Mix

The Application is for 12 houses, seven of which are bungalows. All of the housing is described in the Application as ” Market,” none are earmarked as “affordable”. This runs contrary to all of the guidance which requires all developments of 10 or more house to provide 35% affordable homes. The previous Application did include 6 affordable homes and whilst there is not a large demand in Fressingfield there are local families on the waiting list and the 4 houses, which should be within this submission, would have helped meet this local demand. The Application simply ignores the rules and makes no mention of affordable housing provision. This is wrong.

Traffic Movements

There is no investigation into projected traffic and pedestrian movements likely to be generated by this development and whilst the development is relatively small to make no mention of this is unusual. This is especially relevant as all of the additional traffic will pass in front of the school The safety of school children has repeated been raised as an issue. Currently School Lane is a cul de sac. It will become a through road to the chapel and housing development. Additionally the majority of traffic leaving the residential site will pass through Jubilee Corner thereby increasing pressure on what is recognised to be a dangerous junction for both traffic and pedestrians due to the lack of footways.

Compensatory woodland

The Application forms states that there is no woodland on the site. The site is currently covered by a wood. The chapel scheme also resulted in the loss of a wooded area and offered compensatory land for a wood in New Street. What are the proposals for the housing site? Can a Planning condition be imposed that the compensatory woodland be planted once a start on site is achieved?

The location of the compensator woodland was changed to a location outside the village. In New St it would have provided an amenity for the village and linked up village wildlife areas. We object to the change of location.

Biodiversity

There is no attempt to introduce any biodiversity onto the site, contrary to the NPPF and emerging Local Plan.

Other Key issues relevant to all recent Applications for major development in Fressingfield.

The three recent major Planning Applications did highlight many issues of concern to local residents which may be summarised as follows:-

Road Safety in New Street

New Street is effectively the High Street of the village. The shop, surgery, scout hut and Methodist Chapel are located there. Much of the length of New Street is without footways and this cannot be corrected as houses immediately abut the narrow Road. There are many unreported minor accidents in the New Street area.

The road safety issues were noted by SCC in their recommendation for refusal of applications 1648/17 1449/17 and 1432/17 dated 2nd November 2018 (attached), on the grounds that ‘further traffic passing along New St [the core of the village] and/or through Jubilee Corner would cause an unacceptable impact on road safety particularly of vulnerable users.’The same issues apply to this application, which is governed by the revised NPPF to which SCC refers (unlike the outline application). These issues are not capable of mitigation for the reasons set out in SCC’s letter.

Lack of sustainable transport

There is on bus per week, (which is likely to be removed ). There are no cycle routes and all journeys require private transport. More traffic must statically result in the increase in accidents.

Lack of capacity in the Surgery

Whilst the surgery has confirmed that currently they have some spare capacity waiting times for appointments have increased significantly. Parking at the surgery is a major problem with patients now parking along New Street being unable to get into the car park thereby exacerbating the problems in New Street.

Capacity at the Primary School

Whilst this development will be adjacent to the Fressingfield Primary School Mr. Neil McManus (Development Contributions Manager at SCC) wrote on 7th August 2019 concerning this development (shown on the MSDC Planning portal). “The local catchment schools are Fressingfield Church of England Primary School, Stradbroke School and Thomas Mills High School. Based on existing school forecasts, SCC will have no surplus places at the catchment primary school and sixth form.” The potential for expanding the school further may be compromised by the emerging NDP as the school playing field is identified as a Designated Green Space.

Employment

There are 64 Whole Time Equivalent jobs in the village. Most of these require a higher degree, nurse, teacher doctor. The main employer locally is C. P Davidson, employing about 50 staff but this is out of village and requires transport to get to work. The majority of people living in the village therefore have to leave by car each day to get to work.

Pre-Application Advice

It is noted that the Applicant did not seek any Pre-Application advice from the LPA. It is a pity that this was not done as the LPA are well aware of the constraints of the School Lane site.

Conclusion

The proposal is supported by out of date historical reports which were commissioned by the Trustees of the Baptist Chapel and focus primarily on the Chapel site itself they are not fit for purpose for the current Application, particularly in respect of the drainage and flooding.

Should the Planning Authority reject this Application this will assist in meeting the housing targets for Fressingfield during the next Plan Period in a more measured way, allowing development to be slowly assimilated.

The case is extremely weak, fails to investigate fully the issues and merely focuses on the fact that lower level buildings will visually impact less on those neighbouring the site.

We strongly object to the scheme as there is no up to date tangible evidence that the scheme will not result in increased harm in the village, contrary to NPPF and emerging Local Plan.

PDF – SAFE Objections to Planning Application – School Lane

 

Fressingfield Neighbourhood Plan – Click here to view. Public consultation closes on 27th September 2019.

SAFE have considered the revised Neighbourhood Development Plan which has now been formally submitted to Mid Suffolk District Council. Mid Suffolk are now inviting further comment as part of the consultation process.

The members of SAFE recognise the vast amount of work and thought that has gone into the production of the Plan and are grateful to the Working Group for this. It is good that many villagers took the opportunity to attend the open events and expressed their views to the Working Group.

SAFE members have some points of detail which we will be submitting to Mid Suffolk, but we do support the adoption of the Plan.

The Neighbourhood Development is important as, once adopted , it will be a statutory document and Mid Suffolk will be required to take note of the recommendations within the Plan. It is an important document in helping to ensure that speculative development is not approved. This document will only carry full legal weight once it is adopted. That is after the village votes on whether to approve the Plan in a referendum to take place in due course.

SAFE expects to consider all of these documents in detail shortly


Accidents continue in Fressingfield

In the centre of Fressingfield, two cars collided. There was significant damage to both cars, but fortunately no significant personal injury.

War Memorial Accident 15.07.19

Three days before a vehicle damaged the side of a house close to Jubilee Corner by the Old Forge, causing damage to the structure.

Damage to House at Jubilee Corner 12.07.19

Recently railings along the Beck were damaged in Low Road close to the War Memorial.

Low Road Fence


Post Mill Appeal

An Appeal was lodged on 23/04/19 against the unanimous decision by MSDC in November to refuse Outline Planning Permission for the Post Mill development, Fressingfield (1648/17), Appeal number APP/W3520/W/19/3227159.

Mid Suffolk District Council Statement of Case – Prepared by Vincent Pearce is now available and can be viewed by clicking here

Click here to view the Appeal on the Planning Inspectorate Website: Planning Inspectorate – Post Mill Lane

The grounds for the Appeal can be accessed by clicking here: Appellant’s Statement of Case

More detailed information can be accessed on the Mid Suffolk Website here: Appeal Correspondence – Post Mill Lane

The Inspectorate Case Officer is Mr Simon Dunn. It is very important that comments are received from villagers. This can be done on line on the Inspectorate web site or by email to east2@planninginspectorate.gov.uk – Please quote the Appeal number APP/W3520/W/19/3227159

Comments MUST be submitted by 27th June. (Now Closed)

Final comments are now available:

MSDC Final Rebuttal

Appellant’s Final Comments

MSDC Rebuttal – Appellant’s Claim for Costs

 

Please encourage others to read this posting.

The timescale for the Appeal is as follows:-

Up to 11th July the Appellant and the Local Authority can make further comment on each other’s case. (The public can only comment on gross errors and misrepresentations and the Inspector does not encourage further comment at this stage.)

Week beginning 5th August. The Inspector will visit Fressingfield. He/ she will be accompanied by a representative of the Appellant and the Local Authority. They are only allowed to answer questions put to them by the Inspector and not to make spontaneous comments. Others should not be at this site visit.

A decision on the Appeal should be available about six weeks after the site visit.


SAFE has already sent a letter to the Inspectorate and a copy is below:

SAFE (Supporters Against Fressingfield Expansion) comments on Appeal (APP/W3520/W/19/3227159) on the unanimous rejection by Mid Suffolk District Council of building at Post Mill, Fressingfield (1648/17)

More detailed analysis of the comments on this paper can be found on the SAFE website fressingfieldhousing.org

Fressingfield is a small, agricultural village on the Suffolk/Norfolk border with about 350 houses in the core the village and a total population of just over 1000 in the Parish

  • This appeal relates to the extension of an existing housing estate of 25 houses, making a total of 49.
  • Two hybrid Applications (3872/16 and 4410/16) including 46 houses and two large community facilities were approved in 2017 but have not yet been built, (plus 5 windfall houses). These will generate about 100 additional cars and 120 residents. The full cumulative impact with these is unknown, but an Environmental Information Regulations application to Suffolk County Council (SCC) disclosed an email to MSDC dated 16th April 2018 from the lead flood authority has already highlighted a significant risk to worsening the existing flood risk in Fressingfield” in connection with Application 3872/16 (a stone’s throw from the Appeal site).
  • In a scientifically sound petition, visiting every house in the central village, 94% of villagers were against major development (such as Post Mill) and in favour of no more than 5 homes per annum.
  • As a Primary Village, provisionally a Hinterland village together with the proposals in “The Right Homes in the Right Places” we would be expected to build no more than 5 homes per year. This is supported by the Parish Council and the Pre Submission Consultation Version of the Fressingfield NDP. With the approved and projected windfall houses we have met our housing targets for the next 20 years.
  • At the November 2018 Planning hearing one councillor strongly urged that developments for Fressingfield should not be considered until the 2 approved sites had been developed.
  • 93 villagers submitted objections to the Post Mill scheme in their own words and of their own volition.
  • Traffic and road safety are of great concern. The Post Mill site exits onto the main street (New Street) where the shop, medical centre, scout hut and Methodist Chapel are situated. It is a very narrow road, is frequently congested and has no pavement for much of the road.
  • New Street culminates in a complex 5 way junction. (Jubilee Corner)
  • A recent traffic monitoring survey situated in the midpoint of New Street, presumably commissioned by the developer, would have underestimated the traffic volume as no account would be made for traffic coming from Jubilee Corner visiting the shop and turning immediately or traffic visiting the surgery from the west of the village. The survey was undertaken in February 2019 – one of the quietest times of the year for an agricultural village.
  • The proposed footpath from Post Mill to New Street opens onto a blind corner in New Street.
  • 24 dwellings in Post Mill would be expected to generate 48 vehicles and 55 extra residents all accessing the school, shop, surgery, places of worship and the two pubs, via New Street.
  • In the Post Mill Application, 8 of the homes have been designated as “Affordable”. Within the two major developments already approved, there are 18 “Affordable” homes. Currently there are 8 families with local connections on the waiting list for affordable housing. The two already approved developments will exceed local need.
  • There are no cycle routes in Fressingfield. Cycling is not a realistic sustainable transport option.
  • Fressingfield is 4.5 miles from an A road and 5 miles from the nearest small town. It is 12.4 miles to Diss railway Station and 62.9 miles to the nearest motorway. The nearest District Hospital is either Norwich or Ipswich each approximately 28 miles away.
  • The needs of disabled residents and those with impaired mobility are not considered in the application i.e. are no facilities for disabled people in the village.
  • We have a primary school (nearing capacity), but no senior school, so older children exit the village for secondary education.
  • The medical centre is adjacent to Post Mill. The surgery car park is frequently full and this leads to on street parking in New Street adjacent to the Post Mill entrance.
  • We have only one bus A WEEK.
  • There are only 64 Whole Time Equivalent jobs in the village, so most adult workers will have to journey out of the village by car to work.
  • Lack of local facilities and dependence on motor vehicles, combined with no mains gas means that our Green Credentials are poor.
  • Low Road is at the bottom of four steep slopes and is the route of the Beck and of the village’s sewer. Recurrent significant surface water flooding has been recorded and photographed since the 60s. The surface water drainage strategy at Post Mill takes no account of off- site flooding.
  • Flooding already occurs at the lower end of New Street.
  • There is a serious problem with sewerage. At times of heavy rainfall manhole covers lift causing raw sewage to enter the roadway and residents’ gardens. This occurred four times in 2018 and a clean-up team was needed on one occasion because of the level of contamination. Anglian Water has investigated the problem and conclude this is due to historic surface water connections to the foul sewer. ANY further building will exacerbate the problem as more houses will result in more sewage and less capacity in the sewer at times of heavy rainfall. Recent attempts to modify the pumping station have failed to solve the problem.
  • The problems of flooding and sewage egress are long standing, but becoming more frequent. It was documented in correspondence in 1988 between our then MP, Michael Lord, and Anglian Water’s CEO.
  • Anglian Water have confirmed to us and the LPA that the situation cannot be rectified. To increase the size of the sewer will reduce the flow rate during normal periods and will result in blockages and smells.
  • The Suffolk Director of Public Health formally reported this as a health hazard.
  • The proposed development lies outside the settlement boundary in Fressingfield.
  • The proposed development at Post Mill is on the brow of a Hill and will impact visually on the rural aspect when viewed from the Harleston Hill, especially when the deciduous foliage screen is bare.
  • Fressingfield is important in having a significant Conservation area, 58 designated heritage buildings two of which adjoin the appeal site, and other important non designated heritage assets.

The aim of the National Planning and Policy Framework is to achieve sustainable development: ‘meeting the needs of the present without compromising the ability of future generations to meet their own needs’. For the reasons set out above, the proposed development would not meet these requirements.

TEN KEY POINTS

In summary the proposed development is NOT sustainable because it would:

  1. fail to take account of the cumulative impact of 46 houses agreed but not yet built
  2. bring more houses to the village than policy has allocated
  3. bring new residents to the village with no collocated employment opportunities
  4. fail to adapt to climate change by increasing car travel to/from facilities the village does not have
  5. fail to prioritise pedestrians by radically increasing traffic along the core pedestrian route
  6. fail to minimise pollution by introducing yet more sewage to a defective system
  7. further exacerbate flood risks that cannot be mitigated
  8. compromise the heritage of the conservation area and the two listed buildings adjacent to the site
  9. compromise the landscape setting of the village, identified as unusual for Suffolk
  10. introduce a housing estate of almost 50 houses, entirely out of character for a rural settlement.

SAFE Response – PDF


Members of SAFE have produced individual submissions to the Inspector:

  • Observations on the Post Mill Appeal
  • Appeal Examination Response.
  • General Heritage Issues
  • Heritage Issues at Ladymede Cottage, New Street Fressingfield .
  • General implications for Post Mill Development.
  • Effects of Development at Post Mill
  • Comments on Transport and Road Safety Aspects of the Post Mill Lane Appeal
  • Traffic in New Street
  • Sewerage and Flooding

Observations on the Post Mill Appeal

Introduction

I live in Fressingfield and object to the proposed extension of the Post Mill site (21 houses) by a further 24 dwellings. This would create a housing estate of 45 houses.

I have looked critically at the Appellant’s Statement of Case and 2 new appendices and have made, what I hope are objective comment in the light of my local knowledge and my limited knowledge of the planning process.

Appellant’s Statement of Case

Para 2.8

” Fressingfield is a Primary Village”.

Under the current adopted Local Plan a ” Primary” Village is deemed capable of modest increases in housing. The ” allocation” to primary villages in Mid Suffolk is around 5 houses a year for each of the 11 primary villages. Fressingfield has exceeded this target year on year. There are 51 houses in the village with Outline Approval, but not yet built.

The draft NDP supports these figures and confirmation has been received from Mid Suffolk District Council that the houses approved, but not yet built can be included within the NDP planning targets. When the NDP is approved we can demonstrate we have met our housing targets for the next 20 years.

Para 8.Position Regarding Housing Land Supply

The current position of MSDC is that they have slightly in excess of a 5 year land supply.

Para 9.1.1

” Proposes 24 new homes 8 of which will be affordable”.

Throughout the Appellant’s case a significant benefit is deemed to be the provision of affordable homes. Currently there 8 families with local connections waiting for “affordable Housing” The developments already approved include 15 affordable homes. Local need is therefore more than met. To exceed the target even further will require bringing families from out of area, to an isolated village with one bus a week, almost no employment, no secondary school, no green credentials.

Para 9.1.3

“The village is growing – with facilities responding to this growth”

The report then cites the proposed new scout hut and Baptist chapel as the new facilities responding to growth. Both of this facilities are replacements for existing provision. A significant number of the Baptist congregation come from outside the village and 70% of the scouts do not live in Fressingfield. These replacement provisions are not responding to growth in the village.

Many community activities take place at the Sancoft Hall and the Social and Sports club. It is difficult therefore to make the connection between more houses and the replacements facilities mentioned.

Para 9.1.4

” Fressingfield is a successful rural village”.

Agree that Fressingfield is a successful village, but the limitations in its facilities and isolated position are serious considerations when deciding how much new housing can be sustained. The nearest A road is 4 miles away; there are only 58 whole time equivalent local jobs. 24 of these require a degree level qualification e.g. teachers, nurses, doctors. The nearest hospital is 26 miles away; the village shop has only one till and is not a “super market” in the conventional sense.

With only one bus a week and no cycle routes the working population leave the village by car to go to work.

Para 9.1.10

” No manner in which a proposal for 24 new homes can be considered a significant increase in the context of the village.”

It is recognised that MSDC made an error in stating that there 1080 homes in the village. It is correct that the figure of 1080 relates to the population figure for the Parish. Fressingfield is a physically large Parish with 450 homes within the physical boundary. It is estimated that there are around 350 houses in the core area of the village. 24 new houses would represent an increase of 7% or more importantly the total of the Post Mill development including those already built (21homes) would result in the Post Mill housing estate representing 13% of the houses within the village core. This, one could argue, is a highly significant figure. This will be a large scale urban development out of character within a rural village.

Para.9.2.5

“In order to refuse the application a decision maker must be satisfied that the harms significantly and demonstrably outweigh the benefits”

I hope that my responses later in this report will confirm support to the LPA contention that the harms of this proposed development do significantly outweigh the benefits.

In Fressingfield in April 2017 a scientifically organised petition was undertaken. Every street and house in the village was visited, there was no selectivity. 93.8% signed objecting to large scale housing development mentioning specifically the Post Mill development. This was an overwhelming result. The results of this petition were formally noted at the Planning Committee when the Post Mill Application was considered.

Para 9.3.8

“Crash Map Data”

The use of Crash map data is notoriously misleading as only accidents involving personal injury are recorded. There are numerous examples of damage to vehicles being hit in New Street. Additionally there have been two fatalities from car accidents in Fressingfield. These are not mentioned as they did not occur in New Street. It should be recognised that Post Mill will generate more cars using the Fressingfield roads and thereby increase the percentage risk of accidents.

Para 9.3.9

“Traffic flows during peak hours were low.”

This hardly surprising. If I, as non professional in this field, were asked how to ensure that the minimal trip rates were recorded in New Street I would pick the Methodist Chapel as the monitoring point.

Monitoring at the Methodist Chapel would not pick up many of the trips to the shop as people coming to the shop from the east of the village turn around in the couple cul de sacs before the Methodist Chapel. Additionally people attending the surgery from the west would not go as far as the Methodist Chapel so a very large number of trip rates have not been recorded. These data on which the computer generated modelling is based are false data.

