SAFE – Supporters Against Fressingfield Expansion

Breaking News

A letter from Dr Poulter MP about ‘ Planning for the Future’

A number of residents who have written to Dr.Poulter have received an identical response. Councillors at MSDC received a very similar response.

I hope my email finds you well in these challenging times.

I am writing to you about the Planning for the Future White Paper which suggests changes to the ways that Mid-Suffolk and other councils would deal with the planning and house building process. Having taken the time to study it, I have concerns about a number of the proposals contained within the white paper. In particular I am concerned about using a national planning algorithm to decide our future house building needs in Suffolk.

Fortunately, the proposals in the white paper are a long way from becoming law and there is plenty of time to change them, so I would be grateful for your views and thoughts.

I attach a brief synopsis of the Planning for the Future White Paper which my office team has put together and I hope you find this helpful.

As you will be aware, I have a successful track record of fighting inappropriate housing overdevelopment, and recently stopped plans for 50,000 new houses being built to the north of Ipswich In order to fund a northern bypass. So, please be assured that I shall continue to do all that I can to protect our rural communities from inappropriate housing overdevelopment.

I look forward to hearing from you.

With best wishes,

Dan

 Planning for the Future – White Paper Briefing (Click here to view as PDF)

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SAFE’s Response to Dr.Poulter’s letter:

Dear Dr. Poulter,

I have now had opportunity to look in more detail the synopsis of the White paper produced by your office.

I am pleased that you are giving an undertaking to protect rural communities from Inappropriate housing development, and are keen to protect the greenbelt. Whilst the ” Green Belt ” relates exclusively to London there are significant ANOBs in your constituency which need protection.  The problem is that the White Paper opens the door for building on ” Protected” areas affording them less protection than  under the current legislation. You are silent as to how these objectives  can be achieved should the recommendations of the White Paper be adopted. What elements of the White Paper do you propose to challenge? I have great difficulty in assessing where you stand on the White Paper . You have acknowledged that the White Paper is a long way from becoming Law. I would like  to know how you actively will be involved in bringing about amendments.

I would agree with you over the problems with algorithms which is addressed in detail  in the SAFE response to the White Paper which I again attach. You specifically suggest that brownfield sites in Ipswich should be prioritised for development, yet the table in para 5 of your synopsis clearly shows the lowest uplift in house numbers both in absolute and in percentage terms to be Ipswich putting greater pressure on rural areas.

You have committed to community involvement, but, if implemented, the White Paper will completely undermine the democratic process.  Local Authorities and communities will be powerless to prevent developments once the ” zoning” has been undertaken. This is particularly so for ” growth ” areas.  There seems little point in being able to access digital planning documents  if one has NO opportunity to express an opinion or raise an objection. Community involvement is effectively abolished. Your synopsis makes no reference to Neighbourhood Development Plans. They have been seriously downgraded in the White Paper to a role in influencing design only. I attach again the 10 key points from SAFE which focuses particularly on  these issues.

You did not touch on the issue of affordable housing.  ALL experts/authorities in this field have reported that raising the site threshold to 50 houses before any affordable houses have to be  included will REDUCE the number of affordable homes  being built compared to those currently. As a main driver of the White Paper is to boost home ownership this seems somewhat counterintuitive.

Whilst I accept that you paper is a synopsis it does stray into other areas such as  incorporating  some criticisms of the White Paper  and the views of the “Policy Exchange”. It is therefore reasonable to ask  why serious omissions from the White Paper were not raised by yourself. Over 1 million homes currently have Planning Approval, which has not been implemented. Over 250,000 houses are currently empty in England. Land banking as a means of  controlling  the housing market is a key issue being completely ignored by central Government. A tax on land not developed over a certain period would help focus attention. The Planning System is blamed exclusively within the White Paper for problems in housing delivery, but 9 out of 10 Applications are  approved and the time taken to consider applications compares favourably with other European countries.

I would again urge you to read the attached SAFE response to the White Paper, written by some of your constituency members. These papers have been well received by local politicians.

In summary therefore, I would like to know your position on the White Paper and what challenges, if any, you intend to make ?

Bob Seeley  did assure me that he would be doing his best to influence his colleagues so I hope that he has opportunity to influence you!

Yours sincerely,

SAFE


Sewage Egress in Fressingfield – Again

On Friday 25 September 2020 sewage egress occurred from the manholes in Low/Cratfield Road. It was first noted at around 10.00 hours and continued, at least, until t 22.15 hrs ( over 12 hours) after which it was too dark to observe . Photographic evidence is below. Initially, foul smelling liquid was observed, later toilet paper was seen flowing across the road. Anglian Water attended at approximately 19.00 hours and reported that the pumping station was working satisfactorily and at full capacity. Four covers were leaking  and draining directly into the Beck. Throughout the day the Beck was approximately 50%.full .

The Environment Agency as well as Anglian Water were informed.

During a period of just over 2 years there have been 12 episodes of sewage egress and prior to that many others that went unrecorded. The first documentation was in 1985, in letters that we have between the local MP, Anglian Water and Mid Suffolk.

Many of the episodes in the last 2 years have been photographed and appear on this web site. On the number of these occasions the CEO of Anglian Water was informed directly and on 8 occasions the Environment Agency was informed and the following incident numbers recorded at the Environment Agency.

2 April 18- 1602704

1 October 19 -1743034

6 October 19 -1744172 1

14 November 19 1754353

27 November 19 -1757626

20 December 19- 1763180

7 August 20 – 1834809

25 September 20 – 1851349

Anglian Water will also have a record of the clean up teams having to visit as a result of the incidents.

There is no doubt that these incidents present a health hazard, as documented in the correspondence with the Director of Public Health Dr Abdul Razaq dated 11 May 2018 ( see earlier on this web site) and subsequently Dr. P Badrinath in November 2019.


Interesting Fact

The land in Britain taken up by buildings and roads has grown by 11% since 2010. 8.3% of the land mass is now built on, up from 7.7% . ( The Times January 2020. )


SAFE Web updates.

There are so  many  things happening at present it would be worth your while reading several pages of Breaking news to keep right up to date.


Planning For the Future

On 6th August 2020 the Government Issued its White Paper recommending major changes to the whole planning system click here to view. The document is open for public consultation until Thursday 29th October. This document will then be amended in the light of comments received before being presented to Parliament. We will keep you informed of developments, but would encourage anyone with an interest in these matters to participate in the Consultation.

Click here to view the Planning For The Future White Paper online


“Planning for the future” – 10 Key Points

To read this as a PDF online, click here

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SAFE comments on “Planning for the future”

Introduction 

SAFE ( Supporters Against Fressingfield Expansion) is an independent pressure group concerned with over development in Fressingfield. It maintains a web site    fressingfieldhousing.org   which gives detailed information about the group’s activities.

We are writing this because ticking the  consultation proforma does not adequately address the important issues raised by this White Paper. The White Paper is poorly written,  contradictory in major areas and is extremely light on any detail. We have  no confidence that the proposed procedures will  reduce planning risk and allow fast tracked developments and  most importantly does not present a robust argument around the deliverability of more affordable homes.

When one looks at the background of those sitting upon the Advisory Group the skewed outcome is not surprising. There is a marked bias towards developer input. Whilst advisory groups need to be small there should have been a broader spectrum of representation.. A representative from Local  Government, someone such as Lord Kerslake who understands  affordable housing, a representative from the Town  and Country Planning Association and an individual with an understanding of rural issues. This would have provided a more balanced approach.