New Street traffic 2

Traffic volumes in New Street vary enormously dependent on time of day/ school holidays and agricultural activity. This is evidenced by the pictures of New Street in the Transport Appendices submitted by the Appellant compared to that seen above.

Para 9.3.17

” four pedestrian routes are identified as being “unsafe””

Despite the mitigation proposed it is very difficult to see how this will improve the position. Excess speed in New Street has never been a problem. The proposed mitigation measures will do nothing to improve the position of pedestrians walking in the road. It is impossible to speed in New Street it is just too narrow! However this is looked at there are long stretches of very narrow road with no pavement and a considerable amount of pedestrian movement due to the shop, surgery, scout hut and Methodist chapel all being located on New Street.

Para 9.4.4

“The development will not cause detriment to the capacity of the sewer system”

As Anglian Water have stated the sewer has spare capacity, but why do the manholes “pop” if there is not an issue? Anglian Water have met their legal requirement under the Water Industry Act 1991 as the sewer, under normal conditions has capacity. BUT at a meeting held in October 2018 between the LPA, Anglian Water and myself, as well as other residents, Anglian Water confirmed that the issue revolves around historical surface water connections discharging into the closed foul sewer. At times of heavy rainfall the sewer is overloaded and the manholes lift. Anglian Water confirmed that this cannot be solved as a larger sewer would result in the flows being too slow under normal conditions, resulting in odour and blockages. 24 new houses will discharge into the system thereby increasing the amount of sewage and reducing the capacity for the surface water rain. The sewage in the system will be more concentrated and therefore more polluting.

image002

Para 9.5.5

“Surface water is discharged into a ditch and ultimately into a small stream.”

The “small stream ” happens to be the Beck running through Low Road where there is a significant flooding issue. On 8th May 2018 the Senior Suffolk County Council Flood and Water Engineer issued a holding objection stating” there is not sufficient evidence of the right to discharge surface water into this watercourse as it is outside the redline boundary of the applicant. The applicant also needs to demonstrate that the water course has a positive flow and a discharge point”.

IMG_0743

As flooding is already an issue as a resident I am keen that the position is not worsened. Last year John Lewis refused to quote for my house insurance as they identified my home as being in a flood zone.

Para 9.6.4

“It is unclear why this site, within the village and immediately adjacent to the development boundary is considered an inappropriate location for housing development, when two other, similar- sized sites both located in the village and adjacent to the settlement boundary were only recently considered appropriate locations for new residential development.”

It is correct that two sites were approved for residential development, totalling 46 houses. Application 3872/16- a new chapel and 18 houses has run into considerable difficulty in designing a suitable surface water drainage system. The soil is heavy clay making sustainable drainage systems impracticable. The chapel scheme was approved on 4th July 2018. The Planning Condition relating to the surface water drainage strategy has yet to be discharged. The senior flood and drainage officer wrote on the 16 April 2018 about this scheme ” there is a significant risk to worsening the existing flood risk in Fressingfield “. It would therefore be incorrect to imply that there has been no concern around the two Applications already approved.

Para 9.7.8

When discussing the sewerage issue – ” In attempting to assess the nature and scale of the existing problem, and the extent to which the proposed development would impact on this situation, it is instructive to consider responses to other development proposals in the village.”

The report then examines in great detail the public responses to the two schemes approved, but not yet built highlighting the fact that there had been almost no public comment relating to flooding/ foul water. I would comment that this is completely irrelevant for the following reasons:-

– Public consultation on these schemes was in 2016. Whilst flooding and sewage egress has been a long standing problem it has become far more acute in the last 3 years.

– Until the meeting held with Anglian Water in October 2018 there was no clear understanding, or agreement as to the cause of the problems. Until that time we were told by Anglian that there were various problems ranging from pump failure to fat balls.

At the time of the public consultation on the scout hut and chapel schemes there was no proven correlation between more houses exacerbating flooding/ sewage egress, therefore, why would it be a major plank of objection if there were no such proven link?

Para 9.8.6

When discussing heritage/listed buildings –“the purpose of Visiting is to protect the character of the building and its setting, not to frustrate any development on neighbouring land”.

The proposed development is immediately behind Ladymede Cottage, a grade 2 Listed Building. The building is very “open ” and highly visible from New Street. The development will” frame “the flint and render cottage with modern urban pitched roofs. ( none of the development includes bungalows.) This development would therefore be very detrimental as it would destroy, not protect the listed building’s setting.

Ladymede Cottage

The Appellant does not address the visual impact of this proposed development on entering the village from Weybread. The view across the fields will be compromised, especially in winter when the trees are not in leaf. The draft NDP specifically highlights this vista as one requiring protection.

One point interesting point was raised at the Planning Committee by one of the members (who is a farmer) concerning the 2 fields on which the development would be built. He was convinced that the fields formed part of ancient field patterns and should be preserved. This point has not been highlighted in any documentation, but is worthy of note.

Para 9.8.11

” boost to village vitality and support for local services which arise from a mixed housing development.”

There is absolutely no evidence to support this contention. Since 1995 there have been approximately 90 new homes built in Fressingfield, many in mixed developments. In the same period we have lost a shop; a dedicated post office; petrol station; antique restorer. More houses do not equate to more services.

Conclusion

I believe that this proposed development fails the test of sustainability on all counts. NO green credentials; little employment; no public transport; isolated location; no cycle routes; dangerous roads; lack of pavements; a sewerage system not fit for purpose. Additionally there is no unmet local need for affordable housing as those on the waiting list can be accommodated in the provision already approved.

The Planning Committee unanimously rejected the Application and the development does not have the support of 94% of the villagers in Fressingfield.


Appeal Examination Response

The original application and the appeal Statement are flawed in a number of respects:

1. The ‘principle’ of development – the Statement seeks to establish ‘the principle’ of development at paragraph 5. The case for the alleged ‘principle’ of residential development on the appeal site seems to be based the fact that in 2008 – 11 years ago- the layout plan submitted with 3216/08 (reserved matters for 10 of the houses in the existing Post Mill Lane site) labelled the appeal site ‘Potential Future Development.’ This is irrelevant. Planning law does not bind planning authorities to future approvals of further proposals to which oblique reference is made in an approved application.

Furthermore, paragraph 7.7 puts forward the existence of an infrastructure within the existing Post Mill Lane site alleged to be capable of accommodating additional houses, as justification for approval of such houses. Again this is irrelevant to the planning decision.

2. The baseline for assessing cumulative impact – whilst the Statement acknowledges that approvals 3872/16 and 4410/16 will bring an additional 46 houses, a regional scout hut and a Baptist chapel with extensive community facilities, it fails to acknowledge that the baseline from which all cumulative impact should be assessed will therefore change. The impact of these developments is as yet unseen. Therefore the assessment of the harm that the subject application might inflict is assessed from an out of date baseline. In particular, the cumulative impact of the appeal site with the 106 new residents from the 46 approved houses, and the extra visitors to the village generated by the community facilities, has not been taken into account in:

  • Pollution – The current level of pollution has been identified as a public health hazard by the Suffolk’s Director of Public Health, who, in an email of the 11th April 2018, advised the following precautions on exposure to flooding/sewage:
     – Keep children and pets away from the flooded areas
     – Wear protective clothing such as rubber gloves if you’re cleaning up and cover any cuts and grazes
     – Food which may have been in contact with flood water should be thrown away
     – If you show any symptoms such as diarrhoea or vomiting after a flood, call a doctor straight away.
    The cumulative impact on this public health risk of sewage from 106 new residents is not taken into account, as it has not happened yet.
  • Flooding offsite – The original FRA predated the approved developments and no new FRA has been submitted in support of the appeal, so the cumulative impact on flooding off site has not been assessed, as it has not happened yet. A complication is that in 3872/16, adequate drainage solutions to mitigate flood risk off site are yet to be agreed.
  • Road safety – The ATC measured current traffic levels. The cumulative impact of pedestrian and vehicular traffic generated by the cars owned by 106 new residents and their pedestrian journeys to the shop, school, pubs and surgery was not assessed, as it has not happened yet.

3. Policy Context

a) The Fressingfield Neighbourhood Development Plan – The Plan completed its Regulation 14 consultation on 17th May 2019 and will be submitted to MSDC on the 19th July. It is at an advanced stage, has strong support from the community and is consistent in many respects with the NPPF. It must be given some weight in the appeal decision. However, its draft policies are ignored in the Statement.

b) Babergh and Mid Suffolk Local Plan – according to MSDC’s website, the draft Local Plan is due to be considered by the Council in June. Therefore it should be given weight in the appeal. Even without it, the MSDC Housing Land Supply Position Statement 2018/19 prepared in response to the challenge from the Woolpit appeal clearly demonstrates a five year housing supply so that current policies are not automatically out of date under the NPPF and must be considered in so far as they are consistent with it.

4. Sustainability – The NPPF defines sustainability under three headings: economic, social and environmental. There a number of flaws in the manner in which these are assessed in the Statement

4.1 Economic

a) Meeting housing need – the Statement quotes housing need in the district (para 3.8) but fails to assess whether the appeal site is an appropriate location to meet it, against the NPPF criteria, including

  • Paragraph 103 ‘Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel.’ No evidence is offered of employment opportunities which new residents could access without travel, other than temporary construction work
  • Paragraph 180: ‘Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development.’

It is important to note that the impact on the village’s character of the subject application has been understated as it is in fact an extension to an existing recent development, making it the largest estate in a village which has experienced an increase in housing of roughly a third since the 1995. This is the context in which the issue of sensitivity needs to be assessed.

MSDC has accepted the figure in the draft NDP of 60 houses for Fressingfield for 2018-2036. 54 houses in total have already been approved in village (3872/16 and 4410/16 plus windfall) but not yet built. Only 6 more houses are needed over the next 18 years, which the approved draft NDP anticipates will be met from windfall. The subject application would deliver four times this number, which is not sustainable.

The appeal site is outside the village’s Built-Up Area Boundary and must meet the criteria in paragraph 79 of the NPPF, which include that the design which ‘would significantly enhance its immediate setting, and be sensitive to the defining characteristics of the local area.’ In contrast this development would:

  • feed additional traffic into the conservation area harming its character
  • dominate two adjacent neighbouring listed buildings and their settings
  • introduce a large housing estate entirely out of scale with existing housing, new and old.

3.2 Social

a) Numbers of houses and residents – paragraph 9.1.8 describes the 24 proposed houses as a 5.4% increase on the current 444 (in the village as opposed to the parish), and later asserts that this is not ‘significant’. Significance is relative to context. Whilst a 5.4% increase in a town centre might not be significant, such an increase in a small village with constrained capacity and amenities, is both unsustainable and significant, especially as it would be on top of a 12% increase from the 54 approved.

However, it is the number of residents that is more relevant to the social objective than the number of houses, as it is they who will be using the infrastructure. Suffolk County council estimates that 24 houses would generate an additional 55 people. Fressingfield’s population is already set to increase by some 124 residents for the houses already approved, making a total increase of 17.5% in its population of 1021 (Census 2011) if this development were to go ahead – definitely a ‘significant’ increase.

b) Capacity – at paragraph 7.7 the Statement represents that the existence of certain amenities in the village is of itself evidence that such amenities can accommodate additional demand sustainably. No evidence is offered that the shop, where parking is already very constrained, can accommodate additional customer parking. No evidence is offered that the surgery can accept more patients. Parking is currently severely constrained at the surgery and the 2018 national GP survey indicated that 42% of patients wait longer than 15 minutes for their appointment, a worse position than both the CCG and national averages (26% and 31%)iv. This does not suggest additional capacity – quite the reverse.

c) Road safety – Accidents causing personal injury are specified in the Statement, but make up only part of the adverse impact on road safety to be expected from the subject development, because there are already hazards. Three years ago, a very large hole was made right through the front wall of Woodyard Cottage, which gives directly onto New St. by the mobile library van. More recently the windowsill on the same house was completely removed by a passing car. Mercifully, no one was injured but this is clear evidence that there is an already an impact on road safety, even before the 54 extra houses and community facilities are built, let alone another 24. This accident will not appear in the Crashmap data.

The transport and road safety issues are so extensive that they will be covered in a separate paper.

3.3 Environmental

a) Incomplete assessment of flood risk and flooding offsite – The original FRA considered flooding offsite, as required, but did not discuss the impact on flooding in Low Rd. even though the foul water from the site is to go to the sewer which runs alongside the Low Rd. beck, reducing the sewer’s capacity to accommodate flooding from surface water connections yet further. This colocation, combined with surface water flooding at times of heavy rain has caused flooding and pollution for many years and with increasing frequency. The response to the application from the LLFA did not take account of this fact, perhaps because SCC was under the impression, as evidenced by their response to an application under the Environmental Information Regulations (16583 dated 6th August 2018) that the sewer was a combined sewer, permitting surface water connections, which Anglian Water, in response to a similar application on the 10th October 2018, confirmed it is not.

The Statement (9.6.4) offers the extraordinary conclusion that because two developments had recently been approved for the village (3872/16 and4410/16), a third was also appropriate. The reverse is true. Ours is a rural historic village with a struggling infrastructure already subject to a worsening flooding.

b) Foul water – Anglian Water noted in their response of the 19th May 2017 ‘that the development will lead to an unacceptable risk of flooding downstream’, stating that a Condition requiring a foul water drainage strategy would be needed, which was not produced as permission was refused.

Since the original application, an email exchange of 19th October 2018 between the case officer, Vincent Pearce, and Hannah Wilson, Pre-Development Planning Manager at Anglian Water, sets out new evidence that extra sewage entering the sewer will exacerbate the flooding that occurs in heavy rain and the pollution and risk to public health and wildlife that has been repeatedly associated with it. Sewage will increase by 17%, if this development were to go ahead because of its cumulative impact on the number of residents when combined with those arriving through existing approvals.

In the email exchange, Anglian Water confirmed the unsustainable position: ‘The additional development currently being proposed in Fressingfield and the sewage it will generate is not likely to significantly impact the capacity in the foul surface system in its own right. However it is reasonable to assume that in periods of high rainfall in a short period of time it will take less surface water to fill the capacity of the foul water system [because it now contains more foul sewage] and that as a result an equivalent amount of rainfall post-development as pre-development will increase the risk and quantity of flooding. This flooding is also likely to contain increased levels of foul sewage content because there will be more in the system due to the increase in population.

‘Whilst this is not an issue that can be resolved by Anglian Water, as the regulatory funding framework in which they operate does not allow for water companies to invest in surface water re-connections, it is reasonable for the planning authority to conclude that the impacts described above can be expected even where no additional surface water is entering the foul water system from the new developments.’

The Statement, at paragraph 9.7.11, entirely misses the point about this issue: it is not that the proposed development will or will not solve the problem that is relevant – but that the existence of the problem makes the development unsustainable because the construction of these houses will worsen the problem.

Paragraph 11 of the NPPF is clear on two grounds that permit refusal:

a) where NPPF policies ‘that protect areas or assets of particular importance provide a clear reason for refusing the development proposed’. Footnote 6 includes ‘areas at risk of flooding’ as such a protected asset while paragraph 163 provides such a policy: ‘When determining any planning applications, local planning authorities should ensure that flood risk is not increased elsewhere.’

b) where ‘adverse impacts of doing so would significantly and demonstrably outweigh the benefits.’

The evidence above presents a clear reason for refusal on both grounds.

c) Impact on wildlife – The site includes hedgerow boundaries which are a Protected Habitat under Section 41 of the Natural Environment and Rural Communities Act 2006. The recommendation of Place Services to MSDCv was that ‘a minimum buffer strip of 3m be left undisturbed along the field margins upon project completion to maintain some habitat connectivity with hedgerows, ditches and treelines’. This was noted in the MSDC decision paper. It was originally proposed as a reserve matter. However the consequences of complying with this requirement for the viability of the development are such that it should surely be considered at the planning appeal stage.

d) Heritage – the 2018 MSDC Heritage and Settlement Sensitivity Assessment notes in relation to Fressingfield that : ‘The historic core has already seen several areas of inappropriate modern development and the Local Authority should seek to avoid further exacerbating this harm.’ This is a clear indication that the decision to refuse this development on heritage grounds was correct. The harm to the conservation area and listed buildings (designated heritage assets as referred to NPPF Footnote 6) and their setting, the village, of such a large housing estate offers another ‘clear reason for refusing the development proposed,’

Section 72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 requires that planning authorities pay ‘special attention.. to the desirability of preserving or enhancing the character or appearance of the conservation area’. This is in addition to the NPPF requirements. Although the Statement proposes a number of measures to mitigate acknowledged road safety problems along New St (which are evaluated separately), the impact of such changes on the conservation area is not assessed, as required by paragraph 189 of the NPPF. The argument in paragraph 9.11.2 that the appeal site is ‘neither within nor adjacent to the conservation area’ is spurious because it will impact upon it, though increased traffic, both pedestrian and vehicular and parking congestion outside the shop and surgery which are within the conservation area.

Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 (LBA) requires that ‘special regard shall be had to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.’ Mount Pleasant, which adjoins the existing Post Mill Lane site is a Grade 2 listed building with a large pond in its grounds, from which clay lump was extracted to build the house in the 15th century. When the first Post Mill Lane development was completed, this pond dried up completely – the first time in living memory – and has remained dry ever since, with the loss of a crucial wildlife habitat as well as damage to the curtilage of a listed building, as shown below. There seemed no other possible cause than the adjacent development.

Pond
Dried up pond, Mount Pleasant adjacent Post Mill Site

Efforts to seek redress for this detrimental impact with the developer, the environment agency and MSDC have not progressed. To compound what appears to have been a failure to protect a listed building and its setting, by permitting further inappropriate development in its setting, would be unwise.

SAFE 12th June 2019

Footnotes:
Using the formula used by SCC of 2.3 people per dwelling.
Letter from Paul Bryant Neighbourhood Planning Officer to Fressingfield NP Group 16th May 2019
Letter from SCC to MSDC 30th May 2017
GP Survey 2018
Place Services letter to MSDC 03.08.17


General Heritage Issues

This appeal should be refused in our opinion for the following reasons:

This large scale development of 24 houses, together with the two hybrid applications (3872/16 and 4410/16) of 46 houses already approved in 2017 but not yet built, would be out of character with the existing pattern of development of our small village. This would be contrary to development plan policies CS5, GP1, H13 and H15 and would give rise to a significant increase in the overall size of the village without appropriate infrastructure being in place to accommodate the future occupants of the development. This development on its own would reasonably be expected to generate 48 extra vehicles and 55 extra residents to this small village of only some 400 dwellings.

The appeal is misleading in that it states the development is sustainable in terms of there being a pub shop and surgery in walking distance. The reality is that there are virtually no public transport services, no jobs and the inhabitants would all have to travel by car to work, shop and do their day to day business. The absence of existing facilities and services within reasonable distance/travelling time of the development by public transport, walking or cycling would give rise to a reliance on the private car contrary to the provisions of the NPPF, accentuating environmental harm.

As a primary village, with the approved and projected windfall houses, we have met our housing targets for the next twenty years. We do not know what the impacts of the two hybrid applications are going to be yet before the houses granted are not even built. The cumulative impact of this development would be unacceptable. A resounding 94 per cent of the village have shown in a petition that they are against large scale development, not wishing the rural and picturesque quality of life here to be ruined for future generations.

Fressingfield is a national treasure having 58 listed buildings. It is the setting of these protected buildings and for the village as a whole that should be protected according to the local plan and the NPPF. Luckily the remote and isolated setting of the village means its heritage has remained relatively untouched. The small size of Fressingfield means that it is truly incorporated into the countryside and open landscape around it. These assets bring many tourists and visitors to the area.

Already in a village with just 350 houses at its core, the 47 already granted will have a huge detrimental impact on the setting of the heritage and many listed buildings as well as its rural character. To grant any more major development here represented in these three applications would tip the balance and be devastating for the rural and historical nature of this village. Instead of being on the edge of rolling countryside, we would be hemmed in by new developments which are totally inappropriate in scale.

This large development, if allowed will compound with the houses already granted and not built, creating a very large single urban site of 51 houses which is out of scale for this village. It would harm the character, heritage and sense of place here as well as the openness of the village to the countryside around it, contrary to para 192 (a) of the NPPF which protects heritage assets by sustaining and enhancing them. Neither does the development make a positive contribution to local character and distinctiveness of the village contrary to para 192 (c) of the NPPF. This proposal would also harm the setting of the Fressingfield Conservation Area, providing no clear justification or public benefit for this harm contrary to para 194 of the NPPF and HB8 of the local plan.

This development would impact directly on open land to the immediate rear of a Grade II listed building, Ladymeade cottage and substantially harm its setting which the original planning decision noted contrary to policies HB1 and HB8 of the local plan and 196 of the NPPF. The development would also ruin the setting of another Grade II listed building, Mount Pleasant which is within 50m of the proposed site. The harm to both of the these buildings and their setting as well as to the village as the whole is not less than substantial as this appeal suggest and the levels of harm to designated heritage assets has been clearly balanced by the original planning decision against planning policy and the benefits it might deliver.

Church

The appeal suggests that a mixture of trees and hedges – (in winter months this coverage would be minimal!) – would mitigate the effects to these listed buildings but they are too close and their setting would be harmed immeasurably.

The proposed development would not deliver any public benefits which would outweigh on this identified harm and would also harm the setting of the village as a whole, being extremely visible from the approach to the village, Harleston Hill. The view of Fressingfield here has special mention for protection in the draft Neighbourhood Development Plan.

The impact of this large development cannot be mitigated from a heritage and setting perspective, contrary to the appellant’s Statement of Case in this appeal. It is misleading in that it claims that by limiting development the village would be a “static monument to a historic rural village” which is contentious and untrue. The village has delivered already over its quota as a primary village in the planning numbers recently granted as well as the windfall allocations of houses. This development would not be appropriate in scale or context having an adverse impact. Nor would its impact be any less on the setting of the conservation areas of the village contrary to this appeal and the provisions of policy HB8 and the NPPF do apply here despite the appeal claiming they do not.

It is the same with landscape and our relation to the rural environment.

“Protecting and enhancing the historic environment” is an important component of the National Planning Policy Framework’s drive to achieve sustainable development (as defined in paragraphs 6-10. The appropriate conservation of heritage assets forms one of the ‘Core Planning Principles’ (paragraph 17 bullet 10) that underpin the planning system.”

Our distinctive and valuable rural landscape is also our heritage and as the Core Strategy sets out that the District’s approach to sustainable development must conserve and enhance the local character of different parts of the district as well as restrict development in the countryside to defined categories. The NPPF and saved policy of the district (The Core Strategy Focused Review 3.2) clearly describes sustainable development as including the principle of enjoying a better quality of life, without compromising the quality of life for future generations. These documents also outline the importance of safeguarding the environmental and landscape of the countryside. The local plan also incorporates Core Strategy 2008 which promises a better heritage for future generations, to safeguard the distinctive and attractive areas of Suffolk.

Objectives SO1 and SO4 of this strategy clearly set out that the historic, heritage and environmental character of local towns and villages are protected from new developments which must be appropriate in terms of scale and context of settlement.

This proposed site at Post Mill exits onto the main street, (New Street) of the village, which is very narrow and frequently congested. The traffic and road safety implications here are severe and should be refused in line with the NPPF (P32).

The existing sewerage system here is at or over capacity as it stands and cannot absorb further housing developments. Flooding and overload of the sewerage system is a long term problem that the District and Anglia Water have acknowledged.

The proposed site lies outside the identified development of the boundary and is contrary to policy CS2, in conflict with the development plan and posing harm to the setting of the village.

For these reasons the proposal should remain refused as it is inherently unsustainable triggering the tilted balance in a negative way, the adverse impacts being significantly and demonstrably evident.


Heritage Issues at Ladymede Cottage, New Street Fressingfield

This paper has not been written by a member of the SAFE team, but this issue was so important at the original Hearing that we feel it should be included 

Overview 

The following notes provide evidence of the impact that the proposed development will have on Ladymeade, a grade 2 listed building, in the following areas:

  • natural and historic environment
  • village infrastructure, services and amenities
  • traffic and road safety

Natural and historic environment: 

  • Ladymeade Cottage is one of a number of important listed buildings in Fressingfield. A survey by an architectural historian described it as ‘an unusually well-preserved timber-framed house of the late 16th century that contains a number of historically interesting features, including original window mullions and a rare solid-tread stair.’ Building new properties on an ancient meadow in close proximity to this historically important building is detrimental to the environment of the house itself and to the village of Fressingfield.
  • In summer 2015, when the current owner acquired the meadow, the trees and undergrowth were cleared with total disregard for wildlife habitats. We no longer see the endangered turtle doves, which had been frequent visitors. In the intervening years, with some regrowth of scrub, we have seen barn owls, songbirds, field mice, deer and grass snakes around the meadow. This is an important habitat which will be destroyed by the proposed development.
  • The plans show a footpath on a ‘right of way’ leading between the proposed development and New Street. This is incorrect. No ownership has been established for this strip of land. We accept there is a right of access to the meadow for its owner, but it is not a public right of way.
  • The use of this access will, according to the proposed plans, be open not just to the residents of the houses built on the meadow but to all 24 houses, and the existing houses on Post Mill Lane. This raises considerable concerns for us about privacy, security and liability. We consider that the pedestrian egress from the proposed ‘footpath’ on to New Street is highly dangerous as it is on a slight bend in the road with totally restricted visibility. As shown in the photograph below it is necessary to actually be standing in the road to see approaching traffic.
  • As a point of information, we have sales particulars dating from 1905, which indicate that the right of way to the meadow was originally intended to run between West Cottage and Mount Pleasant, not between East Cottage and Ladymeade.

Village infrastructure: 

  • Drainage and sewerage is a major concern. Twice in June 2018 the main drains blocked under the road in New Street outside Ladymeade. We were forced to move out temporarily as waste had backed up and our toilets were unusable. When Anglian Water came to clear them we were told it was due to build up of household waste and wet wipes. We believe any increase in the number of houses will put further strain on the capacity of the sewerage system.
  • In the north east corner of our garden is a pond. Surplus ground water from the road flows into this, which then drains away into a ditch system in the meadow behind Ladymeade Cottage. We would be concerned that the proposed development could result in more use or blockage of this ditch drainage system, causing significant flooding in our garden, possibly backing up into New Street.
  • As a point of information, maps show the pond as being within the meadow. This is incorrect as the pond clearly lies within the boundary of Ladymeade.

Traffic and Road Safety

  • Currently traffic is a considerable problem on New Street immediately outside Ladymeade. Scout groups using Goodwins Hall park there, causing congestion. If/when the scout groups move to their new HQ, the parking issue will lessen but there will be increased traffic along this stretch of road. There is limited visibility and no pavement along this stretch of New Street. We feel this raises considerable safety issues.
Footpath Exit
Egress from proposed footpath to New Street showing that it is necessary to be on the road to see approaching traffic.

General Implications for Post Mill Development

Dear Sirs

Town and Country Act 1990- Appeal l under Section 78

Appeal reference APP/W3520/W/19/3227158

I write as a long term resident of Fressingfield (Feb 1962) concerning the above Appeal

I note that the Appeal is to overturn the decision for the building of up to 24 houses on the Post Mill site which was refused by the Authorities in November 2018.At present there are 25 dwellings so if this appeal was upheld it would make a total of 49 dwellings virtually a mini estate which being on the brow of a hill would detrimentally affect the aspect of the village when viewed from Harleston Hill. Apart from the aesthetic viewpoint there is the added traffic onto New Street which is narrow has few pavements and is in constant use by residents attending the Medical Centre, the Methodist Chapel Scout Hut and the Village shop plus the two Public Houses.

The Medical Centre cannot be enlarged and at present the car park is often full which means parking on an already hazardous roadway. Permission has also been granted for 46 houses which have not been built which when they are will exacerbate the problem

There is little or no extra employment in the village so any new residents would be forced to travel outside of the village. The Appelant refers to employment during construction which of course would be only temporary. Apart from School Buses there is one bus a week and no cycle lanes which means that cycling is not a realistic mode of transport therefore there is a dependence on motor vehicles so the Village Green Credentials are poor

More houses added to those already approved but not yet built will also add to the acute sewerage challenges this village endures which there is little chance of alleviating according to Anglian Water.

May I suggest that if there is any thought of granting this appeal it is not made until the impact of the 46 houses already approved but not built is appraised


Effects of Development at Post Mill

I am writing to object to the building of 24 more houses in Post Mill lane and request that the Appeal be rejected. This objection is based upon three matters as set out below.

  1. EXISTING GOVERNMENT AND MID SUFFOLK HOUSING POLICIES.
  2. LACK OF SUSTAINABILITY IN TERMS OF TRANSPORT INFRASTRUCTURE, SERVICES, AMENITIES AND EMPLOYMENT OPPORTUNITIES.
  3. FRESSINGFIELD’S ALREADY AGREED CONTRIBUTION TOWARDS NEW AND AFFORDABLE HOUSING

1) EXISTING GOVERNMENT AND MID SUFFOLK HOUSING POLICIES.
a) GOVERNMENT POLICY.

The Chancellor of the Exchequer, Phillip Hammond, declared in his Budget Speech: ‘ We will focus (house building) on URBAN areas where people want to live and where MOST JOBS are created, making the best use of our urban land and continuing the strong protection of our Green Belt. IN PARTICULAR building high quality housing in CITY CENTRES and TRANSPORT HUBS.

b) MID SUFFOLK DISTRICT COUNCIL HOUSING POLICY

The Council will help REDUCE THE NEED TO TRAVEL, REDUCE JOURNEY DISTANCES and make it safer and easier for people to access jobs, shopping, leisure facilities and services by PUBLIC TRANSPORT,WALKING AND CYCLING.

If these policies are to be adhered to then these 24 houses cannot be built in Fressingfield as all the requirements fail, totally, to be met in this village as is shown in the sections below.

2) LACK OF SUSTAINABILITY IN TERMS OF TRANSPORT INFRASTRUCTURE, SERVICES, AMENITIES AND EMPLOYMENT OPPORTUNITIES.

a) TRANSPORT INFRASTRUCTURE

Fressingfield is a small, rural village with no access to the sort of transport necessary to support further, significant housing development.

  • It is many miles from the nearest transport hub let alone an A road.
  • The roads into and out from the village are, in most cases, winding and narrow.
  • The nearest railway station is Diss, 10 miles away.
  • The centre of the village roads are narrow and, often, congested.
  • Large parts of the village have no pavements with the roads running so tight to housing that no pavements could be added.
  • New Street which is home to the village shop, the Methodist Chapel and the Surgery is particularly congested with there being inadequate parking at the Surgery and only on road parking at the shop.
  • Suffolk Highways came out against the development on the grounds of safety, especially that of pedestrians.
  • The one bus service a week to and from Norwich on a Saturday, is under review as it is subsidised and, I am reliably informed, is likely to be axed leaving us with no public transport provision at all. Two SCHOOL BUSES do run on weekdays, in term time, BUT NOT IN THE HOLIDAYS OR AT WEEKENDS. Indeed my granddaughter has used one of them daily for three years and has never seen a member of the public use it!
  • Jubilee Corner, at the end of New Street, our busiest road onto which more traffic would disgorge if this development goes ahead, is a 4 road junction on a sharp bend where a number of accidents have occurred recently. Further congestion will only increase accident risks and heighten dangers to pedestrians as it a popular route for parents taking young children to school.

b) SERVICES

The limited services available, village shop, Primary School, surgery, three churches, a pub and a restaurant make it absolutely necessary for people living in the village to use their cars to access a large number of services located in distant, urban centres – this is totally at odds with central and local government declared policies.

c) AMENITIES

There are two tennis courts and a bowling green in the village with a children’s play area (the football pitch has not been used for a long time). Villagers have to raise a significant carbon footprint every time they wish to access other, higher order amenities such as cinemas, theatres and major stores.

d) EMPLOYMENT OPPORTUNITIES

Less than a year ago I carried out a comprehensive survey of employment opportunities in the village. I discovered that there are 58 Full Time equivalent jobs available. Many of these are part-time (shop, pub, restaurant) and 24 are full-time, graduate posts (doctors, nurses and teachers). A small woodworking business employs 5 people, there are limited opportunities for farm workers and occasional builds in the village provide temporary work for those in the building trade. Virtually all newcomers would have to drive to work thus increasing the carbon footprint which is, once again, totally against declared government policies.

3) FRESSINGFIELD’S ALREADY AGREED HOUSING BUILDS

In the last two years Mid Suffolk D.C. has approved the building of 51 new houses in Fressingfield including 17 affordable houses (i.e. 33% of the total). At the last count there were only 11 families, locally, on the list for an affordable home, leave a surplus of 6 houses.

Fressingfield has a population of 1000 and if the ratio of 51 new houses per 1000 of the population were extrapolated nationally it would produce 3.3 MILLION NEW HOUSES nationally, far, far in excess of the government’s target for new builds. Clearly Fressingfield is already contributing a great deal more than its fair share!!

You will have been made aware of the major problem of sewage egress onto Low Road with contamination of the road, the beck and residents’ gardens at times of high precipitation. In a meeting I attended with representatives of Anglia Water they admitted that a) more houses would exacerbate the problem (more serious and more frequent outpourings) and b) they could do nothing to solve the problem! Environmental pollution on this scale and frequency is totally and utterly unacceptable and we/you cannot allow it to worsen further through the building of yet more housing.

There can be NO GROUNDS on which this appeal can succeed. The circumstances have not changed since the application was made last November and turned down UNANIMOUSLY by the MSDC Planning Committee on the recommendation of a most diligent and impressive Planning Officer who went to great lengths to establish all the facts during numerous visits to the village. The building of the 24 houses in the village goes against government and local authority declared policies, it is totally unsustainable on every count and will lead to unacceptable, increased environmental pollution. If this is not enough Fressingfield is at the top of the league table of villages contributing demonstrably more housing to help the national effort than most other other villages.


Comments on Transport and Road Safety Aspects of the Post Mill Lane Appeal

Click above to view full paper including pictures and tables.

1. CONTEXT – The DJLP (DJLP) has now been published and attracts some weight insofar as it is consistent with the NPPF, as a five year housing supply has now been demonstrated.

1.1 Status of Fressingfield and Sustainable Location of New Housing – The DJLP confirms

  • the status of the village as a ‘hinterland’ village
  • that only 54 houses are needed in Fressingfield between 2018 and 2036.
  • that the subject site remains outside the settlement boundary
  • that no further sites are designated for residential development in Fressingfield.

Paragraph 65 of the NPPF requires LPAs to ‘set out a housing requirement for designated neighbourhood areas [of which Fressingfield is one] which reflects the overall strategy for the pattern and scale of development and any relevant allocations ’ These figures should only need retesting at examination of a neighbourhood plan if there is ‘a significant change in circumstances.’

1.2 CO2 emissions – Mid Suffolk, despite having the third smallest population of all the seven County districts, already makes the highest contribution to transport-generated CO2. At 38.2% this is also higher than the County (29.2%) and the Region (East of England 32.7%) and more than half as high as the national transport contribution to CO2 emissions which is 24%. This cannot be attributable to different generation patterns because most of the other districts are similarly rural. Poorly located transport- generating development, such as that proposed in the subject appeal, with no co-located employment opportunities, must surely be a significant contributory factor.

The DJLP requires ‘all new residential development .. to.. achieve reductions in CO2 emissions of 19% below for the Target Emissions Rate of the 2013 Edition of 2010 Building Regulations (Part L).’

This is consistent with paragraph 150 of the NPPF which provides that new development must be planned in ways which ’help to reduce greenhouse gas emissions, such as through its location.’ In support of such objectives, new legislation provides for net zero carbon by 2050.

It is hard to see how the subject development can meet these objectives when it will generate so many additional car journeys though its inappropriate location in an isolated rural village with no employment opportunities and from which cinemas, supermarket shopping and all education other than primary can only be accessed by car, because of the poor public transport and the village’s location.

1.3 Wrong baseline – all the calculations (which are also questionable in other respects as discussed below) in the Appeal documents are based on the wrong baseline because 48 houses, a large Baptist chapel with community facilities and a new scout hut have all already been approved but not yet built. This means that the starting point for assessing impact of the subject development is wrong, so conclusions drawn from that assessment are not valid

2. CUMULATIVE IMPACT ASSESSMENT – Both the DJLP and the NPPF are clear about the need to recognise the cumulative impact of developments including on transport.

The DJLP and states that development will only be permitted in Hinterland Villages within settlement boundaries and that in considering proposals ‘the cumulative impact of proposals will be a major consideration.’ The subject site is outside the settlement boundary.

This is consistent with paragraph 109 of the NPPF which states: ’development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.’  It is not possible to assess whether the impact is acceptable or not without data on cumulative impacts.

2.1 Lack of cumulative impact assessment – The Transport Statement asserts (1.1.5) that a cumulative impact assessment is not ‘considered proportionate’ because of the low number of houses in the subject appeal. Appendix B of the DfT Guidance is cited as authority for this, but this only sets out thresholds for whether a transport statement or assessment is required and if so, which. Appendix B starts with an exhortation to local authorities to interpret these thresholds ‘in light of their own circumstances, and not treat them as absolutes.

On the 14th August 2017 SCC Highways advised MSDC of their concern about ‘the effects of additional vehicular and pedestrian traffic in the area of New Street / B1116 Laxfield Road / Stradbroke Road / Church Road where there is an absence of footways… This factor should be considered in terms of cumulative impact for all proposed sites in Fressingfield.’ This was an interpretation based on local circumstances.  Development 3872/16, approved on 4th July 2018, comprises 18 houses and a Baptist Chapel covering 959 Sq. metres, including meeting rooms, a coffee shop and some sports facilities. 4410/16 approved on 15th August 2017, comprises 28 houses and a Scout Hut. A further 8 windfall approvals have since been given meaning that the cumulative impact of 24 additional houses with another 54 and the community facilities must be considered.