The document acknowledges that  last year achieved more house completions in year than any other in the last 30 years, yet this document proposes complete abolition of the Planning system without retaining those elements which have been successful.  The overwhelming demand for deregulation  is not matched  with supporting data. This will result in the stated aims of the White Paper not being achieved. The Planning system is cumbersome and there is scope for significant streamlining, but to  remove the whole of the Planning function and assessment of individual Applications is pure vandalism. The current Planning system is currently  delivering increasing numbers of new homes. 90% of all current Planning Applications are approved. Surely what is good should be built on? The Planning system has not been frozen in time since 1947. It has undergone significant modification. Some of the recent changes such as  the relaxation on user classes and Permitted Development Rights may not always be welcome , but change can be brought about in a considered and thoughtful organic way thinking through carefully the laws of unintended consequences!

It is very interesting that in the press and in professional journals the only supporters of the White Paper proposals are the developers, their advisors and house builders. Throughout the document there is a theme that the LPAs are the culprits in obstructing house building. This is just not true. Unfortunately house builders / developers are viewed as the key to bringing the country out of recession!.

Omissions  

Affordable homes

The options for the introduction of the revised Community levy are  complex and really fail  to explain how more affordable houses will increase above the current level. Certainly raising the threshold on when an affordable homes have to  be included in an Application could reduce the numbers being built. The Chair of the Peabody Trust concurs with this view. He is concerned that, if implemented, fewer not more homes will be built. There are currently plenty of houses for sale across the country in all settings, but people cannot afford them. 

With buyers of first homes expected to take priority over shared ownership buyers there could well be the unintended consequence that those on the lowest incomes are unable to buy. For many a part ownership scheme is the only economic option. 

Permitting  off site compensatory affordable housing  will not help in achieving housing mix and could well create ghettos  and we agree with the RIBA President that this policy could lead to the slums of  the future. 

There is absolute silence on delivering houses for rent.  This is a very important sector for those unable to buy.

The Government intends to target  ” unaffordable” areas of the country by flooding the market to bring down prices in that locality. However, house builders may well respond  in a  similar way to OPEC by making sure that profit margins are protected  .Theoretically the Government is adopting a reasonable approach by applying  the Law of Supply and  Demand. BUT nowhere in the document has the whole question of” land banking” been addressed nor has the fact that there are currently  over 1 million approved Applications which are not being progressed.  In 2018 an analysis of the financial reports of the 10 top house builders revealed  that  they had 632,785 building plots on their books, of which more than half had Planning permission. In that year they achieved only 79,704 completions. At that time they had around 8 years land supply!! It is far too easy to refresh an Application which is time expired.  It is in the  house builders/ developers interests to maintain house price levels and not to cooperate to depress them in order to retain their profit margins. Positive action to reduce land banking is needed and also changes on renewing Applications should have been considered by the Government in this White Paper. One option would be to allow only one renewal of an Application.  Changes in the regulations in these areas  would have a massive positive impact on housing delivery. House builders /developers  are not a branch of the welfare state indulging in pro bono activities. They exist to make money and produce dividends for shareholders.

Infrastructure  Costs

There is silence on how improvements in  local  infrastructure, such as primary care and schools, is to be funded on projects that fall below the tipping point of the proposed new  infrastructure levy.

The last Conservative Manifesto stated it “would put infrastructure first. We will amend the Planning rules so that infrastructure; roads, schools, GP surgeries come before people move into new homes.”  There is no evidence of this intent in the White Paper. 

Homes for Older people

By 2035 over one in four people will be over 65. There should have been some recognition that this will create demand for certain types of housing if older people are to remain in communities as long as possible.

ONS data

The argument currently raging over the reliability of the current ONS population projections is completely ignored . There is good evidence that current population assessments on which housing numbers are based are overstated. There should , at least be some recognition of this debate.

The recent row over  housing need assessment in Coventry, where all of the foreign students attending local colleges were assumed to take up permanent residence  after completion of their studies, has resulted  in a serious  overestimate of  the  local housing need in this area. This demonstrates the requirement  to have robust population figures adjusted by local knowledge .

Public Engagement

The proposals stress the need to move away from” signs on lamp posts” and achieve public engagement through interactive digitalised map based plans.  There are people who are not computer literate and they cannot participate in this mode of engagement. Some elderly and infirm could not participate and would be disenfranchised. The recent furore over disadvantaged children being unable to undertake  home schooling is an example of selectivity when it comes to internet access. 

 Local knowledge would be useful in advising on local need and sustainability, but these views are not being sought. If local views are to be truly important  then  the Neighbourhood Development Plan (NDP ) should have a great deal of weight attached to it as it has been formulated by the local population. The Local Plan should therefore take into account an adopted NDP. What weight will be given to an adopted and up to date  NDP is not clear in the White Paper.

Whilst the White Paper purports to increase local democracy the reverse is true. The only input the public will have is into digital mapping at local plan stage and some say into local design codes. Professors Wilson and Vigar from Newcastle  and Professor Tewdwn-Jones from UCL London state,  “Rather than see people as objectors, we should value their vital knowledge and experiences that can improve development proposals.”

The proposed public engagement is nonsensical . Is any community voluntarily  going to sign up to being a “growth area?”  If so, they  then have all Applications  that pass the ” beauty test ” having automatic Outline Approval.

Other issues 

The preamble.

The preamble to the White Paper documentation is extremely selective and misuses data. For example it says that houses in England are twice as expensive as in Germany, Italy and the Netherlands. This is just untrue. The average price of houses in the Netherlands is significantly higher than the average in England and comparisons with Italy and Germany are  meaningless due to a much higher proportion of people living in flats and far less home ownership in both of these countries. The White Paper blames the Planning system for the high cost in England. It is more likely, in part, to be the result of the very high land costs in England; it being the most densely populated European Country after Holland. The extensive land banking by Developers is also a significant factor.

Sustainability 

Without specific scrutiny and local knowledge of individual sites it is impossible to understand how Applications are deemed to be ” sustainable.” The broad intentions  in the revised Local Plans may well be very difficult to apply in individual circumstances without the detailed knowledge of those sites. What exactly is a ” single statutory sustainable development test” ? How  can be applied nationally as sustainability is a local issue dependent on local circumstances? 

The Beauty Premium

This is a seriously difficult issue .How, in practical terms can there be ” fast track for beauty?” Everyone wants more aesthetically pleasing developments . At present we see repeats of standard designs the across the country. This is because standardisation does significantly reduce costs by bulk purchasing , reduced build times and unimaginative repeat design activity. While the document’s emphasis  is to enhance the environment it is unfortunate that the local population will only contribute towards local design codes. Beauty is in the beholder! We personally find the scheme photographed  on page 4 as very out of keeping with the setting, but it won awards and others probably think  aesthetically pleasing.  To build in the image of Poundberry will be very expensive. Unique building increases costs and make buildings less affordable. There is a major paradox here: the Government want  volume, but at the same time beauty ! The White paper fails to explain how this can be achieved.

“Beauty” is not the only factor  in creating flourishing communities where children can excel. For example the educational achievement of many pupils in the East End of London far exceed  the children in the East Coast coastal resorts. Issues are multi factorial and the  over emphasis on ” beauty ” in the Planning process is misleading.

Public participation is limited to input into formulation of Local Plans and into local design guides/codes. Once these have been adopted the public will have no further say in any development.  