Despite asserting that a CTA is not ‘proportionate’ (paragraph 1.1.5), the Appeal documents rely on the CTA produced as part of the original applications (1432/17, 1449/17 and the subject appeal, all of which were refused at the same time). However, this is not fit for purpose as it did not:

  • consider person trip rates
  • prioritise or differentiate pedestrians
  • assess how to minimise conflicts between pedestrians and vehicles
  • consider traffic impact on heritage or the environment
  • consider traffic from the new Baptist Chapel or scout hut
  • consider impact on deliveries or emergency access
  • consider the impact on parking

2.2 Incomplete Vehicular Baseline Data – Current levels of pedestrian and vehicular traffic are not the correct baseline from which to measure any increase, because of the uplift in traffic to be expected:

  • from a further 106 residents from the approved housing,
  • 20 from the windfall houses
  • additional worshippers, attendees at community events, and scouts, at the community facilities.

Table 3.1 presenting Trip Data is therefore inaccurate by a factor of at least 3. It also ignores the school run data referred to in the Pedestrian Assessment.  The correct figures from the housing alone, are shown below. (View PDF for table)

2.3 Incomplete Pedestrian Data – The person trip data in the Appeal documents seems to be extrapolated from area percentages which are then used to gross up the (incomplete) vehicular data, and generate person trip rates of various kinds. School children are not considered because the school run data is not included in the extrapolation.

This data is not derived from any actual counting of pedestrians at all. An additional 124 pedestrians will already be using the highway network as a result of the developments approved who, together with the 55 from the subject development would lead to a 17.5% increase in the village’s population (179 people), and therefore its traffic. The notion that all these people will only make three two way pedestrian trips (2 in the morning peak and 1 in the afternoon peak) between them, as asserted in Table 3.2, is not credible.

This entire edifice of extrapolated data is used to produce the conclusion that ‘the walking and cycling trips combined with the vehicle movements result in an increase on the existing highway network which is negligible in operational terms’. This is inaccurate and unconvincing.

2.4 Wrong Trip Rates – The vehicle trip rate selected (para 3.3.1) is wrong because one of the parameters for its selection is a development of between 8 and 50 houses. The cumulative impact of what has been approved and the subject development is 74 and, with the community facilities, is not exclusively residential.

Furthermore, even the category of trip rate from which this selection has been made appears to be wrong.  On 4th August 2017, SCC advised MSDC by email pointed out ‘the inappropriate selection of sites in the TRICS data bases, specifically ‘edge of town’ and ‘’suburban (out of centre)’. We do not consider Fressingfield to be in this category. Therefore, this has resulted in total trip estimates for vehicles as stated in the TA being considered to be too low.’ The analysis for the appeal makes the same error, classifying the village as a suburban area.’  It is therefore the wrong vehicle trip rate applied to the wrong type of development and the wrong number of houses.

3. PRIORITISATION OF PEDESTRIANS – the prioritisation of pedestrians is a consistent national and local policy requirement, which is not reflected in the subject application.

The DJLP requires:

‘2. All developments to maximise the uptake in sustainable and active transport. A transport hierarchy must be considered. This will prioritise the following modes of transport in order – walking, cycling, public transport and car sharing

3. Proposals for all development shall, where appropriate, incorporate provision for: a. Pedestrians, including disabled persons and those with impaired mobility..’

This is consistent with the NPPF which at paragraph 110 sets out detailed requirements for developments:

  • Pedestrians and cyclists – give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;
  • Disabled people – address the needs of people with disabilities and reduced mobility in relation to all modes of transport;
  • Road Safety and local character – create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards;
  • Deliveries and emergencies – allow for the efficient delivery of goods, and access by service and emergency vehicles.’

3.3 No prioritisation for different types of pedestrian – So far from being prioritised, pedestrians, particularly elderly people with impaired mobility walking to the shop, pubs or surgery, will suffer increased safety risks from higher levels of traffic at all the points of limited visibility in the village (shown in the photos on the front cover). In addition to using the wrong baseline, the Appeal documents fail to differentiate between types of road users. The failure to recognise the needs of disabled people would put the planning authority in breach of its legal duties, as well as the NPPF.

3.4 Failure to consider extra traffic from approved community facilities – The Appeal documents ignore the impact of the expanded relocated Baptist Chapel, and the new regional scout hut. It is instructive to consider the usage proposed for the new scout hut and Baptist Chapel, from the Design and Access Statements issued with applications 3872/16 and 4410/16, as shown in the Table below. (View PDF for table)

Little information is available on the use of the sports and meeting facilities at the new Baptist Chapel other than services. It will have 50 parking spaces, considerably more than now. The scout hut anticipates that 10-15 cars per event will be attending to drop off and pick up scouts.  Some at least of these journeys will be outside the peak times used to extrapolate traffic data. The additional traffic generated by the new usage patterns of the much larger replacement facilities are ignored in the calculations which appear in the Transport Statement.

All these figures are estimates. Until usage has started it will not be possible to see the actual impact or have an accurate baseline from which to extrapolate further traffic impact from the subject development.

3.5 No Data On Jubilee Corner – No attempt is made to assess the safety of Jubilee Corner for pedestrians or traffic. The photos on the front cover illustrate the current limitations of the junction.  A possible additional 150 cars from new residents (based on one car for each of the 74 houses and a second for 505 of them), as well as extra journeys to the Baptist Chapel and Scout Hut will exacerbate these safety issues further, even without the subject development. Therefore the conclusion in 4.4.11 that the key junctions ‘would continue to operate within their capacity with development in place,’ is not proven.

4.  FLAWED EVIDENCE – overall the evidence presented in the Appeal documents on transport is flawed in a number of respects.

4.1 Over reliance on speed and volume – The volume and speed of traffic heavily relied upon in the Appeal documents are only two of the factors relevant to road safety. There are at least another five factors, which make up ‘the local character’ impacting on road safety, to which the NPPF refers:

1. Visibility – Some buildings impair visibility where built directly onto the road or junction. There are five such buildings in New St but only one is mentioned in the Transport Statement (2.3.7). In addition to the many driveways and front gates emerging directly onto it, there are several exits onto New St with very limited visibility, (including the proposed new footpath). Elsewhere on the village highway network there are exits with limited visibility for pedestrians and vehicles onto the B1116 (opposite the Swan pub), and onto the War memorial junction. Visibility is also relevant at the junctions onto which traffic of all kinds emerge, such as Jubilee Corner, a four way junction with limited visibility. Extra pedestrians and extra traffic will exacerbate these problems.

2. Character of the highway network – the heritage context for the development and relevant highways is important, as it may limit any mitigation. There are 54 listed buildings in Fressingfield including two on New St, one adjacent to the existing Post Mill and the other to the subject development site and numerous other unlisted historic properties. Most of New St is unlit.

3. Character of the pedestrians – the types of pedestrian and their usage pattern on the highway network must be taken into account, as described above. Village residents range from primary school children to people over 65 who make up 31% of the population

4. Road space – the conflicting uses of road space are relevant, particularly given existing conflicts between pedestrians in roads which lack footways, which will be exacerbated by extra pedestrians and extra traffic from developments approved but not yet built.  It is noteworthy that

  • New St is narrower even at its widest point (5.5 m narrowing to 4.2m) than the narrowest typical street width recognised in the DfT’s Manual for the Streets which specifies the width of a typical mews as 7.5-12m as the narrowest typical street.
  • The DfT’s Inclusion Mobility requires a minimum width of 700mm for a person in a wheelchair and with another walking beside them, 1.5m.
  • The Manual requires a minimum width of 6.5m for bus routes. New St is not a bus route but it is the route for substantial agricultural HGV traffic of equivalent size to a bus.

5.       Parking – parking outside the shop in New St already makes walking along the street hazardous for pedestrians, particularly when there are deliveries, exacerbated by passing agricultural HGVs. Parking at the surgery is equally congested at peak times, bringing further conflicts with pedestrians

All these aspects of local character; are relevant and will mean that even a slight increase in vehicular and pedestrian traffic can be disproportionately negative to road safety. Over reliance in the Appeal documents on volume and speed of traffic is therefore misleading and the assumptions on the benefits of introducing a 20 mph limit in New St exaggerated. The TRL Reports 641 and 452 cited focus on speed reduction and are not relevant to other aspects of local character.

4.2 Over reliance on historical data – The use of historical data to prophesy the future impact of the subject development is illogical. The historical pattern of recorded accidents causing personal injury with the current level of pedestrians and traffic is no indicator of the impact of more traffic and pedestrians – it is hard to see logically how it could be. On the contrary, it is obvious that the accident history for an area with a particular level of development is of limited value in determining the likely incidence of accidents when development increases – especially when even the current safety is misrepresented, rendering the conclusion in paragraph 2.4.5 unsound.

4.3 Other aspects of ‘Local character’ – the urban ‘rush hour’ profile used to analyse the traffic in New St is not very meaningful in a rural village where

  • pedestrians of all ages access the shop 7 days a week: Mon-Sat 6.30am-8pm; Sun. 8am-6pm
  • patients of all ages access the surgery which is open Mon-Fri 8am -6.30pm and 7.30pm on Mondays
  • heavy agricultural traffic passes through throughout the working day
  • New St includes two facilities needing regular deliveries, the shop and surgery
  • Back St includes two further facilities needing regular deliveries, the two pubs
  • A 17.5% increase in population will bring a proportionate increase in emergency access requirements

4.4 Actual rate of accidents – Crashmap acknowledges that its data only covers accidents causing personal injury which are reported to the police, noting ‘although it is known that a considerable proportion of non-fatal injury accidents are not reported to the police’. Therefore the accident data presented in the Report has been discounted by two factors: accidents not reported to the police and those which did not cause personal injury. There have been many more accidents unreported in the village. Those known to the writer to have occurred in the village include:

  • 2017 – Woodyard Cottage New St – the mobile library van crashed into the front wall of Woodyard Cottage making a large cavity in the front flint wall above the door.
  • 2018 – Woodyard Cottage New St – a car removed the front window sill on the ground floor, which had to be completely replaced and no longer matches the one of the other side of the door.
  • 2018 – the fence opposite the war memorial at the junction of Harleston Hill, Back Lane and Low Rd was knocked over by a passing car
  • 2019 – In New St. a contractor’s van was scraped along the whole side of the vehicle removing the wing mirror by a JCB, which failed to stop.
  • 2019 Articulated lorry attempted to do a “U” turn around the War Memorial damaged the grass surround, the sand pit and narrowly missed the Memorial.
  • 2019 A stationary car (depicted on the front cover) waiting to exit at Jubilee Corner was hit by a lorry turning into New Street from the B1116.The lorry driver did stop.
  • 2019 A Construction works van was hit by a private car in New Street.

4.5. Public Transport – there is only one bus a week on a Saturday, which does not assist with commuting leaving residents to rely on their cars to get to work.  Even this poor service is under threat of closure. This limited public transport will make the hazards and pollution arising from an increase of 17.5% in traffic of all kinds unavoidable for village residents.   

4.6 Parking – parking outside the shop represents a considerable hazard at busy times, with pedestrians having to step out into the road to progress along New St, where there is limited visibility especially as the road curves to the West of the shop. This hazard will be greatly exacerbated even with the approved developments let alone the subject development.

5. PROPOSED NEW FOOTPATH ONTO NEW ST – A new footpath is proposed between the Post Mill site and New St., presented as a safer route for pedestrians to the main services accessed via New St.

5.1. Title – In the original application, it was disclosed that the ownership of this footpath is unknown. Paragraph 2.2 of the Transport statement which states that the right of way ‘forms part of the appeal site’, is inaccurate. The right of way over it is derived from a conveyance of 30th January 1956 through which title to the field forming part of the site was also transferred and subsequently registered under Title No SK358961. For some reason the right of way is not shown on the Land Registry Filed Plan. There may be additional prescriptive rights over this land.

5.2 Safety– this footpath is depicted in Figure 2.1 of Appendix 9 and on the indicative site plan at figure 1.1. Because the photo is taken from the highway its safety is misrepresented in that when a pedestrian is emerging from this footpath onto the road there is no visibility in either direction since it is at the top of bend. The photo illustrates that this is a blind exit for pedestrians. The footpath is unsafe and is also almost opposite one of the houses built directly onto New St, Prelude, forming a pinch point and reducing safety even further because of reduced visibility from more than one aspect.

6. IMPACT OF TRAFFIC ON THE CONSERVATION AREA AND HERITAGE – Harmful impacts of excessive traffic on the conservation area, the two listed buildings on New St and the many others in the village include visual intrusion, noise and air pollution. Excessive traffic interrupts the tranquillity which is a critical part of the character of a small rural village. This will erode its heritage.

7. CONCLUSION – The Appeal documents contain unproven conclusions and are based on a thoroughly flawed baseline of data from which further flawed data is extrapolated. Approval of this development would locate housing where it is not needed, exacerbate the seriously disproportionate contribution that Mid Suffolk makes to transport generated CO2 with yet more new houses where there is no employment and over burden an already stretched transport infrastructure increasing hazards for pedestrians and irrevocably eroding the character of a historic rural village.


Traffic in New Street

The original planning application, reference 1648/17 was brought to Committee on the 21st November 2018 and, after a very substantially presented case, was refused unanimously along with two other applications in Fressingfield.

One of the main reasons for the refusal for this particular application was the unavoidable and inevitable increase in vehicular traffic as well as pedestrian traffic at the entrance of Post Mill Lane onto and along New Street.

image005

This area is already a point of congestion as it is only a few metres from the Fressingfield Medical Centre. There is an existing problem there due to insufficient parking space and no opportunity to expand. Many patients and visitors must park on the roadway ie New Street.

Vehicular traffic is often chaotic as the accompanying photo’s show and for pedestrian traffic ie parents and children walking school in New Street toward the preferred entrance to the school, dog- walkers and residents making their way to the village shop, which is further down New Street, is often a frightening experience. When heavy transport and huge farm vehicles meet on this road where there is virtually no pathway, there is simply no safe place for pedestrians.

 

20190606_103151

New Street and Top Road, which are at best ‘C’ category roads, connect the B1123 and B1116 and are frequently used to divert traffic during road works et cetera thereby bring more traffic into Fressingfield and specifically New Street.

New Street Traffic 5

There have been countless ‘collisions’ in New Street as a result of the winding and narrow road i.e. side view mirrors being damaged or destroyed, side-swipes and panel damage. Many of these incidents are not reported to the Police simply because the damage has not been witnessed or anyone harmed but some have and these are recorded. But all these issues are caused by current vehicular congestion.

At the conclusion of the 21 st November ’18 Committee hearing, Councillors commented that Fressingfield already had two approved planning applications (totalling approximately 50 dwellings) neither of which had, at that time, been developed. Along with the refusal, these Councillors unanimously agreed that no further applications should be considered until the two approved sites had been developed. At the time of writing, not only have these sites not been developed but one site is still on the market and the other has not broken ground due to surface water/drainage issues.

Why on earth should an appeal for Post Mill Lane even be considered!?


Sewerage & Flooding

Post Mill Lane Fressingfield Appeal APP/W3520/W/19/3227159

I am writing to OBJECT to the building of houses in Post Mill lane and request that the Appeal be rejected. This objection is based on sewage egress and flooding in the village. The sewerage was planned in the late 1930s and building was delayed because of the war. Details of the sewerage problems can be found in the lobbying section of the SAFE web site fressingfieldhousing.org where there are many detailed papers.

The Fressingfield sewerage system was installed in 1946. The design of the system is well documented. Sewage from the current Post Mill development is pumped uphill to New Street and continues to Church Hill, down to Low Road (150mm pipe) where it joins , at the War Memorial, another similar size branch coming across the fields from the John Shepherd development. The two pipes then join and form a single 225mm pipe which runs 200 yards to the pumping station and continues along the Weybread Straight to the treatment plant in One Eyed Lane.

Problems -Sewerage

There have been problems in the existing Post Mill houses with sewage refluxing into toilets and wash basins. This has been attributed to problems with the local pumping station in that housing development.

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In Low Road, at times of heavy rainfall the sewerage manhole covers lift and raw sewage goes over the road and into gardens and also runs back into the stream (the Beck) to be dissipated further.

This is a long standing problem. There was correspondence in 1985 between our then MP, Michael Lord and the then Anglian Water CEO Peter Bray. The Chief Environmental Health Officer was involved, but it was concluded that the correctional works needed were too expensive. It has variously been suggested that pump malfunction and failure to desludge the system was the cause. However, sewage egress has occurred following work to correct these problems, indicating they are not the cause.

The problem is becoming more common and more severe. Sewage egress occurred four times in a 5 month period between 28th December 2017 and April 2018. This is not exclusively a winter problem, but also occurs in summer (12 July 2016). The contamination has been so severe that Anglian Water have sent a ” Clean Up Team ” on one occasion.

Abdul Razaq, Director of Public Health and Protection, Suffolk County Council, has been involved and wrote on 11th May 2018.

” Thank you for your emails. I would agree that the situation relating to sewage leaks is not acceptable and unpleasant. The legal powers sit with the environmental health departments and so I have ensured that Mid Suffolk District Council know of your concerns, but it from your email it seems both they and the water company are fully aware of the situation. I have informed Public Health England of the situation although they are advisory only and have no legal powers.

Manhole

If sewage leakage does occur I am sure that you realise that it is important to avoid exposure and if exposure does occur scrupulous personal hygiene is essential”

Because the sewage egress flows into the Beck it is further disseminated and has other impacts. Effect on wildlife may also have occurred ( Dr. James Meyer- Suffolk Wildlife) . It is noted that water voles have not been seen in the Beck after the latest sewage ingress. We have reported this to the Environment Agency as pollution of a water course.

The Cause

In October 2018 SAFE held a joint meeting with four representatives from Anglian Water as well as representatives from Mid- Suffolk District Council.

At the meeting it was agreed that in times of high volumes the pressure in the pipe coming down hill from the John Shepherd development would be greater than the connection from Low Road because of gravity. This could result in back pressure on the sewer in Low Road causing the manholes to “pop”.

Detailed investigations have been undertaken by Anglian Water and there is no ingress of general rain water into the closed system. It is believed that the sewer is overloaded at times of heavy rainfall due to dwellings discharging their surface water directly into the foul sewer. When this happens the manholes lift. (5 times last year). Historical connections of surface water directly to the foul sewer are not illegal and no resident can be forced to remove the connection. No one has any idea how many houses are connected. The problem cannot be solved by increasing the diameter of the pipe work because it would reduce flows in “normal ” conditions to such a level as to increase smells and blockages. Should the manholes be sealed to prevent egress then there would be backflow of sewage into peoples’ toilets and wash basins. Anglian Water confirmed that they are not funded to invest in laying ” storm pipes ” for storm only events. Anglian Water confirmed that under normal conditions only 50% of the capacity of the sewerage system is currently used. There was agreement that the egress of sewage relates exclusively to periods of heavy rainfall and that the Beck need not flood for this to occur. The problem is that when it does flood effluent enters the water course. The point was made that there is no deliverable solution and the egress of sewage may continue. The fact was highlighted that with the potential for more houses to be connected to the sewer then more of the spare capacity would be utilised within the sewer making the ” tipping point ” for egress of sewage lower. i.e. there would be less capacity for surface water than at present.

Already 51 houses have been approved, but not yet built as well as two large public buildings. The impact of these developments on the sewage egress cannot be assessed, but based on the logic above it must make it worse.

The sewage generated from the Post Mill development currently proposed is not likely to impact significantly the capacity of the foul system in its own right. However it is reasonable to assume that in periods of high rainfall it will take less surface water to fill the capacity of the foul water system ( because it now contains more foul sewage) and that as a result an equivalent amount of rainfall post- development as pre-development will increase the risk and quantity of flooding. The flooding is also likely to contain increased levels of foul sewage content because there will be more in the system due to the increase in population.

Comments by the Appellant

9.7.11 It is important to note that the appellant agrees that the overtopping of the sewer network is- whatever the cause- unacceptable. However, preventing new development is not going to solve the existing problem, and the fact that this issue was not raised on other, similar applications in the village which were approved in the 22 month period during which the appeal application was being determined, raises questions as to why it is such a significant issue in this application, but was not considered a problem for these other developments.

9.7.12 The test in para 11 NPPF requires adverse impacts to significantly and demonstrably outweigh the benefits of the proposal in order to justify refusal. Given the modest increase in flows generated from the proposed development ( which would represent a 6% increase in the number of properties served.). It is not considered that adverse impacts arising from this development in respect of foul water and surface flood water- if there are any at all- out weigh the benefits associated with the proposal.

We agree with the Appellant that overtopping of the sewer network is unacceptable. Preventing new development will not solve the existing problem BUT it will stop the problem becoming more frequent and more of a pollutant. It was only after repeated meetings with Anglian Water and their investigations that the full cause of the problems were elucidated. It is now realised every new dwelling that is connected to the existing sewer network will make the situation worse. With more extreme weather conditions and climate change the problems are becoming more frequent and more obvious.

It is incorrect to state that issues have not been raised on other similar applications in the village. The application for a new chapel and 18 houses was approved in July 2018. (3872/16) The Planning Approval Condition concerning the surface Water drainage strategy has yet to be discharged. The senior Flood and Water Management Engineer for Suffolk County Council wrote in April 2018 about this scheme” “There is a significant risk to worsening flood risk in Fressingfield.” (this information was obtained through an FOI request.)

In summary there have been long standing problems with the sewerage system which is not fit for purpose and these problems will be significantly exacerbated by a further 24 houses at Post Mill.

Flooding

Fressingfield sits in a natural basin and the soil is impervious so the surface water naturally run to the low point, which is the Beck, using ditches and the roadways as conduit ( Church Hill and Back Road). Flow down these roadways can be very heavy and washes down mud and debris making them dangerous. Some surface water is discharged into the foul sewer. More houses and hard landscaping means more surface water and however it is restricted or temporarily restrained it must eventually flow down hill causing flooding and overload of the Beck and sewerage system.

There are two areas of ” small surface water sewers (conduits)” which ultimately discharge into the Beck. They have no connection to the foul sewer.

vicarage flood

Flooding is notoriously under-reported as Suffolk County Council themselves acknowledge, so our own evidence as residents is particularly important.

Flooding is a long standing problem in Low Road . We have representative photographs over the last 20 years. This is not only a problem in Winter, but occurs in Summer as well. It occurred 4 times in six months in 2018. Residents in Low Road have difficulty in obtaining house insurance as the area is a designated flood zone. The cumulative effect of the 51 houses approved, but not yet built and the two communal buildings is unknown.

The surface water from the proposed Post Mill development drains exclusively into drainage ditches there are no sustainable drainage systems. The development will create an additional acre of hard standing. The Plandescil Report ” Flood Risk Assessment , Surface Water Strategy and Foul Water Drainage Strategy” submitted with the Planning Application states ” In the event of an exceedance event, consideration has to be given to route surface water away from vulnerable areas towards drainage features” i.e. the houses should not flood, but more water will be diverted to the ditches and the lower village. This does not conform to the requirement of the NPPF not to cause off site flooding. The Applicant does not own all of the ditches, so he is unable to guarantee good maintenance. In any event more water going into the Beck (the ” stream” mentioned in Appellant’s submission) increases the risk of flooding. This flooding has occurred as far as Afton House up the Harleston Hill.

” our overriding objective is to ensure there is no detriment to existing customers as a result of the development” (Hannah Wilson – Anglian Water 20th April 2017)

” Flood risk should be managed and not increase elsewhere by the development.” (NPPF July 2018)

Summary

Egress of sewage onto the public roads and into private gardens and flooding are serious and unsavoury. The Appellant, although aware of the seriousness of the situation, has made no mitigation suggestions to ameliorate these serious problems which will be compounded by the building of a further 24 houses at Post Mill.


Draft Mid Suffolk Local Plan.

The above document is now available. Public consultation will take place later in the summer.

For Fressingfield it confirms us as an “Hinterland ” village with an allocation of 56 new houses between 2018 and 2036. 51 new houses have already been approved.

To view the Draft Plan, click here.

23/06/19


Post Mill Lane Appeal Notification Letter:

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Post Mill Appeal Letter – PDF

JC 28/05/19

Current News.

Suffolk Preservation Society

John Castro was approached to write an article for the latest issue of the Suffolk Preservation Society Magazine, “Suffolk View” (available here to read online – See Spring 2019)

Suffolk View Spring 2019 SAFE

Introduction

Fressingfield is a small village close to the Suffolk/Norfolk border with about 350 houses in the centre of the village and a total population of just over 1000. It is primarily agricultural with only 64 full-time equivalent jobs. In early 2017 Mid Suffolk District Council published its SHELAA (Strategic Housing & Employment Land Availability Assessment) document which identifi ed significant parcels of land in our village for potential major developments. In February two “hybrid” schemes, including 50 houses, were approved. A month later planning approval was sought for three sites totalling 208 houses with an additional 584 residents. At this stage we decided to become active. SAFE (Supporters Against Fressingfield Expansion) was formed, with a small committee and developed into a lobbying group. Our aim was to ‘limit major development in Fressingfield’.

Actions

We arranged a scientifically sound petition, visiting every house in the central area of the village and found 94 per cent of villagers were against major developments. This gave us a mandate to speak for the village. It was apparent that residents were unaware of what was happening so we arranged for distribution of posters and subsequently set up our own website https://fressingfieldhousing.org/ This was to inform both residents and decisionmakers. We instigated public meetings and wrote to specialist departments at District and County Council level, including Highways, Planning and Anglian Water. We reviewed important policy documents as they became available and made comment to the appropriate authorities, as well as publicising these on the website. SAFE was involved in both writing and organizing lobbying papers to be sent to District Council planning committee members.

These papers deal with single aspects of infrastructure and their impact on village life. We met with the senior planning officer and discussed the issues of concern to the villagers and the lack of sustainability.

Areas of Concern

When the planning applications were submitted a very significant number of objections were raised by villagers of their own volition and in their own words. These highlighted the problems in the village which would be aggravated by more development, for example the overloading of the primary school and surgery, (although these are not planning considerations); the fact that there was one bus a week and the lack of local employment. There were several major problems which we were able to publicise and provide objective information.

Traffic and road safety has been a cause of great concern for many years. Many areas do not have footways, including New Street where the shop, medical centre, scout hut and Methodist Chapel are located. New Street leads to a complex junction – Jubilee Corner. More development results in more cars, particularly as there is a lack of local employment and no secondary school in the village. A projected 57 per cent increase in vehicular and pedestrian traffic in these circumstances would lead to an ‘unacceptable impact on highway safety’. The revised NPPF cites this as a reason for refusal. There is a long standing, poorly documented problem with surface water flooding in Low Road which is at the bottom of four steep slopes. Residents testify to flooding going back to the 1960s.

There has also been a serious problem with the sewerage. Manholes lift at times of heavy rainfall, causing raw sewage to enter the roadway and residents’ gardens. This is a public health hazard and is getting worse. We have corresponded with the Suffolk Director of Public Health and met with Anglian Water who told us that the situation cannot be rectified. More development would worsen the situation.

Heritage aspects were also important. The proposed urban developments would be out of-scale and alien in character. Fressingfield is a small village set in a hollow dominated by its ancient Grade I listed church. There are 444 houses in the Fressingfield Parish of which 58 are listed. There are also many unlisted ancient houses. The Suffolk Preservation Society robustly objected to all three schemes on the grounds that Fressingfield was a deeply unsustainable location. Both Historic England and Suffolk Archaeology expressed reservations about some developments

The Outcome

The senior planning officer’s report recommended refusal of all three planning applications. The applications had been taken to Committee on 21st November 2018 and, after debate and an open vote, all three were unanimously rejected on grounds of –

  1. an unsustainable location,
  2. exacerbation of flooding with the egress of sewage, and
  3. highways impact.

Epilogue

The aims of SAFE have been to express and publicise the views of the village in a polite and objective way and to clearly state the facts, without bias or emotion. It was important to maintain the support of the village and the success of this approach was manifest by more than 60 people journeying to Ipswich for a 9.00am Planning Committee hearing.


Five Year Land Supply

In October 2018 an Appeal regarding housing at Woolpit was upheld because the Inspector ruled that the Local Authority could not demonstrate that it had a five year land supply. MSDC reviewed the deliverability of their housing targets and published a draft document for consultation which ran from 17th January to 28th February 2019.

The conclusions of the report are:-

  • A housing land supply of 5.06 years is deliverable ( para 7.5 and table 16 page 35)
  • Local Housing Need is considered to be 575 dwellings per annum(dpa). Under the Housing Delivery Test a 20% buffer is required uplifting this to 690 dpa. ( see table 2, page 10)
  • A delivery rate on sites of 40 dwellings per annum is considered appropriate ( para 3.36, page 21)
  • A lead- in time ( from the submission of the Application to start on site/first completion) of 2.8 years is considered appropriate ( para 3.38, page 21)
  • The final report is an informal planning document and does not form part of the statutory Development Plan or any adopted back ground document . It is a material consideration to be weighed in the assessment and determination of Planning Applications in the District between the date of publication and the date of any other statement on housing supply published subsequently.

With the strict new standards of evidence required when demonstrating a land supply MSDC can confidently announce that they can demonstrate a 5 year land supply under the new strict criteria. They believe they have consistently had a 5 year supply over the last 6 months and can now evidence that position to the satisfaction of the National Planning and Policy Framework. A 5 year land supply is only one part of the picture when it comes to assessing Planning Applications, but it is an important element.

In Summary

  • MSDC local housing need is 690 dwellings per annum
  • The land supply position is 5.06 years

 


The main issues that were raised at the Planning Committee in November 2018. namely highways and flooding with sewerage egress onto the roads still exist and will not go away. In fact, with the developments in School Lane ( chapel and 18 houses – 3872/16) and Red House Farm ( scout hut and 28 houses -4410/16 ) which are not yet built will make the situation worse.

Road Accidents Continue.

Only serious accidents with personal injury are logged by the Authorities. It is our view that other accidents are important and should be recorded. With increasing traffic and pedestrians these lesser accidents may become more serious. The roads in Fressingfield are dangerous. Recently another incident occurred at Jubilee Corner with a private car sustaining significant damage after being hit by a lorry.
Jubilee Corner 5th January 2019

Accidents continue. On the afternoon of February 27th, a villager with 2 passengers, also villagers, were stationary  and waiting to turn right into New Street from the Harleston Road. A truck heading towards Harleston from the Laxfield road struck the off side of their vehicle. There were no injuries but over £2000 of damage was caused to their vehicle.

Soon after this an articulated lorry tried to turn at the War Memorial and crossed the surrounding grass and damaged part of the sand container. Fortunately, the Memorial itself was not damaged.

It is important to record all traffic accidents in the village and damage to property. Any details can be sent to any SAFE members – listed under “members” on this web site. Photographs showing damage would be very helpful.

“Near misses could become serious with more traffic.”

Sewerage.

When the Applications were heard in November 2018 sewerage was an important consideration. SAFE has now received documentation that confirms that further development in the current situation will increase the risk and quantity of flooding at times of heavy rainfall and the egress of sewage from the manholes will increase. This will occur because more houses will generate more foul sewage meaning a smaller volume of rainfall is needed for the sewer covers to elevate.

We have been told by Anglian Water that there is no solution to this problem. We have reports of sewerage blockages occurring in New Street on 2 June 2018 and again on 10th June 2018. The sewage from Post Mill is pumped to the sewer in New Street.

Future Developments.

The Parish Council housing policy, as we understand it, is that the current
approved houses ( 46 at School Lane and Red House Farm) will be the agreed allocation until 2026. There is no mention of the additional “windfall houses” which will be built. The Parish Council Minutes of 18th December 2018- Item 18.9.2 state that the Council proposes to discuss potential plans for the period post 2026 with the NDP committee, Developers and other interested parties. It is not yet clear whether SAFE will be part of this process and whether the general public will be involved.

SAFE believes it would be better to wait for the publication of the draft Local Plan and the draft Neighbourhood development Plan as both of these will inform on the way forward.

Conversion of the “Old Baptist Chapel” in Cratfield Road ( DC/19/00571)

Plans have now been submitted for permission to convert the Grade 2* listed chapel into a single 5 bedroom dwelling. Comments and objections should be sent to MSDC by 1st March.

The Application proposes that the surface water drains into the foul sewer. In view of the sewage problem in the village a more eco friendly solution and a better surface water strategy would be recommended.

Mid Suffolk Heritage Department has made comments on design.

Historic England have made significant comments. They have concerns on heritage grounds and would like significant changes to the plans. Their recommendations can be viewed by clicking on this link

Other Documents.

Local Plan. Within the Local Plan the village hierarchy will be an important determinant in the amount of development in Fressingfield . We expect our village to be classified as an ” Hinterland Village”. SAFE will be party to these discussions with MSDC. It is anticipated that the next draft of the Joint Local Plan will be presented to Babergh and Mid Suffolk Council Meeting in June 2019 with public consultation thereafter.

Right Homes Right Places. This policy document is still with the Government and has not been adopted yet following consultation. There is no information when this might be.

Neighbourhood Development Plan  The draft Plan is currently available for consultation.

Planning Appeals.

As yet, we have no information on Appeals or resubmission of the Applications
considered in November 2018. SAFE is preparing for any of these events.

It has been noted by many residents that traffic recording apparatus was installed outside the Methodist Chapel in New Street. This, of course will not have recorded vehicles approaching from Jubilee Corner going to the village shop and turning soon after and similarly vehicles approaching from the Post Mill end of the village going to the surgery. Trip rates will consequently be unrepresentative.

J.E.C. April 2019


The Planning Meeting

The Planning Meeting took place on Wednesday 21st November 2018 at Endeavour House, Ipswich

There was a magnificent attendance of about 50 villagers. Thank you all so much for this wonderful effort. It was much appreciated and showed the Planning Committee and Officers the strength of the feeling in the village. Well Done.

PANO_20181121_091515.vr
Endeavour House, while public were arriving.

Procedure

Each Application followed the same format:

  • An introduction by the Acting Chief Planning Officer;
  • Comments by the Parish Council;
  • Comments by SAFE;
  • Comments by the Applicants Agent;
  • Comments by the Ward Councillor.

There followed, after debate amongst Committee members, an open vote.

Results

(The full statement for refusal is view-able for each application below)

Stradbroke Road (1449/17) – unanimously rejected

John Shepherd Road (1432/17) – unanimously rejected

Post Mill (1648/17) – unanimously rejected

Minutes of the MSDC Planning Meeting (Mid Suffolk Development Control Committee A) can be read here, detailing the events of the meeting in full.


News Article

The East Anglian Daily Times has published a story about the Planning Committee Meeting at 7pm, 23 November 2018:

Fressingfield 200 homes plan refused after hundreds object

image
Three outlines of planning applications for new homes in Fressingfield Picture: GOOGLE MAPS (EADT News Story)

Plans to develop more than 200 homes in a north Suffolk village have been rejected after hundreds of objections and fears over “unacceptable growth”.

Three outline planning applications were presented to Mid Suffolk District Council’s development control meeting on Wednesday by two developers aiming to develop land in Fressingfield.

Developer Simon Brown had lodged applications for 85 homes off Stradbroke Road and 99 homes on land west of John Shepherd Road, while Davidson Ltd requested permission for 24 homes off Post Mill Lane.

Reports prepared for the planning committee said all three proposals were outside the settlement boundary of the village, with planning officers describing the plans as a “significant and inappropriate level of development” with the level of growth deemed “unacceptable”.

Fressingfield Parish Council objected to all three developments, stating that it “remains committed to its original (Dec 2015) view that the village could accommodate growth of 50 units over the coming 10 years and will reject proposals that exceed this”.

Wednesday’s committee unanimously refused all three.

Councillor Lesley Mayes, vice-chairman of Mid Suffolk District Council’s development control committee, said: “The decisions taken were not a simple matter, considering over 200 homes across three applications.

“The committee looked at each application in turn and the individual merits and weaknesses of each one.

“After long deliberation, the committee felt unable to approve any of these applications: each was refused for reasons specific to the individual application, but some common themes emerged including an unacceptable increase in traffic in the village centre without safe, practical alternatives and the impact of the proposed developments on the drainage system of the village.”

Suffolk Highways also objected during its consultation because of road safety fears, while 308 objections from members of the public were received for the two largest developments alone.

A spokesman from NWA Planning, agents on behalf of Mr Brown were approached for comment.

Two applications for 46 homes in the village were approved earlier this year.

Original web page can be found by clicking here:

Fressingfield 200 homes plan refused after hundreds object – EADT 23/11/2018


Email Submission – Prior to Planning Meeting

At 4.00pm the day before the hearing the following letter was received from the Agents acting for the Stradbroke Road scheme and the John Shepherd scheme offering a significant reduction in the number of houses to be developed.

The Chair of the Planning Committee , with legal advice, made it clear that the original Applications, not the last minute proposals would be considered. Despite this the Agent for Stradbroke Road and John Shepherd Road presented the Applications almost exclusively on the revised schemes.