Duty to Co-operate

This requirement is being specifically abolished with rather vague proposals taking their place. This is unfortunate as planning does not take place in locality vacuums. For example  we live  in Suffolk 3  miles from the Norfolk border. Formal  co-operation is a requirement between the relevant Authorities. If this is removed collaboration will be more difficult.

Housing Targets

The setting of housing targets nationally seems on the face of it a sensible approach, but the assessment is to be undertaken by “algorithms”. Since the A level fiasco there can be little confidence in this approach! The maim driver of the planning algorithms will be house price. ie the more expensive an area the larger the assessed additional housing requirement. The shires and London will therefore take the largest share of the additional housing with annual requirements in Manchester falling by 1000 homes and Leicester 600 homes, both these areas have significant brownfield sites. This does not play well  into creating a” Power House of the North. ” Sustainability in terms of local infrastructure, employment and green transport, whilst discussed in the White Paper do not seem to be relevant in the calculations.

Zoning

The whole thrust of the White paper hangs on the introduction of zoning land throughout England into three categories. The local authorities will decide on the demarcation, but there intends to be a very heavy handed top down approach to this process.

Zoning is widely used in the USA and parts of Europe . France uses this system, but analysis of  the time taken to process Applications in France is similar to England .

 Zoning is inflexible and implementation is not simple. The advantage of the current system in England is that it does allow Applications to be heard in the absence of up to date Local Plans .

It is in this area that the public will be invited to participate. This is the very area which will create the most discord and delay and may well derail the whole proposed process.

Environmental  Issues  

It is extremely disappointing that  there is not a more aggressive target  to achieve carbon neutral homes. For example by 2035  which would not be unreasonable. 

The creation of cycle ways, footpaths, green transport and job creation in a rural environment could be difficult and how to achieve this not addressed. 

Homes for young people

The White Paper says that those objecting to Applications have a stronger voice than those who may support it. No evidence is produced to support this statement.   In a democratic society all citizens have an equal say . Most objectors are not against development in principle. What they are against is overdevelopment in areas which are not sustainable and  lack appropriate infrastructure.  Young people who need houses are specifically identified as not having a voice. Young people are well able to organise themselves as shown in the opposition to tuition fees and the fiasco over A level results. These were subjects they were understandably well  motivated to act upon. 

CV 19 

The timing of this White Paper  is not good as there are significant changes taking place in society as a result of CV19. There are  likely to be  significant numbers of  empty shops and offices coming to the market for change of use to residential use in the near future. These have not have been factored into any of the projected housing deliverability calculations The impact of these has not been considered in making changes to the Planning system. Regrettably, another likely consequence of the pandemic and subsequent recession is that unemployment will rise, necessitating people to sell their homes and others intending to buy will not be able to achieve this.

Conclusion.

The Planning System is being blamed for all of the problems in the housing market. The cause is multi-factorial.  Everyone probably  believes that  the current systems can be improved, but the proposals in the White Paper are grossly undemocratic and are reminiscent of a totalitarian  state  and may have a similar impact to architecture seen in those countries and be reminiscent of the  unfetter disastrous developments of the 1960s.

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Fressingfield and the White Paper

Fressingfield Description

Fressingfield is a village in North Suffolk 3 miles from the Norfolk boundary and within Babergh/Mid Suffolk District Council. The population is just over 1000 and there are 350 houses in the central area of the village. It is designated as a “Primary” village, capable of only limited sustainable development. In the 1970s a large Conservation Area was created in the village core. Within the Parish there is an SSSI at Chippenhall Green. This is one of the last remaining greens  in the area . There are 2 Grade one Listed Buildings and 53 Grade two, an abnormally high proportion of the houses in the village. It is an historic agricultural  village. The former guildhall is now the Fox and Goose restaurant. It is important to preserve the unique quality of village life.

Other local villages are reliant on Fressingfield for medical care and primary education and with approved increased developments in these villages services will be strained. In Fressingfield itself 54 houses have been approved, but not yet built.

Implications of the White Paper for Fressingfield  

The Government talks of building in the right places. Residents, developers and house builders will have very different views as to what are the ” right places.” In Fressingfield we think it is the wrong place for sizable development , above that already agreed ,as it would be unsustainable for the reasons stated later. 

The White Paper proposes  that more land should be released where it is most needed . There is very limited need for development in Fressingfield. The waiting list for affordable houses is very small and our infrastructure would be overwhelmed by large development. Land earmarked for development is indentified in our excellent NDP, which is made and received very complimentary  comments from the Examiner. The NDP should provide the primary policy guidance for future development in the village and the Local Plan.

The White Paper proposes limits the involvement of  the public to digital input into development areas and local design codes. Some older villagers do not have either computers or the expertise to get involved. Exclusion of  the young from the planning process is mentioned, but they have far more experience of the digital age and because of this are very able to organise themselves and make their views known.

The emphasis on ” beauty ” in the White Paper is to be commended , but this will make houses less affordable.  All of the pictures within the White Paper presumably  reflecting ” beautiful” design show developments with either no parking or one parking space per dwelling. In Fressingfield a recent survey on car ownership generated 104 responses. Only 2 respondents did not own a car 69% owned 2 or  more cars in their household. Beauty is soon destroyed by indiscriminate on street parking ( it is also dangerous. ) .

Building in certain areas such as  town centres is promoted. In our small village we do not have a town centre! – The centre of the village is the 12th  century Parish Church and the surrounding graveyard. Brown field sites are commended for development, but in the main the Industrial Revolution passed East Anglia by and we have relatively few brown field sites.

Protection of heritage is very important to us  with 2 grade 1 listed buildings and 52 grade 2. The easiest way to compromise these is by overdevelopment of a rural area with a fragile infrastructure. Net gain from development is highlighted in the White Paper. There is no evidence of this in Fressingfield. In the last 20 years there has been a significant amount of house building, but during this time the Post Office, 2 shops, the garage, the coal merchant and ALL bus services have ceased to exist !

Public participation in the planning process is stressed repeatedly in the White Paper. The current LPA Planning portal is not user friendly as evidenced by splitting Appeals and Applications on the search engine, but at least we do have the opportunity to comment on current Applications .

The best way for a small village to contribute is to use the NDP which was well publicised and had good participation.   

The White Paper states that the Planning Systems should support efforts to combat climate change. Building in green areas and on farmland  with the destruction of trees and hedges will not help with this. In this village there are no buses, no cycle routes, only 55 whole time equivalent jobs. Cars are necessary for getting to work, secondary education, the hospital ( 28 miles away), major shopping, and the railway station ( 11 miles away).

The  abolition of the Duty to Co-operate will have a significant impact upon us . We live 3 miles from the Norfolk boundary . Our nearest larger shopping area, Harleston, is over the border and a large number of Harleston residents are registered with the Fressingfield surgery .The majority of villagers are referred for secondary care to Norwich Hospital . There is cross border flow in many areas.

The Case for Fressingfield being  designated as a Protected area

The White Paper proposes that land use should be simplified and all land should be designated using three classifications.

1 Growth Area.- Capable of taking major development  to include new towns and former industrial sites.

2 Renewal Area- capable of accommodating smaller scale developments.

3 .Areas that are protected -. Areas which, as a result of their particular environmental and/or cultural characteristics would justify more stringent controls to ensure sustainability. This would include areas such as the green belt, Areas of Outstanding Natural Beauty, Conservation areas, Local Wildlife sites, areas of significant flood risk and important areas of  green space.

Key Issues for Fressingfield- Increased development will impact on all of the following issues:-

Flooding. Includes overflow from all sources, including sewage. ( as confirmed by the Lead  Flood and Water Management Team at Suffolk County Council ). Fressingfield has experienced 11 incidents of sewage egress since December 2017, with raw sewage and  sanitary material  flowing down the road and into gardens . Clean up teams have been needed and the local Director of Public Health has described this as a health hazard.. Pollution of the local Beck has been common and has been reported to the Environment Agency. More housing will exacerbate the problem because of the limited functional capacity of the sewer.

The other cause of flooding is the overtopping of the Beck, not associated with sewage egress. Some Fressingfield residents living in the flood zone have had difficulty in obtaining building insurance.

Green Credentials.  In Fressingfield these  are poor. There are no cycle routes and a significant absence of footways . Private transport is needed to get to work, major shopping, hospitals and the railway station.

Public Transport. There are no buses and car ownership is high. An online survey in January 2020 had 104 responses. Only 2 households did not own a car and 69% owned 2 or more cars.

Employment . There are 55 whole time equivalent jobs in Fressingfield. Many of these are specialised  posts  ( eg nurse, teacher ) and these people tend to live outside the village. Travel to work increases the carbon footprint.

Highways.  Lack of footways makes walking difficult and is a particular problem for the disabled in wheelchairs.

All roads are minor roads and are narrow with poor visibility and with significant on street parking. There is no potential for improvement as in many instances houses abut directly onto the road. Jubilee Corner and New Street are of particular concerns regarding safety.. 

Services. The surgery for the locality is based in Fressingfield with a branch surgery at Stradbroke. There are significant developments approved, but not yet built  in the catchment area of the surgery – 60 house at Stradbroke; 54 at Fressingfield; 24 at Laxfield; 80 at Weybread, with smaller minor developments in other villages  . These developments will generate an additional 700 new patients. The surgery is already short of space and has insufficient parking. Staff recruitment is also a problem in this region.

Some of these developments will put pressure on the school which is nearing capacity. 

Pressure will also increase on the highways as cars are needed to travel to these facilities.

Heritage and the Local Environment. Fressingfield is surrounded by agricultural land . Further significant development will impact detrimentally to the rural character of the village and its setting as a whole. It would also affect the open aspect of the village and have a negative impact on the setting of many listed buildings. The topography of the village should be recognised  as it sits in a low point and is visualised from every approach.

Neighbourhood Development Plan. 

This was overwhelmingly approved by Fressingfield residents. It has been adopted and received significant praise from the Examiner. It is the village voice for determining future developments. With all of the work and effort that has contributed to this document, we trust that it will be the basis for future planning decisions and recommendations . Should the document guidelines be overridden or ignored then many residents who voted for  the document will feel very betrayed and their faith in local planning decision making will be severely damaged. 

We feel that for all of these reasons Fressingfield should be zoned as a ” Protected area” should the recommendations contained within the White Paper become Law. 

*  *  *  *  *  *  *

Press coverage  and Reports following release of the White Paper

Zack Simons – Planning Barrister at Landmark Chambers “Creating what will become the slums of the future.”

Lord Kerslake – Chairman of the Peabody Trust. ” Increasing supply, reducing demand , and lowering house prices is not on housebuilders’ agenda. This is not a criticism of the private sector, it is just an observation of the reality.”

Alan Jones – RIBA President ” these shameful proposals do almost nothing to guarantee the delivery of affordable, well designed and sustainable homes” 

Prof Tim Marshall, Oxford Brookes University . ” The ideological aversion of the current Government to serious planning ( as against rhetoric on beauty and democracy) is such that it is prepared to make even some of its own goals unattainable.”

Neil O’Brien MP for Harborough  when discussing the reduction of housing targets in  northern areas. ” Lots of our large cities have brownfield land and capacity to take more housing and it seems strange when planning to “level up” to be levelling down their housing targets to rates even lower than they have been delivering”.

East Anglian Daily Times ( 27th August 2020 )- ” Don’t bet your house on planning changes making it easier to buy a home”

PEC/JEC  for SAFE 

SAFE Members – John Castro, Pam Castro, Tim Eastoe, John Kelsall, Elizabeth Manero, Abi Maydon, Paul McCann, Michael Miles. 

31.08.20


Mid Suffolk  Consults on the 5 year Land Supply for Housing

MSDC has issued a report on the 5 year land supply and the deliverability of new houses. Click here to view. The available land for development has increased from an assessment of 5.66 years supply in March 2019 to 7.76 years currently, with supporting good evidence that the proposed houses can be delivered within the timescale.

This is very good news for Fressingfield as without the required land supply of a minimum of 5 years the Neighbourhood Development Plan carries less weight and certain Planning Policies need not be taken into account when Planning Applications are considered.

SAFE has responded to this Consultation Document.

Consultation  is open until 14th September 2020. If you wish to comment reply directly to    delivery@baberghmidsuffolk.gov.uk

PC .

August 2020


Provisional Dates for Hearings

The provisional date for hearing these Applications is October for John Shepherd Road and Stradbroke Road and November for Post Mill. These dates may well change so watch this space! Separate dates for hearing Applications in the same village make cumulative impact assessment more difficult.


Recent damage by traffic in New Street

New Street Damage. 27 July 20
New Street – 27th July 2020
New Street Damage 20.09.20
New Street – 20th September 2020

Proposed Development at Post Mill

The original Post Mill Scheme ( 1648/17) was unanimously rejected on 22 November 2018. It went to Appeal ( APP/W35200/W/19/3227159)and was refused on 25 September 2019, primarily on the grounds of heritage and the impact on the setting of Ladymede Cottage.

A modified Application was submitted on 24 December 2019 (DC/10/05956). 50 public comments were submitted. None supported the Application. Consultation closed on 14 February 2020. Since this time the Developer and Planners have been in discussion and minor changes have been made to the Application.

SAFE members and others have written to the Planning Authority to stress that the problems of 2018 have not changed and in many cases significantly deteriorated since the Inspectors decision. Papers are submitted under the aegis of SAFE as follows.

John Kelsall

Dear Vincent,

Planning Application DC/19/05956

I hope that this e-mail finds you well and stress free at this strange and difficult time.

As Vice Chairman of SAFE I am party to your correspondence with John C on the above application and am astonished and bewildered to learn that you may be favouring supporting this slightly revised application.

I have set out below the very strong arguments you made against the granting of planning permission for the original application made at the Committee meeting in Nov 18 and also, subsequently, when the developer appealed against the unanimous decision of the planning committee in the summer of 2019.

I have also added a list of changes/developments which have occurred since the application and appeal were made which make support or this application even more difficult and unlikely.

YOUR STATEMENT FACTS (I have tried to bullet point these so as to give you less reading, you will know the detail by now!)

  1. The development lies outside the settlement boundary of Fressingfield
  2. Unacceptable safety hazards to non-motorised users travelling on New Street and through Jubilee Corner: no provision of safe, practical alternatives. Risk is unacceptable in its own right. Contrary to LPPF T10 and contrary to para 109 0f the NPPF.
  3. Suffolk Highways against development: further traffic passing along New Street and/or through Jubilee Corner would result in an unacceptable impact on highway safety particularly for vulnerable pedestrians.
  4. Contrary to Paragraph 163 of the NPPF in that it will increase flood risk of raw sewage elsewhere in the village. THE RISK IS CONSIDERED IN ITS OWN RIGHT TO SIGNIFICANTLY AND DEMONSTRABLY OUTWEIGH THE BENEFITS WHICH MIGHT ARISE FROM THE PROPOSED DEVELOPMENT.
  5. Adverse impact on MSDC District Wide Settlement Hierarchy and Housing Distribution Strategy in that it will result in a significant level of new residential development being located in a village where only small scale, sustainable development is encouraged due to poor accessibility( huge and unacceptable new carbon footprint) ,relative isolation and low economic, environmental and social sustainability of the location.