To All Members of Mid Suffolk District Council Development Control Committee A

Dear Member

I am writing to you as agent for the above applications.  You will be aware that both applications are to be considered at the Development Control Committee’s meeting on 21st November 2018 with both applications being recommended for refusal.  The applications were submitted following inclusion of both sites in the Council’s SHLAA and pre-application consultation with both the District Council and the County Highway Authority indicated no objection to the principle of the development proposed.  Indeed, after nearly 18 months following submission of the applications the current Committee reports provide the first indication to my clients that Council officers have fundamental objections to the schemes such as to warrant refusal of planning permission.  Those objections have not been put to my clients for consideration and comment and had that been done I am sure that my clients would have given the concerns positive consideration.  As it stands, if the Committee is minded to refuse planning permission my clients would propose to submit revised proposals which I believe would overcome the objections raised sufficient to allow the Committee to support the revised schemes.

In essence, these revisions provide for:-

(i)                  A substantial reduction in the number of dwellings proposed;

(ii)                A consequent substantial reduction in vehicular movements at Jubilee Corner and within New Street;

(iii)               Measures to ensure no additional flood risk is caused;

(iv)              Avoidance of any unacceptable impact on the Conservation Area and adjoining listed buildings.

In respect of the two applications these revisions would involve the following changes:-

Stradbroke Road, Street Farm

(i)                  A reduction in number of dwellings from 85 to 10 – 15 which would require a revised application;

(ii)                A change from estate development to frontage development reflecting existing development on the opposite side of Stradbroke Road;

(iii)               Provision of a frontage footpath to Stradbroke Road and footpath link to the recreation ground adjoining the southern boundary;

(iv)              Diversion of the public sewer in New Street through Church Farm to connect with the mains sewer downstream of the existing flooding problem thereby removing a substantial number of existing dwellings from the problem area within the foul drainage system resulting in a net improvement in flood risk.

John Shepherd Road, Church Farm

(i)                  A reduction from 99 dwellings to 27 dwellings by restricting housing development to the first field within the application site adjoining John Shepherd Road.  This could be achieved by modifying the existing planning application as the reduced site is clearly severable from the remainder of the development and self-contained;

(ii)                The reduced development would have a commensurate effect on traffic in New Street and Jubilee Corner;

(iii)               Minor modifications for foul drainage proposals would enable connection to the mains sewer downstream of the existing pumping station so as to avoid any exacerbation of the existing flooding problem.  This can be covered by either submission of amended plans or by planning condition;

(iv)              Omission of development immediately to the west of the adjoining listed buildings and Conservation Area which is protected, in any event, by an established 10m wide boundary hedgerow.

The NPPF requires Local Planning Authorities to approach development proposals in a positive and creative way and support for the revised approach to the development of the Stradbroke Road and John Shepherd Road sites as outlined above would meet that requirement.  It would result in:-

  • a substantial reduction in the number of dwellings proposed and a scale of development normally considered appropriate for hinterland villages;
  • significantly reduced traffic generation coupled with substantial improvements to the road system which would be of benefit to the whole village;
  • a significant reduction in the existing flooding problem; and
  • it would avoid unacceptable impact on Heritage Assets.

I would therefore urge members to support modifications to the John Shepherd Road application as proposed and to indicate that a revised application for frontage development on Stradbroke Road could be given favourable consideration.

An immediate response was sent to all committee members & Planning officer from Elizabeth Manero and SAFE:

Dear Councillors – you will be aware of this very last minute amendment to proposals 1449/17 and 1432/17, produced less than 24 hours before the planning committee meeting. We think it quite inappropriate to put Councillors into the invidious position of having to decide two very contentious amended applications on the  basis of an email making very significant changes without any of the evidence usually required to support the claims made for those changes.

1. Unlawful process -This document is  not on the planning register so other objectors, and there are many as you may know with the petition against the original proposals attracting 450 signatures, have not had the chance to review it. We do not see that the Committee can lawfully discuss this proposed amendment in the absence of a further consultation, particularly  because 3 out of 4 of the possible criteria that government guidance specifies for re- consultation are present in this case: substantial original objections (public health hazards, road safety, flooding); substantial changes proposed and issues raised that were covered in our objections (road safety, flooding, sewage and heritage)

2. A document which fails to resolve our objections – Even if it were appropriate for this document to be considered tomorrow in relation to these applications, we feel that it does not address our objections and we would respectfully suggest that the Committee should  proceed with the Officer’s recommendation for refusal.

3. Early Thoughts – In the limited time available we have endeavoured to collate some early thoughts, based on the extremely sketchy information, contained in the email to yourselves from Neil Ward on behalf of the applicant, sent at 3.55 this afternoon.  No plan has been provided, making it very difficult to understand what is actually proposed.

a. Generally The fiction underlying the presentation of these changes is that there is now spare road and drainage capacity and the very, very serious impact of the original proposals would now only very serious – and therefore acceptable. The truth is the road network is currently overloaded, the flooding is already out of hand and both these problems will be exacerbated by the 52 houses already approved. We already have another 119 residents arriving including at least a dozen primary school children, as well as those coming to the scout hut and the Baptist chapel. We are already approaching an unsustainable situation so no amendment is capable of making these additional proposals sustainable.

b. Road safety – the reduction to  up to 42 houses, in two parcels of  10-15 at Stradbroke Rd and 27 at JS Rd, does not overcome either our road safety objections, nor those of SCC because

  • The baseline road safety has been assessed by SCC from their observation of existing levels of vehicular and pedestrian traffic, as already subject to road safety risks
  • In addition to the current level of pedestrian traffic (unmeasured in the Cumulative Transport Assessment CTA originally provided), the extra 119 pedestrians that will come from 33872/16 and 4410/16, will exacerbate existing independently observed road safety hazards further, while the extra vehicular traffic they will bring including that caused by people attending the larger Baptist Chapel and larger scout hut from outside the village (explicitly not measured in the original CTA) will exacerbate those road safety risks further,
  • The people living in the reduced number of houses suggested  would still have to access the ‘core area’ as defined by SCC to access the main facilities (shop and surgery). There might be fewer of them but there will still be an extra 96 people (using SCC’s formula) walking round the village and at least 42 extra cars contributing to traffic every day. Unless these new residents were banned from car ownership, this can only aggravate road safety through higher pedestrian and vehicular traffic in the village generally and in the core area.

c. Flooding and sewage – it is important to distinguish between these two existing problems.

  • Flooding happens independently of the sewage overflow and is poorly recorded. In the absence of accurate records it is hard to see how any calculations can have been done  to prove any improvement in flooding – a mere statement in an email is not adequate to inform a planning decision.
  • No evidence is provided as to how the sewage problem would be avoided by moving the connection beyond the pumping station, which may or may not be able to cope in the different topography in which it lies – again a mere statement is not enough to inform a valid decision

3.Amendments Stradbroke Rd –

  • It is  not clear how a footpath link to the recreation ground assists with the safety route to the school, shop and surgery – how would people be forced to use this very long way round to get to the facilities in the core area?
  • With the 52 houses already approved, Jubilee Corner and New St will already be more dangerous so the point about a supposed reduced additional impact from reduced  numbers of new houses is irrelevant .
  • Cars coming through Jubilee Corner and into New St from these new  42 houses, at least once a day, and would add significantly to the regular traffic through this dangerous junction, which is already set to increase as is the number of pedestrians making their way round and along it, with all the evidenced problems of poor visibility.
  • This would gravely compromise the conservation area particularly New St., through additional traffic, which is already hazardous.
  • The sewage reroute is hard to assess and Anglian Water would need to comment upon this. The volume of sewage added would still be significant and it is not clear that the pumping station has capacity to deal with this. Where would this route be and is it uphill or not? Given the chequered history on this, the suitability of this proposal would need a very through independent assessment – a few lines in a last minute email does not meet this standard.
  • There is no assessment of the risk of flooding elsewhere as guidance requires (from more hard standing for example than currently), and no mention of a SUDs.
  • We should expect a cumulative flood risk assessment to be done of these amended proposals and Post Mill as well as the two approved developments as the 23018 NPPF requires.
  • The assertion of a ‘net improvement in flood risk’ is not tenable – there is an existing flood risk, about to be worsened, and moving these houses to discharge sewage further up the network whilst still adding more surface water and less permeable ground, will not mitigate that
  • There is no mention of any affordable housing. We already have 12 being built in the approved proposals

4. Amendments John Shepherd Road

  • Building more houses with more traffic, will not ‘reduce traffic’ as claimed
  • SCC has pointed out (their letter of 31st July 2018) that the existing pedestrian access from the proposed JS Rd development does not currently have good visibility and cannot be improved. This  position remains unchanged.
  • These additional houses would still add to traffic emerging onto Back St. and contributing to hazards at Jubilee Corner including the adjacent footpath which SCC has highlighted as particularly hazardous
  • There are no ‘substantial improvements to the road system’ as claimed, other than a new foot path from S Rd to the recreation ground, a destination of limited value
  • There is no ‘significant reduction in the flooding problem’ as claimed.  Flooding must be distinguished from sewage overflow. How would  these houses reduce flooding?

5. Re-consultation – We do hope that you will proceed to refuse these application in line with Officer recommendations. In the event that you decide to entertain these amendments we would request a significant re consultation period to allow the 1000 plus residents of the parish the chance to respond, especially given the run up to the Christmas period.

Many thanks

Elizabeth Manero and John Castro

SAFE


Major Issues

There are five major issues relating to proposed Applications –

  • Overall Sustainability
  • Flooding and Sewerage
  • Highways and Road Safety
  • Heritage
  • Deliverability & Viability

1 – Overall Sustainability

Fressingfield Planning Applications 1432/17, 1449/17 AND 1648/17

Sustainability Summary

SustainabilityPaper1

1. THE STORY SO FAR

1.1 Sustainability Deficit – Construction has yet to start on the 46 houses, larger scout hut and Baptist chapel already approved. These will come on top of 25% housing growth since 1995. There has been no associated increase in sewerage or road capacity, so there is already a ‘sustainability deficit’. This would be aggravated by the three further proposals for 208 houses, increasing housing overall by 57% and bringing a 584 extra residents to the village, according to SCC estimates.

1.2. Accountability deficit – In Mid Suffolk, houses have not been built where policy intended. In all but two of the last eighteen years, more houses have been built in rural rather than urban locations, contrary to MSDC policy and compromising ‘the intrinsic beauty and character of the countryside,’ which the NPPF seeks to protect. Despite an MSDC target of 100 houses over each five-year period across all Primary Villages like Fressingfield, 197 houses were built in such villages between 2012 and 2017. In 2017 2018, 120% (120) of the entire target for the succeeding five years was built across such locations.

This ‘accountability deficit’ would be aggravated by these three further proposals because they would locate 48% of the annual housing need figure for the entire district (MSDC 430) in one medieval rural village. Even based on the higher annual figure specified in the recent Woolpit Appeal (702), 30% of the houses needed for the whole district would be built in Fressingfield – a village currently occupied by 1% of its population. The courts have recognised failure to apply policy as a material consideration in planning decisions.

In addition to being disproportionate, contrary to MSDC policy and unreasonable, such approvals would flout the NPPF (para 103), which requires ‘significant development’ to be ‘on locations which are or can be made sustainable.’ 1 As explained below, this location cannot be made sustainable.

2. SUSTAINABILITY AND ADVERSE IMPACTS

In the absence of an up to date development plan, the NPPF (para 11) presumes proposals to be sustainable, and requires them to be approved, unless:

a) specified assets need to be protected, including ‘areas at risk of flooding’ ; or
b) any adverse impacts of approval would ‘significantly and demonstrably outweigh the benefits’ when assessed against the NPPF policies as a whole.

2.1 Flooding and Drainage – there is a long standing and poorly documented problem of surface water flooding in Low Rd. which runs along the hollow formed by the four steep slopes that characterise Fressingfield – a rare Suffolk topography according to MSDC’s own Joint Landscape Guidance. This is also the route of the beck and the village’s foul sewer. Residents testify to flooding going back to the 1960s and can evidence their attempts since 1985 to get this problem addressed.

The additional long-standing problem of sewage manholes popping in heavy rain causes raw sewage to pollute residents’ gardens, leading to a public health hazard and possible statutory nuisance. This hazard is getting steadily worse and seems to coincide with the 25% growth in the village over the last 25 years or so. It has happened eight times since 2016 alone

These factors were not taken into account in the Flood Risk Assessments for the five developments, which under the NPPF must assess impact of developments on flood risk ‘elsewhere’. This was because of flawed information from the bodies dealing with flooding and sewerage:

SCC – Flood records are acknowledged to be incomplete, because of low reporting. Our July 2018 Environmental Information Regulations application disclosed that SCC

  • has records of only one flooding incident in Low Rd. since 2011 (out of 29 floods recorded)
  • does not know how much surface water gets into the sewer, nor the extent of current flooding
  • designates the sewer as Combined*, (*designated to take both surface water and sewage) although Anglian Water, its owner, insists that it is not

SCC has required no cumulative impact assessment of the flood risk of these multiple developments, as the NPPF (para 156) requires. It has recommended approval based on an incomplete picture of the current and potential flood risk, and an incomplete understanding of whether surface water does – or should – get into a sewer that regularly floods.

b) Anglian Water – Despite regularly attending incidents of sewage egress from the sewer, Anglian Water have recommended approval of these proposals, at this stage. Our EIR application to them of August 2018 revealed that their reasoning ignores reality:

  • an unknown number of houses are connected to the foul sewer for rainwater discharge
  • this causes an unknown amount of surface water to enter the foul sewer
  • with increasing frequency, any spare capacity in the sewer is taken up by this surface water

These connections are not illegal and residents concerned cannot be compelled to change their connections. Although this surface water is the cause of the regular flooding, Anglian Water does not consider it to be within their power to recommend refusal of these applications because of it, as this is not a sewage problem and their remit is exclusively sewage. Anglian Water has confirmed that the problem of egress of sewage cannot be cured.

Unless the 105 new residents expected in the 46 approved houses, and the 479 in the 208 proposed houses are put on a forced starvation diet, there will be 57% extra sewage discharging into a system which already regularly floods, pollutes and causes hazards to public health. The threshold for flooding will be lower because of the extra houses and climate change, while the impact will be higher because of more sewage in the system. Planning approval would fail to protect an ‘area at risk of flooding’ and generate precisely the sort of overwhelming ‘adverse impacts’ that make a development unsustainable according to the NPPF.

2.2 Traffic and Road Safety Despite unresolved concerns about road safety and congestion, SCC has recommended approval of these applications, at this stage. SCC estimates an extra 584 residents, including 63 primary school children, all variously walking to the medical centre, the school, the shop, the pubs, the sports centre, Sancroft Hall and the three places of worship. Yet they have asked for no baseline data on pedestrian traffic, nor any modelling of the increase, and have ignored the impact of more traffic on either. The amount of additional traffic resulting from the larger scout hut and Baptist chapel has been omitted from discussion altogether.

There are many areas of the village without footways where pedestrians must walk along the road, including most of New St. where the shop and medical centre are located, as well as one complete side of Jubilee corner. Increases in pedestrian and vehicular traffic will make this more hazardous. Planned and existing footpaths concentrate pedestrian traffic at the points where these footpaths will join the road. Yet in some cases, visibility is very poor:

  • Visibility where an existing footpath emerges onto New St., a few yards from Jubilee Corner, offers no visibility into Back Street (onto which John Shepherd Rd emerges) nor Stradbroke Rd. These are the roads onto which traffic from an extra 184 houses will emerge. SCC recommends painting the lines on Jubilee Corner a different colour to slow traffic down.
  • The new footpath proposed from Post Mill Lane onto New Street will emerge at the top of an outward facing curve in New St, with very poor visibility in each direction and no footway. SCC does not appear to be aware of this.
  • The village shop, which is vital to its sustainability, does not have adequate parking and it is already dangerous for pedestrians negotiating their way along the road around cars parked outside the shop, with the view of oncoming traffic blocked. More traffic and pedestrians will increase this hazard. SCC has ignored this factor.

The needs of pedestrians have not been assessed, breaching the NPPF requirement to ‘prioritise pedestrians’. Mitigation measures designed without data on pedestrians, children, cyclists or disabled people do not address the likely adverse impacts upon them. Given current road safety risks, a 57% increase in vehicular and pedestrian traffic of all types, would clearly lead to ‘an unacceptable impact on highway safety’, which the NPPF cites as a reason for refusal.

Fressingfield has a one bus a week, described by SCC as ‘of no use for commuting’. This suggests that at least an extra 508 car journeys will be generated per day by 254 new houses, assuming just one return journey per house per day, whether to travel to and from work or school, or for major shopping, leisure activities or to get petrol, increasing emissions by a very considerable amount.

The information provided in support of the planning decisions is incomplete, in that it not only ignores different types of road users but it also fails to assess the impact on the environment. The impact on character of a small medieval village of so much extra traffic has been entirely ignored.

2.3 Heritage – These developments would be out of scale and out of character for Fressingfield.

Both John Shepherd Rd (1432/17) and Post Mill Lane (1648/17) are extensions to existing housing developments and would be contiguous to each other, creating a collar of new housing around the western boundary of a medieval village, matched by new housing to the south (3872/16 and 4410/16 already agreed and 1449/17). This would radically alter the village’s character and certainly not make a ‘positive contribution to local character and distinctiveness’ as the NPPF requires.

Fressingfield is a small village set within a hollow dominated by its ancient church. It comprises 444 houses, 58 listed buildings and many unlisted historic buildings. Large estates around its boundaries would destroy its character as a small ancient settlement and compromise its relationship to its rural setting. Both Suffolk Archaeology and the Suffolk Preservation Society have expressed reservations about some of these developments and the former has formally objected to part of 1432/17.

3. THE PLANNING SYSTEM

In addition to complying with the NPPF and relevant local policies, like all public bodies MSDC and SCC are required by law to

  • act only within the powers they has been given; and
  • take account of matters they are required expressly or by implication to take account of; and
  • disregard matters which are not relevant to the decision; and
  • avoid ‘a conclusion so unreasonable that no reasonable authority could ever have come to it’

The flaws outlined above call compliance with these matters into question.

4. CONCLUSION

Policy limits on development in villages like Fressingfield which were designed to maintain their sustainability, have been exceeded for many years, creating a ‘sustainability deficit’ before these applications are even considered. An unknown number of houses are connected to the sewer for rainwater discharge, which has caused flooding and pollution for many years, of the worst possible kind – human excrement flooding onto the highway, into the beck and adjacent properties. This has been neither recorded nor resolved. More houses would mean a greater impact from high rainfall because an even greater volume of sewage would overflow.

The increase in car journeys by so many new residents in a location with minimal employment opportunities and a sparse bus service will be significant, exacerbating emissions and contributing to climate change rather than mitigating it.

Fressingfield is a small medieval settlement within an unusual landscape setting. It will suffer significant harm from three large developments that, together with the two already approved but not constructed, will swamp its character.

No amount of mitigation can make what is unsustainable, sustainable. Adverse impacts on flooding, pollution, public health, road safety and the environment together mean these developments would not be sustainable and their adverse impacts would be significant.