IT WILL RESULT IN UNSUSTAINABLE AND INAPPROPRIATE development contrary to para 8 of the NPPF.

DOES NOT AMOUNT TO SUSTAINABLE DEVELOPMENT.

6     Lady Meade Cottage ( listed building) has sight lines blocked by new development. THESE ARE ALL YOUR ARGUMENTS/CONCLUSIONS AGAINST DEVELOPMENT, ONLY 6 HAS BEEN PARTIALLY RIGHTED.

       I CONCLUDE BELOW WITH A LIST OF CHANGES/DEVELOPMENTS WHICH HAVE OCCURRED SINCE THE APPEAL WAS LOST WHICH MAKE THE CASE FOR A FURTHER REJECTION FAR STRONGER.

RECENT CHANGES.

  1. The agreed downgrading of Fressingfield in the MSDC settlement hierarchy means many fewer houses should be built with a guide of 5 a year. With a present holding of 51 builds agreed there is now no need for this development.
  2. Since the appeal was lost Fressingfield’s Neighbourhood Plan has been approved by the inspector AND by MSDC and compliments passed on its quality. It does identify 60 potential builds, including 51 already agreed but IT DOES NOT IDENTIFY POST MILL LANE as a potential growth area. We were told that an approved NP carried weight when planning decisions are made?
  3. More frequent and more serious outpourings of raw sewage have occurred in the months since the decisions were taken ( you will be aware that John Castro has the photographic evidence). It is NOT the case that these have diminished in severity or number.
  4. MSDC has approved the building of 80 new homes in Weybread thus increasing greatly pressure on Fressingfield services including the school and the surgery.
  5. The new build in Weybread will increase traffic flows around Jubilee Corner and along New Street thus increasing safety risks, something which Suffolk Highways regard as dangerous.
  6. Such a build, miles from public transport ( our last public bus service has been discontinued) and work centres will create a large, new carbon footprint, contrary to MSDC and central government policies.
  7. Anglia Water now publicly accepts that there is a major problem with its foul sewer in that rain water ( run off) has been directed into its sewer for many years and through many links and that, at times of high precipitation it cannot cope with the joint discharge. (This makes the appeal inspectors conclusions out of date and erroneous). Further building will, inevitably, worsen the situation in the future.
  8. I am told that the sight lines from the rear of Lady Meade Cottage are still not wholly clear, contrary  to the inspector’s decision

ALL OF THE ABOVE MAKE THE CASE FOR REFUSAL FAR STRONGER WHEN COUPLED WITH YOUR DETAILED AND VERY STRONG ORIGINAL OPPOSITION TO THE POST MILL LANE DEVELOPMENT DEMONSTRATED AT THE PLANNING COMMITTEE MEETING IN NOV 18 AND LATER IN YOUR REFUSAL OF THE APPEAL. GIVEN ALL OF THIS THERE CAN BE NO CASE FOR SUPPORTING THIS FURTHER APPLICATION/

Thank you for taking time to read this letter.

Pam Castro

Application DC/19/05956 – Post Mill Lane

The Inspector rejected an Appeal in September 2019.  Objectors and probably the  LPA were surprised by the reasons cited by the Inspector in support of his decision. Critical infrastructure issues were completely ignored. This paper attempts to highlight briefly what has changed since the time of the Report.

Sewerage 

Pollution incidents have become more frequent and more severe. Anglian Water accept that surface water is entering the system causing it to be ” overwhelmed.” Following 3 years of investigation they are no nearer in resolving the problem. (This issue is dealt with in detail in the paper submitted by John Castro.)  

Transport 

The one bus per week has since  been withdrawn. There have been no cycle routes and no new footways. In January 2020 an anonymous online survey was conducted by SAFE in order to gain more information from residents about the highway safety issues in Fressingfield. There were 104 responses. Only 2 respondents did not own a car, 40% owned 2 or more cars and 19% 3 or more cars. The village is completely dependent on private transport. In his report to the Planning Committee on the original Post Mill Application Vincent Pearce himself observed that during the school run nearly all children were delivered to school by car. He assumed this must be due to concerns over the dangers of walking to school.  There is no secondary school in the village. There are no green transport credentials in Fressingfield and almost everyone has to travel to work by car due to there being still being only 55 WTE jobs in walking distance. Many of these  posts are specialised and many professionals ( eg Nurse, teacher) live outside  the village .

 The results of the survey confirmed a  very high level of anxiety around road safety, especially when walking in New Street and at Jubilee Corner. The proposed Post Mill extension will add significantly to traffic in these areas as the access is directly onto New Street.

Education

A further 80 houses are likely to be built at Weybread.  Primary School children from Weybread go to the school in Fressingfield. Since the Inspector’s report the school made a teacher redundant due to a funding crisis, not a lack of pupils. The Weybread development will put pressure on the school.  

Medical Care

Since last September there is more local development is in the pipeline. Within the medical practice catchment area there are 60 houses approved at Stradbroke;  80 likely to be approved at Weybread; 24 at Laxfield ( with a further 8 pending) on top of the 52 approved for Fressingfield. There  will be additional approvals for the smaller villages, therefore this figure is conservative. These additional homes will  seriously impact on medical care. All the above villages  refer to the Fressingfield practice  with its branch surgery at Stradbroke . The lack of physical space is a real issue as is staff recruitment. Many people are already  concerned over the lack of available appointments and the already increased waiting times. A  serious lack of parking at the Fressingfield site is contributing to road safety problems in New Street as patients are now parking on New Street  often  adjacent to the entrance to Post Mill.

 The houses not yet built, but approved  will result in approximately  700 new patients. Approval of the Post Mill application will make the situation worse.

Revised site layout at Post Mill

In an attempt to meet the Inspector’s objections the developer has reduced the house numbers from 24 to 18, removing the houses that directly abutted the Ladymede boundary. It  can be strongly argued that the proposed reduction in house numbers and site  layout does not meet the requirements of the Inspector in the protection of the setting of Ladymede cottage.  Should there be any more  building on the Post Mill site? The Inspector called the appeal site as ” Open and Verdant” and noted that the proposals did not ” conserve and enhance the historic environment.” It is difficult to see how a reduction of 6 houses will meet the objections. Ladymede will still be backing onto an unimaginative  urban housing estate VERY clearly visible from the first floor of the cottage. 

Approved Applications

An argument has been put forward that the two major approved applications at Red House Farm and School Lane are not deliverable, therefore Post Mil is  needed. This is not true. Both Applications are live with recent Applications being lodged for both sites. 

NDP 

The NDP has been made and confirms that Post Mill is not a recommended  development site and remains outside the settlement boundary. The detailed arguments around ignoring the NDP will be made by others, but there is the basic question over the principles involved. Many people voluntarily devoted a great deal of time and effort to the formation of the Plan and a good deal of public money supported its production. If, at the first test of the Plan it is ignored residents will understandably ask ” why did we bother?” Apathy is the greatest enemy of gaining public engagement . Not to adhere to the Plan will have a massive negative impact on the village and call into question the whole democratic process. 

Joint Local Plan

Under the current adopted Plan we are designated as a” Primary “Village capable of only limited sustainable development  52 houses have already been approved but not yet built. The NDP recommends 60 houses during the Plan period up to 2035. The Post Mill development would significantly take the housing numbers over 60 and makes no allowance for ” windfall” houses. Under the draft plan we were erroneously classed as a “core” village. MSDC have confirmed that this will be corrected  at the next stage when Fressingfield will be designed as an “Hinterland “” village. Permitting only limited sustainable development. 

NPPF

The proposal runs contrary to a number of recommendations within the NPPF concerning off site flooding, transport,  and overall sustainability. 

Conclusion

The LPA  robustly objected to the first Post Mill Application and it was refused by  all Planning Committee Members in November 2018 . The subsequent Appeal  was unsuccessful.  The situation has not changed and the information above demonstrates that the situation around overall sustainability has deteriorated since September 2019. Whilst it is understood that the LPA is under enormous pressure to approve building Applications and the  presumption in favour of development  is understood, this should not result  in Applications being approved that do not meet the basic criteria and are not sustainable.   This  Application needs to be viewed in the light of all of the supporting evidence above. Put bluntly it does not tick the boxes in terms of Policy and to approve it would be very detrimental to the village.

Michael Miles

Dear Vincent

I write to object to the above. First of all the objections I raised on 13th January still apply-reference Planning Application DC/19/05956 Post Mill Lane

OBJECTIONS

1.THE NDP for Fressingfield STATES THAT 60 NEW BUILDS MAYBE ACCEPTABLE OVER THE PLAN PERIOD AND 51 HAVE ALREADY BEEN AGREED

2.The proposed development is outside of the settlement boundary and not identified by the NDP as a site for subsequent development

3.More dwellings will affect the safety for pedestrians and motorists by increasing the congestion especially in New Street

4.Increased risk of unacceptable flooding, raw sewage and sanitary products on the road and walkways which in the past have required professional clean ups for health reasons

5.This development if approved would affect the rural character of Fressingfield already diminished by overdevelopment

6.There is,  subject to planning approval a development in Weybread less than 2miles away for 80+ dwellings  which will ,if given the go-ahead  exacerbate the traffic and parking  challenges currently experienced in the village.

7.The NDP for this village has been formally ratified therefore this should be the prime guide for any future development.

8.Should this application be approved it would have a negative impact on the rural aspect of Fressingfield as seen from one of the main approaches to the village especially in winter when the trees are devoid of leaves.

9.I am appalled by the size of the Baptist chapel currently under construction- an eyesore is the only way to describe it. Further building in the village of unwanted and inappropriate items will further erode the heritage and setting of this medieval and picturesque place to live.

10.This village was wrongly identified as a primary village-this has been corrected in the local plan which means that only FIVE new builds per year are appropriate and that figure has already been exceeded

Abi Maydon

Objection to Planning Application DC/19/05956

Dear Vincent,

I hope that you are keeping well.

I am writing to object to the revised planning application to Post Mill at Fressingfield. 

All the same arguments as I made before still stand:

The proposed development lies outside the settlement boundary of the village and is in an area not identified by the NDP as a suitable place for subsequent development.

The proposed site is on agricultrual land which connects with open fields and space beyond the village to north and east. The site clearly lies outside the settlement boundary of Fressingfield in the Mid Suffolk Local Plan, 1998 (LP), and therefore in planning policy terms is designated as ‘countryside’. 

Fressingfield’s NDP outlines that 60 new builds may be acceptable for Fressingfield over the plan period, and as you know 51 have already been agreed. 

This development will present more safety hazards and congestion through the village which is already unsafe for pedestrians and motorists.

The risks of unacceptable flooding and raw sewage will be worsened and already these issues are unacceptable for the village.

More importantly, the development will impact detrimentally on the rural character of the village and it’s setting as a whole, and Ladymeade Cottage, identified at harm by the inspector will still have its setting ruined by this slightly revised application.

The Council’s Heritage and Design Officer recognised that Ladymeade was once an isolate rural dwelling and is likely to have been a farmhouse benefitting from a spacious setting adjoining open farm land. 

Therefore, the site’s open and verdant setting helps illustrate the listed buildings historical use as a farmhouse being in close proximity to undeveloped rural land surrounded by mature vegetation which makes an important contribution to the setting and significance of this listed building.

Again proposed development here would erode the openness of the site, altering the listed building’s immediate open and verdant setting. As such, there would be a negative effect on the setting of the listed building and harm to its significance. It would also not be sympathetic to local character and history, including the surrounding built environment and landscape setting, as advocated by the Framework. No boundary treatment advocated by the developer could mitigate this harm to the setting here and the proposed development here would be substantially damaging to the heritage and setting of this part of the village and the way it connects with the open countryside here at the edge of the settlment boundary.

This would go against the saved Policy HB1 of the Mid Suffolk Local Plan, 1998 (LP), which states that the Council places a high priority on protecting the character and appearance of all buildings of architectural or historic interest, and that attention will be given to protecting the settings of listed buildings. 

It would also conflict with the relevant requirement of the Framework which seeks to conserve and enhance the historic environment. Finally, it would not preserve the setting of the listed building as required by Section 66(1) of the Act, but instead would be harmful.

Furthermore, since the inspector’s report against this development in September 2019, there is a nearing possibility of large scale development at Weybread which will further erode the sustainability of this small village. 

Fressingfield was wrongly identified as a primary village which has now been corrected in the local plan meaning that only 5 new builds should be appropriate per year which we have already exceeded. 

Fressingfield’s NDP has now been formally ratified and should provide the primary policy guidance for future development in the village. 

The topography of the village recognised and safeguarded in the new Village Development Plan means that new development proposed here would negatively impact on the rural aspect of the village as one of the main approaches into Fressingfield. This will be especially marked in winter months when the trees are not in leaf.

Currently, the Baptist chapel is being built in the village. It is a huge monstrosity and looks totally out of place in this small rural village, eroding the character and heritage here. Please do not further erode the heritage and setting here by allowing unwanted and inappropriate development such as this.

T Eastoe

Application No. DC/19/05956 – Post Mill Lane, Fressingfield.

Dear Mr Pearce,

There are numerous points regarding the proposed development that I feel should be carefully considered and a satisfactory response to each in your report would be appreciated.

It is worth looking at the history of this site and how the new proposal relates.

Firstly, the Post Mill Lane site originally belonged to the former farmhouse, grade II listed Mount Pleasant. On this meadow were agricultural buildings used for pigs and chicken farming. When the existing development was passed, the land was designated as a brown field site which of course has a priority for development over greenfield land. The existing boundary of the brownfield site does not include the land on the new application for the additional 18 houses. This land is clearly greenfield and outside the parish settlement boundary. Therefore, this is more than just an extension of the existing site, it is encroaching onto greenfield land beyond the approved settlement boundary.

It is noted in the previously refused application that the impact on the listed property Ladymeade was carefully considered which resulted in the refusal of that application and with this point in mind, consideration should also be made for the star listed property Mount Pleasant which adjoins the Post Mill development. Little consideration was made for Mount Pleasant when the existing development was approved and hopefully MSDC has since adopted more conciliatory approach.

The proposed development will only exacerbate the problems of surrounding the listed buildings of Ladymeade and Mount Pleasant with modern styled development that might be seen in almost any urban sprawl. Mount Pleasant at least, had been a rural farmhouse within a rural setting for at least 500 years and to erode that setting even further with the proposed development would be a travesty to its heritage and the village.