Elizabeth Manero, on behalf of SAFE 26th October 2018

The full report on sustainability can be accessed here: Sustainability Detailed Paper


2 – Flooding & Sewerage

Recent Planning Activity

There has recently been a lot activity regarding the Planning Applications for Fressingfield. Flooding and sewerage are currently the factors being considered. The Principal Planning Officer, Vincent Pearce posed a number of questions to Officers concerned with these matters. These are shown below:

1432/17 Officer Correspondence

The response from Jason Skilton at Suffolk County Council is also below:

Drainage Issues and Flooding Response

SAFE has produced papers on flooding and Sewage which have been circulated to Planning Committee members and Senior Planning Officers. See lobby papers:

An Overview of Flooding and Sewage Egress in Fressingfield

Lobby Paper – Problems with flooding and sewerage in Fressingfield

Contents in full below:

Problems with Flooding and Sewerage in Fressingfield

“Anglian Water would not permit the discharge of surface water from a new development or hard standing area to connect to a dedicated foul water sewer” – ( Growth and Planning Services Team at Anglian Water 11 May 2017 )

John Shepherd Way( Road) – 1432/17 ” -Surface Water Disposal -The proposed method of surface water drainage submitted is acceptable to Anglian Water.   –The connection point for the surface water would be to manhole 9651  – at a rate of 17.5 litres per second” – ( Nigel Minter at Anglian Water 8th August 2017)

Application 3872/16   ” Should infiltration or attenuated discharge from the ditch not be possible Anglian Water have confirmed they would accept restricted discharge rates of 5 litres per second into their network.” -( Plandescil Report 17th August 2017- Confirmed by Anglian Water 27th October 2107 – Mark Rhodes Report.)

” our overriding objective is to ensure there is no detriment to existing customers as a result of the development. “ -( Hannah Wilson- Anglian Water 20th April 2017.)

” Flood risk should be managed and not be increased elsewhere by the development “ -(NPPF July 2018)

“Without an adequate system for surface water drainage, this is causing flooding on the  road. Surface water is also getting into the foul sewer system, which is not designed to cope these levels of flows and therefore causing manholes to pop and sewage to overflow. I would recommend that the lead local flood authority need to ensure a suitable drainage system for the surface water is implemented  and Anglian Water need to remove surface water inputs from their foul sewer to relieve some of the pressure.” -(Rachael Storr- Environment Agency 18 May 2018)

There seem to be a number of paradoxes and conflicting advice in these statements. Certainly if more surface water is allowed into the sewer the sewerage system problems will be exacerbated.

This paper points out the short comings of the current strategy and seeks clarification and answers about  factors which  may contribute to the current problems.

Background History

There is a long standing problem with flooding and sewage egress, but it appears to now  be more prevalent with four episodes in six months at the beginning of 2018.

In 1988 the problem was discussed between our then MP Michael Lord and Anglian Water CEO Peter Bray. The Chief Local Authority Medical Officer was involved as was the Local Government Ombudsman ( correspondence on this is available).

Egress of sewage only occurs at times of heavy rainfall suggesting that the  system is filled with excess surface water. If more surface water is allowed into the sewerage or Beck the situation will be made worse.

Current Situation

There are some considerable concerns about flooding and sewage egress in Fressingfield. I understand that SCC is primarily concerned with flooding whereas  Anglian Water have responsibility for the sewerage system.

The problem in Fressingfield is that the two aspects are intimately related. Surface water flows downhill to Low Road ( the Lowest point of the village) towards the Beck, sometimes the Beck overflows  and causes flooding and with, or without flooding of the Beck the manholes lift and sewage and water flood onto the road and private gardens. Because of these inter- relations a number of agencies are involved and it is difficult to get clear answers to questions.

Agreed Points

What is agreed, I believe , is that :-

  1. Low Road is at the bottom of 4 steep inclines.
  2. The soil in Fressingfield is impervious.
  3. Flooding in Fressingfield is a long standing problem.
  4. Manhole covers “pop” and this has been a long standing problem.
  5. There is a single sewerage system which takes both sewage and some surface rain water.
  6. Zonal Payments, as with CIL payments,  are not necessarily spent on the village from which they emanate.
  7. Sewage from Fressingfield is pumped to the Weybread treatment plant.

Questions

  1. Why is there flooding and egress of sewage in Low Road ( 4 times in a six month period 07/12/17; 12/03/18; 30/03/18 and 3/04/18)
  2. Are these problems due to overload, particularly surface water entering the system.
  3. How many properties in Fressingfield have an abatement on their sewerage bill because they do not discharge surface water to the sewer?
  4. How many new build properties and developments in the last 30 years been given permission to discharge surface water  to the sewer.
  5. Currently there are 2 major approved schemes, not yet built. We believe that the Chapel scheme ( 3872/16) has permission to discharge to the sewer. Does the Red House Farm Application  ( 4410/16) also have permission to discharge to the sewer and, or via ditches to the Beck?
  6. There are 3 major Applications outstanding  ( 1432/17; 1449/17; 1648/17) Will any of these be permitted to discharge surface water to the sewer or Beck?
  7. All of the drainage strategies appear to be reliant on desk top modelling. How robust are these and what are the levels in confidence? Obviously such   modelling is not fool proof because a change of strategy has occurred on 1449/17 after further extensive modelling.
  8. Will Application 1449/17 be remodelled now as we believe there is a revised site layout increasing the area of hard standing? Jason Skilton ( SCC )wrote on 9th July ” If the layout has changed Area Plan 1152-02-003 will need to be changed as would the FRA/drainage strategy”.
  9. Why does the cumulative impact study include only the three Applications outstanding and not the two already approved, but not yet built?
  10. Is it correct that the desk top modelling allows for 25%ingresss of surface water and is it true that a small inaccuracies in this assumption will significantly affect the outcome figures?
  11. Have Pre-Planning assessments  been updated as plans for developments have changed?. For example a nursing home was in the original John Shepherd scheme( 1437/17) , but this has been omitted and an additional 49 houses added?
  12. Is it true that the soil conditions and topography in Fressingfield make sustainable drainage systems difficult to achieve and discharging into water courses increases the risk of flooding in Low Road ( Anglian Water Letter 20th August 2018)
  13. Is there capacity in the pipe work going to the Weybread, particularly beyond the proposed additional 110 houses for Weybread. Can the system cope with a possible additional 372 houses. ( 54 in Fressingfield approved, but not yet built; 208 under consideration in Fressingfield; 110 in Weybread.) How is this capacity assessed objectively and if only part of the Applications were approved what is the cut off point in terms of the number of houses?
  14. Surface water on the proposed Post Mill site flows to the ditch. I understand that the it is proposed that the flow is attenuated, but if there is very heavy rain the system is designed not to flood the housing estate but will cause the water to flow to the Beck and flood Low Road. The ability of attenuation mechanism to cope with extreme weather conditions has not been evaluated. I note that the drainage consultant for the scheme has included a disclaimer that he will not be liable for any subsequent flooding.
  15. I understand that detailed modelling of the drainage strategy and its approval by the Planning Authority is  not required until after Planning permission has been given. What happens if modelling subsequently shows there will be flooding of the buildings and off site flooding.
  16. Is it true that the permitted capacity  of the  Weybread treatment plant is assessed on dry weather and not total flows and is this how compliance is achieved? There are massive fluctuations particularly when storm water enters the system. Is this of significance in the total overall assessment of the realistic capacity of the treatment plant?

Summary

There are serious problems with the sewerage and flooding in Fressingfield.

These are compounded by the topography and the poor infiltration of the mainly clay soil.

The egress of sewage is probably due to overloading of the sewerage, especially by surface water which has been historically allowed to enter.

Additionally, foul water from extra dwellings will place a further load on the system.

Dr. John Castro on behalf of SAFE

John Kelsall, Elizabeth Manero, Pam Castro, Trevor Orchard, Abi Maydon, Dawn Cavilla, Michael Miles

3 September 2018


Anglian Water

Anglian Water convened a meeting to discuss the outstanding questions. Here are the notes of that meeting:

Notes of an Informal Meeting held on 12th October to discuss Sewerage Issues with Anglian Water

Present

From Anglian Water From MSDC From SAFE
Luke Crump Lavinia Hadingham John Kelsall
Hannah Wilson Vincent Pearce Elizabeth Manero
Nigel Minter John and Pam Castro
Grant Tuffs

Introduction

John Castro welcomed those present and stated that the purpose of the meeting was to discuss sewerage issues and to gain a better understanding of Anglian’s position in addressing those issues. His note of the 3rd September ( copied to all ) would form the basis of the discussion.

John C explained his understanding of the sewerage system, which is generally correct. It was pointed out that the two 150mms pipe connect at the War Memorial into a single 225mms pipe. Agreed that the pressure in the pipe coming downhill from John Shepherd would be greater than the connection from Low Road due to gravity. John C was concerned that this could result in back pressure on the sewer in Low Road causing the manholes to “pop.”

There are two areas of “small surface water sewers ” (conduits)which ultimately discharge into the Beck. They have no connection to the foul sewerage. This fact had not been appreciated by SAFE members, who had understood that there was only one sewer.

Noted that because of the topography surface water runs down the four hills( Church Hill; Buckingham Hill; Back Street; Harleston Hill) to the Beck in Low Road. The soil in Fressingfield has low permeability.

Why do we have egress of sewage in Low Road?

Detailed investigations had been undertaken by Anglian and there is no ingress of rainwater water into the closed system. It is believed that the sewer is overloaded at times of heavy rainfall due to dwellings discharging their surface water directly to the sewer. When this happens the manholes lift.( five times in the last year). Historical connections of surface water directly to the foul sewer are not illegal and no resident can be forced to remove the connection. No one has any idea how many houses are connected. The problem cannot easily be solved as to increase the diameter of the pipe work would reduce flows in “normal” conditions to such a level as to increase smells. Should the manholes be sealed then there would be backflow of sewage into people’s properties. Anglian Water are not funded to invest in laying ” storm pipes” for a storm only events. Anglian stated that under normal conditions only 50% of the sewerage network was currently used. Which disagrees with the SAFE assessment. There was agreement that the egress of sewerage relates exclusively to periods of heavy rainfall and the Beck need not flood for this to occur. The problem is that when it does flood effluent enters the water course. The point was made that there is no deliverable solution and the egress of sewage may continue. John Kelsall highlighted the fact that with the potential for more houses to be connected to the sewer then more of the spare capacity would be utilised within the sewer making the “tipping point” for egress of sewage lower. ie. there would be less capacity for surface water than at present.

Bill Abatements

Unknown how many households have bill abatements for not discharging surface water to the sewer. This cannot therefore be utilised for modelling purposes.

New Properties with surface water connected to Sewer

New properties are not permitted to connect surface water to the sewer , but for developments under 10 houses Anglian Water are not involved. Vincent stated that the Building Regulations would prohibit connections of the surface water drainage to the sewer, but it was pointed out that it is impossible to say that this never happens. ( Please see foot note )

The Chapel Scheme(3872/16 )

Confirmed that this scheme discharges to a “surface Water Sewer” and ultimately to the Beck at an agreed attenuated rate.

The Three outstanding Applications

Hannah confirmed that none of the major Applications would discharge surface water into the used(foul) water sewer, but all three would ultimately be discharging surface water to the Beck. SAFE believe that this will increase the risk of more flooding.

Desk Top Modelling

Luke explained how the computer modelling worked. SAFE were concerned as to how robust such modelling is. Without knowing the amount of rain water entering the system it is impossible to know the starting point in terms of capacity. The models did not feed in exceptional storm events.

Revised Site Layouts

It was asked whether revised drainage strategies should be prepared if site layouts changed. For example, in the case of Stradbroke Road there is now more hard landscaping. Hannah reported that if the developer makes amendments to the onsite design, reducing permeability of the site, the developer would need to construct additional on site attenuation and still only discharge at the agreed rate. Concern was expressed by SAFE over this approach ” a paddock will not have the same run off rates as a car park.”

Issues around Flooding

Whilst accepting this area is not directly the responsibility of Anglian they do work with local Flood leads and model 1:30 year events using predictions from the Met Office. The model which Anglian Water uses is an industry wide standard model agreed by other agencies including the Environment Agency. Vincent reported that the Environment Agency were now using 1:1000 year event modelling.

It was noted that residents in Low Road had had difficulty in obtaining house insurance as the area has been designated as a flood zone.

SAFE is also concerned over the proposed attenuation restricting flows from the new developments to the water course. In times of heavy rainfall flooding to the new developments would be mitigated, but the flows, if excessive could overcome the systems and excess water flow to the Beck, causing off site flooding, contrary to NPPF.

Environmental Information Request

Grant apologised for the delay in response and for the fact that some of the information was incomplete and not totally accurate.

There was confusion in respect of data collection. Nigel confirmed that records for day to day incidents have been recorded since 2011. The Environment Agency(EA) has collected data since 1997, BUT for an incident to show on the EA records it has to meet certain criteria as to the level of pollution. For example whilst the incident in April 2018 was submitted it has not been placed on the EA list of incidents. Since 2011 Anglian Water have reported five incidents in Fressingfield to the EA. Anglian Water are dependent on Fressingfield residents to report incidents. Only 2 of the 4 incidents this year were reported to Anglian.

Elizabeth drew attention to an email from the EA stating that Anglian Water should take steps to reduce the amount of surface water going to the sewer and that they would be discussing the pollution issues in Fressingfield with Anglian . None of the Anglian representatives were aware of any approach from the EA and agreed to follow this up.

Anglian have no powers to require residents to remove their surface drainage connections from the foul sewer and do not have any power to object to a Planning Application nor can they prevent a connection to the foul sewer from taking place. Anglian’s legal position is understood. It must be recognised that there are risks in accepting a system that will be under greater strain at a time of heavy rainfall. Vincent recognised Anglian Water’s legal position in the consultation process and suggested that he write to Hannah with specific questions on which he required answers. Hannah confirmed that Anglian would be in a position to respond to the specific questions relating to the Planning Applications.

Key Messages

-It is highly likely that the egress of sewage is due to overload of the system at times of heavy rainfall because of historical connections of surface water to the foul sewer.

– There is NO obvious deliverable solution, therefore egress of sewage in Low Road will continue in the future, regardless as to whether there is further development.

-Site topography and the fact that the Post Mill , Stradbroke Road, and John Shepherd Road all ultimately discharge surface water to the Beck which must increase the risk of flooding in Low Road.

It is important that the relevant authorities maintain the Beck to keep it clear.

– There has been serious under reporting of incidents by residents. Anglian Water assessment can only take account of the known issues.

-More houses will increase the volume of effluent in the sewer decreasing the spare capacity for rain water thereby increasing the risk of sewage egress in Low Road. This is contrary to the NPPF and Anglian’s policy of not causing disadvantage to existing customers.

Anglian will respond to written questions by the Principal Planning Officer on this issue.

PEC 25/10/2018

Foot Note

Anglian Water Amendment

New Properties with surface Water Connected to the Sewer

New properties are only permitted to connect surface water to the foul sewer network if all other methods of surface water discharge have proven to be non-viable, but for developments under 10 houses Anglian Water do not normally make comment unless requested to do so by a customer or an LPA case officer. Vincent stated that the Building Regulations would prohibit connection of the surface water drainage to the sewer, but it was pointed out that it is impossible to say that this never happens.


Previous Anglian Water Meeting

Meeting with Anglian Water – Hannah Wilson visited village for question and answer session. Report can be found here.

Also provided is a document from Anglian Water about how they fit into the planning process in Mid Suffolk, and points raised about the large developments. See more here.


Sewerage Overflows

Sewage overflow occurred on 27th Dec and again on 12th March, 31st March and 3rd April. This latter episode was featured on Look East on the 3rd April. Water was flowing a foot high from the sewer cover and at this time at least 3 sewer covers lifted. The foul water was heavily contaminated with waste food, toilet paper and human waste. This happened despite recent cleaning of the sewerage and CCTV showing satisfactory flow. Anglian Water staff visited twice during the overflow and reported that the pump was working satisfactorily. Egress form the manholes continued throughout the day. Associated flooding meant that foul water was distributed down a large part of Low Road and into some gardens. The following day a team from Anglian Water came to clear up the mess.

Although this is a long standing problem ( see lobby paper – “Lobby Paper – Fressingfield Sewerage“) this was the worst episode seen by residents in recent years. The extensive contamination is both a health hazard and unsavoury.


Saintfield Problems Lead To Building Ban.

Saintfield, NI has had similar problems to Fressingfield namely egress of foul sewerage at times of heavy rainfall. The only difference is that they seemingly have a potential solution by increasing the capacity of the sewer. We have been told by Anglian Water at a recent meeting attended by our MSDC Councillor that in Fressingfield there is no solution. A larger pipe would decrease flows at normal times and would result in increasingly bad aromas and a failure to self clean.

New housing developments have been banned in a County Down village after its sewage system reached capacity.

In recent years Saintfield has experienced a building boom and its population has nearly doubled in the past two decades.

The strain on the sewage system has led to raw sewage flowing from manhole covers on the Old Grand Jury Road after periods of heavy rain.

Northern Ireland Water has now said no more homes will be built.

Resident David Forbes said: “The sewers are lifting. There are children walking through this on their way to school. “I don’t know what could be on their shoes when they get to school or get home. Manhole covers are lifting. It is just madness.”

The full news story can be viewed on the BBC Website below:

BBC News Saintfield sewage problems lead to building ban


Letter to MSDC – Flood Risk

A letter has been sent to the Planners at MSDC regarding Flood Risk and Drainage – the document in full can found on both out Lobbying page and Other Important Documents, as well as following the link below:

Letter relating to Flood Risk


3 – Highways & Road Safety

New Highways Report – Dated 2nd November

A new Report has been publish by SCC Highways Regarding the Applications 1449/17 (Land Off Stradbroke Road), 1648/17 (Land At Post Mill Lane) and 1432/17 (Land Off John Shepherd Road). This three page report details pedestrian safety and traffic issues within the Village, following the July 2018 NPPF Draft.

The conclusion to the report is below, along with a link to the full report.

Conclusion

There are hazards to non-motorised users travelling on New Street or through Jubilee Corner. The layout of the village means that this is the desirable route to reach many services. The proposed developments will result in increased vehicle and pedestrian movements through this core area.

While it is appreciated that all three developers have contributed in finding ways to improve road safety the constraints imposed by the existing highway network severely restrict the practical options. The measures proposed are the best solution available within the existing constrains they fall short of making the highway safe for pedestrians.

While it is noted the few crashes have been recorded in this part of Fressingfield recent planning appeals have determined that weight should be given to observed conflicts between pedestrians and vehicles. It is the Highway Authority’s opinion that this is the case on New Street and Jubilee Corner if further development were approved which increased pedestrian and / or vehicle movement through the core of the village without the provision of safe, practical alternatives.

It is the Highway Authorities opinion that further traffic passing along New Street and / or through Jubilee Corner would result in an unacceptable impact on highway safety particularly for vulnerable pedestrians.

For this reason, the Highways Authority recommends that permission is refused for these applications.