The proposed development has only one access point which is off New Street. With the erratic width of New Street and lack of footpaths is a serious problem. Only by living in New Street can anyone really appreciate the safety issue. The critical part of New Street is where the road is the narrowest and has very poor visibility for both drivers and pedestrians. Little can be done to improve the road to overcome these problems and with the expected increase in the volume of traffic from the new approved developments, road safety in New Street will undoubtedly deteriorate let alone the pressure from the proposed development. New Street falls well below the modern highway standards and by encouraging even more traffic by the proposed development, the problem will only get worse.

Another associated problem of New Street is the lack of parking for the Medical Centre. At present numerous cars park all around the junction of the Medical Centre car park and often  illegally parked. The proposed application will without doubt contribute to this problem even more despite only within walking distance. The infirm, disabled and elderly will need transport for this journey.

The NDP has given the village the guidelines for future development and this important document was overwhelmingly approved by Fressingfield residents. With all the work and effort that has contributed to this document, we trust that it will be the basis for future planning decisions and recommendations. Should the document guidelines be overridden or ignored then I’m sure the many residents who voted for the document would feel very betrayed and faith in local planning decision making would be severely damaged.

The LDP states that a maximum of 60 new houses over a period of 10 years is the new development recommendation. With currently 51 new houses already approved and waiting to be built, leaving 9 extra new houses. The proposed development clearly contravenes this recommendation and therefore on that basis alone, should be refused. Additionally, Fressingfield has been officially designated Village Hinterland status meaning no more the 5 new houses per year.

There are numerous problems with this development, such as the inadequate sewage system, complete lack of local public transport, lack of employment opportunities, the impact of the expected 80 houses at Weybread, further pressure on the school and Medical Centre. With all these problems, I believe the NDP got future development just about right with the additional 9 new houses spread over a 10 year period. The proposed development is too large and in the wrong place. Why build on precious greenfield land when there are far more suitable sites within the village? This goes against the NDP and the majority of the residents, therefore should be refused.

Resident of Post Mill Lane, Sharon Lytton

To Vincent Pearce and Mid Suffolk Planning Authority

I am submitting new evidence for your consideration with regard to the current Post Mill application.   I would be grateful if you could let me know this has been received and taken into account.

Appeal Report and Protection of Heritage View from Ladymeade Cottage

From the garden and top window of 16th c. Ladymeade Cottage the houses proposed in the field behind/adjacent to the cottage would be seen.  This would contravene the Inspectors Report whereby the heritage view from Ladymeade should be protected and kept open to the verdant countryside.  No new housing should be visible.

In what sense therefore could it be permissible to build in this field?

I look forward to a timely reply on how the question will be examined and determined.

The application design is the same as the previous one except for several large houses cut out at one side of the field behind Ladymeade Cottage.  No effort has been made to redesign the site given the Inspectors Report.

Residents of Fressingfield, .E. and C. M. Comin

Planning Application DC/19/05956 – Post Mill, Fressingfield

We have written previously and, following the Inspector’s Report (dismissing the Appeal on the previous Application for 24 houses), ask that these additional comments be taken into account before any decision is taken:

1) There have been further frequent incidents of the sewers overflowing in times of heavy rain. We are sending a photograph taken on 6th October 2019 in Cratfield Road opposite where we live. This caused pollution and created a health hazard, and unfortunately was by no means an isolated incident. This is a well-recognised and intractable problem in Fressingfield generally, and it is clear that the sewer cannot accommodate any additional loading, and nor has any workable remedy been devised to tackle the issue.

2) The lack of any public transport will mean increased traffic as the resultant increased number of residents having to use their own vehicles, raising concerns around highway safety within the village, particularly in New Street (to and from which Post Mill accesses/exits, as well as the Health Centre and where the shop is). Here there are no footways along this narrow road, or sufficient space to provide any. Traffic will also increase elsewhere in the village; for example, vehicles exiting The Gull (a Byway Open to All Traffic) which runs alongside our property, can only reverse out onto the highway as there is no turning space there, and this will become an even greater highway danger once the old Baptists Church is converted to a residence with five bedrooms (as permitted by your Council).

3) An overriding consideration in this (and any other application for development) is that over 50 houses have already been approved in Fressingfield but not yet built.
Further, we understand that in neighbouring Weybread the Council are likely to approve around 80 houses, in addition to a similar number already approved in Stradbroke and Laxfield. Without knowing the impact that these will have on the village infrastructure and facilities generally it would be wholly irresponsible to approve yet further development.

4) Since the Inspector’s decision on the previously rejected application (for 24 houses), our Neighbourhood Development Plan has been finalised and accepted, the result of considerable voluntary effort and consultations within the village residents who engaged with the process in large numbers. Further housing in Post Mill was not recommended, being outside the settlement boundary. To ignore the NDP at this first test would be unconscionable. Furthermore, as a soon to be designated ‘hinterland village’ under the Joint Local Plan, limited sustainable development only will be permissible in Fressingfield.

5) Notwithstanding the above comments, the proposed design and layout of the development is extremely disappointing, more akin to a town environment where there may be similar existing housing and absence of the atmosphere of a rural village. The plots are also small as a result of an excessive number for the site area, albeit reduced in number from the earlier scheme, leaving little space for gardens and sympathetic soft landscaping or tree planting.

6) The previous application for Post Mill was refused, and this should be too.

Pic Oct 19

Please confirm receipt of this letter.

Yours faithfully

Fressingfield Residents

Paul McCann

Dear Vincent,

New evidence has emerged regarding the inadequacy of the sewer since the Planning Inspector’s Report.

At times of heavy rainfall, the CEO of Anglian Water has confirmed that, the sewer is ‘overwhelmed’ due to the fact that the sewerage  system in Fressingfield is actually a combined system. You will have seen the extent of the pollution in the village following heavy rainfall through the photographs sent to you from SAFE. It really is unacceptable, I’m sure you will agree.

I recall when the original Post Mill Application ( 1648/17). was considered at the previous Planning Committee, the Chief Planning Officer stated regarding the sewage egress that ‘It seems ridiculous and COMPLETELY UNACCEPTABLE to expect local people to endure what at times looks and smells like a medieval living environment’

How the Inspector overlooked this situation is beyond comprehension and now the position has worsened and are occurring more frequently

Since the Inspector’s Appeal decision In September 2019 Anglian Water has confirmed that the functional capacity of the sewer is reduced by non-foul water entering the system. Put simply, more houses will create more foul sewage resulting in more frequent and concentrated sewage egress.

On top of all this, to add to the equation, planning has been agreed for 80+ houses to be built in Weybread. This will impact on the infrastructure and roads in Fressingfield.

Finally, since the Inspector’s Appeal decision, we now have a Neighbourhood Development Plan (NDP)which outlines that 60 new houses may be acceptable over the plan period and 51 have already been approved.The NDP should now provide the primary policy guidance for future development in Fressingfield.

John Castro

Application DC/19/05956- Post Mill Lane Fressingfield

This paper documents new evidence regarding  the inadequacy of the sewer which has become evident since the Planning Inspector’s Report . Anglian Water (AW) has also changed its position with regard to the functional capacity of the sewer as explained below.

*The sewer in Fressingfield is a designated foul only sewer.

*For the first time, recently  the CEO of Anglian water ( AW) accepts that a large amount of surface water enters the system . Although the sewer is designated as a foul sewer  it is de facto  acting as a combined sewer. On 5th May 2020 the CEO of a AW wrote ” The sewerage system in Fressingfield is actually a combined system.”