The full report can be read by clicking the following link:

SCC Highways NPPF Revised Report.


Current Highways Issues

Fressingfield Cumulative Impact – Suffolk County Council

SAFE Responses:

1st SAFE response to SCC Highways Paper dated 31st July 2018

Introduction

Road safety in Fressingfield has consistently been of major concern to residents of Fressingfield with a potential for 254 extra houses in the village( the central area of the village currently has around 400 homes). SAFE has produced a number of lobby papers on highways/ road safety and the key issues have been fully explored in these papers. It is not, therefore, proposed to revisit all of the issues in detail. All of the relevant lobby papers are listed at the end of this paper and can be found on the SAFE web site.

We understand that in response to the concerns raised over road safety the “mitigation” measures proposed by the Developer have been considered further by SCC Highways and their opinion is laid out in their letter of 31st July 2018. This paper is the SAFE response to the SCC letter.

Comment on the SCC Paper

We are very pleased that SCC recognise that the there is a need to look at the cumulative impact of all five Applications in Fressingfield, BUT there is no mention of additional windfall houses, nor the high probability of an additional 110 homes in Weybread. As Weybread people will be using the Fressingfield shop, school and surgery there are significant implications for additional traffic flows into Fressingfield as well as increased parking on Fressingfield roads. Additionally there will be no increase on the very limited employment opportunities in Fressingfield, therefore most of the new residents will travel out of the village by car to work.

Policy and Guidance

Whilst the current Local Plan is rather old. It is our understanding that in Law policies
relating to transport are not out of date and should be adhered to, together with the new NPPF. Policies such as T10 are therefore relevant. The SCC paper clearly identifies the requirements under the NPPF, but fails to explore the potential for applying the policy statements to Fressingfield.

– sustainable transport not discussed. There is one bus a week , no cycle paths and private transport is the only feasible option.

– there is absolutely no discussion of the needs of disabled people. The Fressingfield population has a high proportion of elderly and a high number of wheel chair and mobility scooter users.

-there is no discussion on the safety of children. Planning permission has already been granted for a chapel and 18 houses at the end of the School Lane cul de sac. School Lane will become a through road with increased speeds and traffic. The proposed Stradbroke Road development opposite School Lane will significantly increase traffic and congestion.

– no significant discussion of the conflict between pedestrians and traffic, ( particularly in New Street) although it is stated at the conclusion “that this causes the Highway Authority some concern”

– the proposed pedestrian exit from the Post Mill development is not discussed. This path exits on a blind bend. ( although we suspect the response to the latter part of question 7 relates to this and is misnamed)

MSDC Core Strategy

The previously accepted ” target ” for new homes in Fressingfield as a primary village was 50 houses over a 10 year period. It is strange that this previously accepted formula is not stated . Under the formula in ” Right Homes Right Places” a very similar figure is arrived at.

Road Safety

The transport assessment undertaken by the developer was seriously flawed.

-it was undertaken the day after one of the main roads in the village had been closed for planned road works ( which were well publicised). Drivers would still be taking alternative routes as the completion date was not advertised.

– was not a busy time such as harvest

– did not include pedestrian trip rates

– concentrated heavily on junction capacity

We are concerned over the major overemphasis on historical accident data. There are lot of minor accidents in Fressingfield which are unreported. With a potential increase of 57% growth in the local population all using minor roads, (in many instances without pavements) we find it difficult for Highways to come to the conclusion that future safety can be extrapolated from these data. More cars will result in more accidents and there is the possibility that these minor accidents may be more major in future.

We do not agree that the proposed mitigation measures will have any material impact on overall road safety. There does not appear to be any objective evidence to support the SCC statement that ” the proposed mitigation and additional traffic flows are likely to decrease speeds, hence decrease the degree of harm.”

The proposed Coloured Road Surface and additional signage are not enthusiastically supported by SCC and we agree that it will make no difference as traffic slows at Jubilee Corner anyway because of the bend and the junction.

We believe that the response to question 8 relates to proposed pavement widening at Jubilee Corner. We have never seen a dimensioned drawing. Tractors with loads and articulated lorries already have difficulty negotiating this bend so it is hard to see how this proposal can be achieved in practical terms as the current road width will be reduced. Will the new dimensions conform with the Manual for Streets?

SCC objected to the Red House Farm Application on the grounds of pedestrian safety. We cannot understand the logic of Highways objecting to Red House while a year later not objecting to the Post Mill extension. ( both exit onto New street and are physically very close.)

Comment on the Summary

We would argue that the base line traffic data is low because the traffic study was flawed. An additional 375 cars in Fressingfield alone would seem significant! We do not agree that there are a “small ” number of HGVs. There are a significant number and also a large number of home shopping delivery vehicles. These will increase with more houses. SCC recognise the lack of footpaths and sustainable transport and see this as ” moderate to a high degree of significance in Planning terms” we would argument that the proposed increases would be ” severe” Likewise general road safety is deemed to be ” at the higher level of significance but not severe.”

There is a real issue as to the interpretation as to what constitutes a ” severe Risk” . SCC (Planning Section, Strategic, Development, Resource Management) confirmed verbally that there is no nationally agreed definition, the decision is dependent on local circumstances and is not is uniquely linked to historical accident rates. We are concerned that the SCC paper has adopted a very narrow focus in this respect.

We are pleased that the report recognises there are serious issues, but are disappointed over the overreliance on poor traffic data and historical accidents. We believe that a 57% increase in population, (taking no account of Weybread) will have a severe impact and is unsustainable in road safety terms.

For Further detailed information on all of the points discussed above please refer to the following Lobby Papers to be found on the SAFE web site:- fressingfieldhousing.org
“Fressingfield Developments- Highways and Road Safety Issues.” “Traffic in Fressingfield”
“Highways Historic Objections” ” Enhanced Child Safety Dangers.” ” Post Mill and Traffic ”
“Traffic Accidents in Fressingfield” “Traffic Issues.”
” John Shepherd & Traffic” “SCC Highways Paper Resopnse”

John and Pam Castro on behalf of SAFE 7th September 2018

Dawn Cavilla, John Kelsall, Abi Maydon, Trevor Orchard, Michael Miles, Elizabeth Manero


2nd Safe Response to Suffolk County Council Highways 

Background – This document has been produced in response to concerns raised by residents and queries from MSDC’s Planning Officer. Unfortunately, it fails to address many of the specific concerns raised on the inadequacy of the documentation provided by developers and makes a number of assertions without any evidence to support them.

The key point is whether the proposed developments are sustainable. Our contention is that they are not and the response from SCC contains nothing to refute this contention.

The errors and omissions are detailed below.

Errors and Omissions

Current Local Policy – The 4th paragraph of the Policy and Guidance section states that the Local Plan is out of date so greater weight is being given to the NPPF. This is a misstatement of the law. The Supreme Court concluded in June 20171 that it is only ‘policies for the supply of housing’ which are deemed out of date if a planning authority has not met its five year housing targets. The revised NPPF introduces a new way of calculating housing supply and need but the interpretation of when existing policies are out of date stands. This means that all MSDC’s existing policy on matters that do not relate to housing, including transport, landscape and heritage, stand, including those specified in our original document of 13.02.17.

Ignoring NPPF requirements – The SCC sets out the need to consider legal requirements to prioritise pedestrians, minimise conflict between cyclists or pedestrians , and recognise the needs of disabled people as well as locate development where it is sustainable – and then proceeds to ignore these issues.

Ignoring non-compliance of the developer documents with national guidance – our original document recited a number of respects in which the Cumulative Traffic Assessment from Create Consulting failed to comply with government guidance, in particular by failing to measure pedestrian trip rates. The SCC response ignores this lack of a baseline and fails to attempt to extrapolate how pedestrian and cyclist traffic might increase as a result of growth in the population of the village by 57%.

Road safety – Ignoring the impact of the footpath emerging onto New Street – clear photographic evidence was supplied of the poor visibility of the footpath onto New Street. The whole issue of this footpath is ignored in the document, notwithstanding that it is onto the most hazardous street in the village which is narrow, largely without footways and is within the conservation area, reducing the possibility of mitigation measures.,

As in the CTA, the assertion is made that as there has not been a heavy accident record in the village over the last 10 years, this will not change as a result of these developments. In the absence of a baseline of pedestrian trip rates as guidance requires, and an extrapolation of the impact on such trip rates of developments will which increase the population of the village by 57%, the conclusion that the impact will not be severe is not supported by fact.

Conclusion – This document

  • does not cite any evidence for its conclusion that the cumulative impact will not be severe
  • ignores road safety in New Street
  • ignores the needs of disabled people and fails to prioritise pedestrians
  • makes assertions on road safety without evidence

It is however encouraging to see that SCC considers that there are factors which inhibit sustainability are of ‘moderate to high significance’. It would be useful if this conclusion could be included in the overall recommendation, as there seems to be an irrational to conclude that the cumulative impact is not severe whilst also concluding that it is not sustainable.

Elizabeth Manero SAFE

SAFE Members – John & Pam Castro; Dawn Cavilla; John Kelsall; Abi Maydon; Michael Miles; Trevor Orchard

05.09.18


Mid Suffolk has now published a response by the developers to the Highways concerns. The full report can be seen on this web site under “Other Important Documents”

Suffolk Highways initially raised ” holding objections” to the developments on the grounds of road safety. which they have now withdrawn. The two developments already approved ( the Chapel scheme and Red House Farm) together with the housing developments proposed ( a total of 263 new houses) will result in a 57% increase of personal cars in the village. Suffolk County Council Highways Department have written a report stating that the impact of all these extra cars will not represent a “severe risk to safety” and as such not longer object to the developments. They have received “mitigation measures” from the developer for the John Shepherd site and Stradbroke Road, but have not received anything for Post Mill, although the red House Farm scheme and Post Mill proposal will result in an additional 76 cars exiting onto New Street.

What the Developer Proposes – we do not have much detail on this as only a drawing has been provide which is “draft”

  1. Resurfacing with a coloured material along the B1116 at Jubilee Corner and extending into New Street and Stradbroke Road.
  2. A road hump in New Street just after the Jubilee Junction.
  3. A block work strip at the exit of the footpath in New Street running from Back Street and a proposed ” pedestrian strip.”
  4. Minor adjustments to the Jubilee Corner junction.
  5. Increase the width of the existing footpath at Jubilee Corner. (To do this land will need to be taken from the triangle where the village sign is located)
  6. Improvements to the bus stop

The Report does not address:-

The large number of accidents in the village, the lack of footpaths , particularly in New Street . The dangers at other junctions, speeding in Harleston Hill. There is no mention of cycle routes or the needs of the disabled.

The SAFE response can be found on this web site (Highways Paper)


Recent Photographs

IMG_20180612_104330 (4)

This picture above was taken on 12 June 2018 and again shows the sort of problems which can occur in New Street, which caused serious delays.

Large Agricultural Vehicle Filling RoadThis photograph, taken recently, in mid April,  shows the continuing problems in New Street and this was not at harvest time. Roads in Fressingfield are unable to take more vehicles.

Another, pictured in early May:

Lorry2Web


Planning incentives ‘lead to housing estates centred on car use’

Transport for New Homes today published a new report looking into how homes are being developed that rely on cars due to poor access to both Public Transport and Pedestrian Infrastructure. Below is the start of the news article referencing this from The Guardian:

Planning incentives are encouraging housing developments that push residents towards “car-based living” by failing to include public transport or pedestrian infrastructure, a report has claimed.

Poor regulations allow developers to buy up cheap, almost rural locations for new housing stock, which councils are required to assess for “deliverability” while meeting national housebuilding targets and before making transport assessments, according to the report by the campaign group Transport for New Homes (TNH).

“Building new homes in fields so remote from good public transport networks, major employment hubs and services, means that sustainable transport options are perceived as limited from the start and too difficult,” the report said.

The full report from Transport for New Homes can be found by clicking the link below:

Transport for New Homes Paper (PDF)


4 – Heritage

This aspect of our of our objections has been highlighted by Historic England. Click here to see their letter, which also appears under “Other Important Documents.

The Suffolk Preservation Society has also made strong representations previously. Fressingfield has a high number of listed buildings in an historic setting and the developments will impact negatively on this.

The Implications for Fressingfield’s heritage by Applications 1449/17 (Land off Stradbroke Lane); 1648/17 (Land at Post Mill Lane) and 1432/17 Land off John Shepherd Road.

The Supreme Court Judges – in the landmark case of Hopkins Homes v Suffolk Coastal – found that planning officers and councils should be mindful of guidance in local plans and the NPPF as a whole and not isolate advice given therein. There is a common theme in both of these planning guidance documents that protecting landscape and heritage is a legal requirement and part of the sustainability test to be considered. Also given that the definition in the NPPF of sustainability is quality of life and it should be remembered that people choose to live and holiday here because of it’s rural qualities and for the quality of life they offer.

In both the NPPF and the Babergh/Mid Suffolk local plan, there are repeated legislation or guidance to protect heritage and to maintain it from being adversely affected in terms of character and setting.

Fressingfield is a national rarity having 58 listed buildings and it is their setting and that of the village as a whole which will be ruined for future generations if these inappropriate and large scale developments are granted in addition to the 52 just recently given permission. Fressingfield is a small rural village without the necessary infrastructure and sustainability to absorb large developments.

Mid Suffolk’s Conservation Area Appraisal described Fressingfield as being somewhere with ‘quality of place’, and it is indeed not just a local asset for it’s picturesque tranquillity and beauty, but a national asset bringing many tourists to the area.

There are many ancient manors and hall houses within the village including examples of early timber-framed medieval houses, and the many other listed buildings, farmhouses and cottages with their architecture in the local Suffolk vernacular style.

If these large and inappropriate developments are granted, we will loose the rural character and heritage setting of this rare medieval village. The Stradbroke Road development as just one example, will mean that this access to the village will be transformed from open countryside to a surburban housing estate of 85 homes.

As the local plan (2.2.7) states, “The District Planning authority looks to safeguard and enhance these listed buildings and their settings using statutory powers.”

However, the topography of the village means that the large developments proposed for John Shepherd Road and Post Mill are on the brow of a hill and will massively impact on the rural aspect of the whole village as viewed from Harleston Hill, the main access road into Fressingfield. This will be especially marked in winter months when the trees are not in leaf.

Policy HB1 clearly denotes the Council’s “priority on protecting the character and appearance of all buildings of historic interest. Particular attention will be given to protecting the settings of listed buildings.”

It is the same with Churches, (2.2.9) Suffolk’s many outstanding churches “form an important part of the landscape of the setting of villages” and must be preserved in accordance with this principle. The important Grade I listed Church of Saint Peter and Paul here which is famous for it’s fine Decorated and Perpendicular architecture and magnificent hammer – beam roof will be impacted negatively and significantly by the John Shepherd and Post Mill development.

The other Grade I listed building is a national treasure, as one of the only surviving raised aisle open hall house dating from circa 1330-1340. (C A Hewitt, Aisled Timber Halls and Related Buildings, 1976). It is perhaps the most “ostentatious “ example of a raised-aisled hall roof with its crown-post and triple tie beams. (Dymond, D & Martin, E, An Historical Atlas of Suffolk). It is a truly outstanding example of fourteenth century vernacular carpentry. (Hewitt, English Historic Carpentry, 1980).

As English Heritage commented on the John Shepherd application with real concern:

“The proposed development to the west of Church Farm Stable and barn would introduce modern housing beyond the established historic pattern of development and separating the historic farmstead from the fields at this point. This would result in harm to the historic significance of the Former Stables and Barn by diminishing the quality of their setting that contributes to their significance.

The National Planning Policy Framework (NPPF) identifies protection and enhancement of the historic environment as an important element of sustainable development and establishes a presumption in favour of sustainable development in the planning system (paragraphs 6, 7 and 14). Paragraph 128 of the NPPF requires applicants to describe the significance of heritage assets affected by proposed development and the contribution their setting might make to that significance.”

Policy HB8 outlines the statutory duty of the council to safeguard the character of conservation areas, protecting their character. Policy HB10 states that “The District Planning Authority will refuse advertisments that detract from the character or appearance of their surroundings.”

Our heritage includes Fressingfield’s open and rural character and it’s connection to the fields that surround it. By allowing over development, the council will go against policy H7 which protects “The existing character and appearance of the countryside” and also that of SB3 which outlines the importance of retaining visually important open spaces.

Policy H8 states that proposals should “not detract from the character and appearance of its surroundings and landscape setting.”

Policy CL1 sets out the same advice, “The landscape quality and character of the countryside will be protected for its own sake..development in the countryside should have the minimum adverse affect and should seek to positiveley contribute to its diverse character.”

The Core Strategy Focused Review 2012 (3.2) describes clearly what sustainable development (a legal requirement within the new NPPF) entails and this includes enabling people:

“To enjoy a better quality of life, without compromising the quality of life of future generations.”

This document also outlines the importance of safeguarding the environmental and landscape sensitivity of the district and maintaining its value as a heritage and tourist asset.

Core Strategy 2008 promises “A better heritage for future generations”, to safeguard the distinctive and attractive areas of Suffolk. The Objectives SO1 and SO4 of this strategy clearly set out to “protect, enhance and restore landscape..to protect, manage, enhance and restore the historic heritage/environment and the unique character” of local towns and villages, by ensuring that new developments are appropriate in terms of scale and location in the context of settlement form and character.”
The NPPF is absolutely clear that “Protecting and enhancing the historic environment is an important component of the National Planning Policy Framework’s drive to achieve sustainable development (as defined in paragraphs 6-10. The appropriate conservation of heritage assets forms one of the ‘Core Planning Principles’ (paragraph 17 bullet 10) that underpin the planning system.

The conservation of heritage assets in a manner appropriate to their significance is a core planning principle. Heritage assets are an irreplaceable resource and effective conservation delivers wider social, cultural, economic and environmental benefits.”

None of the proposed developments will in any way enhance the environment in Fressingfield, quite the reverse. The proposals run contrary to all of the current guidelines relating to the protection of important heritage assets.

Abi Maydon on behalf of SAFE: 23 October 2018
SAFE Members:
John & Pam Castro
Dawn Cavilla
John Kelsall
Elizabeth Manero
Michael Miles
Trevor Orchard


5 – Deliverability and Viability

When Planning Approval is given, MSDC would expect houses to be deliverable to increase the housing stock and meet the targets for new homes.

Fressingfield is Primary/Hinterland village with limited facilities, poor infrastructure and not near a railway station or major road network.

Further major development is not sustainable and non – viable as evidenced by two sites, with Approval being unsold for over a year.


Access to the Web

Currently a great deal of information is being uploaded onto the MSDC Planning pages regarding the “Big Three” applications. In order to see them, click on the links below, then click on the Documents tab:

Application 1449/17 – Land Off Stradbroke Road

Application 1648/17 – Land At Post Mill Lane

Application 1432/17 – Land Off John Shepherd Road

On this website, anything in red text is a link to the corresponding document/pertinent  web page. All will open in a new tab/window.