*The CEO of AW confirmed on 14th November 2019 that at times of heavy rainfall the sewer is  “overwhelmed .”

*The excess water comes from historical surface water connections from houses to the sewer and possibly other unidentified sources. AW charge 341 properties(approximately a 85%of the village) for surface water connections.

* CCTV examination of the sewer has been undertaken twice, the last time in early 2020. On both occasions no other source of water ingress was found and there are no fractures of the system.

*In a recent two year period there have been NINE occasions when manholes have lifted and raw sewage and sanitary products have flowed down the road and into gardens. These occur at times of heavy or persistent rainfall. The longest incident on 20 December 2019 lasted over 27 hours. Clean up teams were required on several occasions to clean up the mess. Five of the nine events post date the Inspector’s Report ( 25th September 2019). Representative photographs of these 5 events are attached. All of these events were reported contemporaneously to the Environment Agency.

*The sewers have been flushed through periodically and the last occasion was June of this year. No significant blockages or fatburghs have been found, so foreign body blockage is not the cause of the sewers overflowing.

*The sewage causes pollution of the Beck and the Environment Agency are investigating this. Offwat are investigating whether AW are in breach of their obligations. These actions post date the Inspector’s report.

*The Director of Public Health has described sewage egress as a health hazard.

*A further 52 houses, a chapel and enlarged Scout hut have been approved, but not yet built. The sewage from these houses will enter the system and stress it further. More approvals will have the same effect and result in more egress of sewage, especially so with climate change, creating extreme weather events.

*The use of dry flow calculations for sewerage capacity are meaningless as no allowance for surface water ingress is made. AW  having accepted the point that there is significant surface water ingress should now recalculate sewerage capacity allowing for surface water drainage from over 300 houses and worsening storm events. This significantly impacts on the advice given by AW to the Inspector.

*AW have undertaken intensive investigation in the village over the last three years, but seem to be unable to propose any remedies to  the situation.

*The Inspector dismissed the Appeal ( September 2019 ) , but chose to ignore the above facts as a reason for dismissal . This was based exclusively on the fact that AW raised no objection. The situation was neither explained or questioned. Since the Appeal decision AW have confirmed in writing that the functional capacity of the sewer is reduced by non- foul water entering the system resulting in the sewer being periodically ” overwhelmed.” More houses will create more foul sewage resulting in more frequent and more concentrated sewage egress.

When original Post Mill Application (1648/17) was considered at a previous Planning Committee  (November 2018) the Chief Planning Officer, when commenting on the sewage egress stated ” It seems ridiculous and completely unacceptable to expect local people to endure what at times looks and smells like a medieval living environment ” ( para 4.13.11). Despite the Inspector having no regard for this situation the position has worsened as described in this paper. Unacceptable events have become even more frequent. 

( all of the documents mentioned in this paper are available should they be required)

Sewage Egress in Fressingfield since 25th September 2019 - Date of Inspector's ReportEgress on 20th December 2019

Elizabeth Manero

Available as PDF by clicking here

00010002000300040005000600070008


Sewerage Problem in Cratfield Road/ Low Road again.

On 7th August2020 foul smelling sewage discharged from a manhole near the Carnser . Effluent drained directly into the Beck. This was reported to Anglian Water and the Environment Agency. This episode occurred on the hottest day of the summer and on a day when there was a virtual drought. Egress lasted approximately 5 hours until the blockage was resolved. Further investigation to exclude an underlying cause will be undertaken by Anglian Water. Four weeks previously the annual examination of the sewers by Anglian Water showed no significant encrustation or fatburghs.

Low Road 7 August 2020


Annual Parish Meeting – Report from SAFE ( Supporters Against Fressingfield Expansion)

SAFE has continued with activities related to its original aims at the time of its inception. It has been primarily concerned with housing developments, rather than individual properties, except where these a have disproportionate impact.

SAFE maintains its web site – fressingfieldhousing.org – which gives detailed information on its activities and other information relating to development in the Parish.

Three major Applications at Post Mill (18 houses), John Shepherd ( 27 houses ) and Stradbroke Road ( 21 houses) are all pending a decision. SAFE is considered an interested party and has argued objectively and in detail against them.

Recently a revised Application was submitted for housing in School Lane. Housing here and at Red House Farm were approved before SAFE was active and so our input is related to the environmental impact and fulfilment of Planning Conditions.

Our aims of preventing overdevelopment of the village has been helped considerably by the adoption of the Fressingfield Neighbourhood Plan. We offer our thanks to the Steering Group for their hard work and congratulations on the result of the referendum. A target of a total of 60 new homes up until 2035 has been agreed. Of these 53 houses already have planning approval, but are not yet built.

During the three major Planning Applications many residents were concerned about a range of issues. SAFE has continued to gather information on these, particularly the problems relating to the sewerage and flooding and highways. We have a continuing dialogue with Anglian Water and subsequently we have been in contact with a series of related Agencies such as the Environment Agency, Ofwat, Suffolk County Council, the Department of Communities and Local Government, the Planning Inspectorate Complaints Team and the Parliamentary Ombudsman, as well as our Local MP.

In January 2020 SAFE carried out its own road safety survey ( see web) . This demonstrated strong views amongst those who responded to the survey. A significant majority would feel less safe if more houses were built. The range and richness of the comments points to a clear picture of the difficulties of living in an historic rural village not designed to accommodate excessive traffic.

We have highlighted the lack of local employment, the pressure on the surgery and school, the fact that there is no sustainable transport and the impact of the proposed developments on our heritage. We have pointed out that further major developments are outside the settlement boundary, do not conform to the policies within either the adopted or draft Joint Local Plan and are not supported by the Neighbourhood Development Plan.  We continue to bring all of these points to the attention of the decision makers – Mid Suffolk District Council. Our mantra is ” Fressingfield is a Village not a Town.” 

SAFE 26.6. 20 Members –   J. Castro (Chair) J. Kelsall (Vice Chair), P. Castro (Secretary) T. Eastoe, E Manero, A. Maydon, P. McCann, M. Miles


Suffolk Preservation Society  ( SPS ) and Fressingfield

Suffolk View  is the magazine of SPS. In the current issue they talk of ” the saga around large housing proposals continues across our districts. Some are new proposals and the others are persistent reapplications attempting to push through applications . ” “In Fressingfield SPS has objected to the three applications for separate sites which have all had previous applications refused. Parts of the supporting case against these applications are the local Neighbourhood Plans  ( NPs) that exist.”  “Once adopted they become formal policy documents that the Local Planning Authority has to take note of, and give weight to, in any planning decision. ” 

“In Fressingfield, it is more about disproportionate scale of the development when taken together with the other schemes already approved. The recently adopted NP  ( having been through Examination ), does not allocate this particular site for development with the Plan’s Examiner noting ” I do not consider it necessary for inclusion of additional sites.” Therefore , SPS ‘ s view is that the policies within the NP should be given significant weight in consideration of the proposals as they have been independently assessed and the views of the Parish have been clearly made on sites for future development.”

SAFE strongly supports the approach taken by SPS and hope that the applications will be refused.

JC   April 2020


Fressingfield Neighbourhood Plan (NDP)

Our thanks to the NDP Steering Group for all of their hard work and this excellent result. Also to the many other villagers who helped with the project. It is an outstanding result which augurs well for the future. This overwhelming result was achieved despite an unsigned flier with false information which circulated in the village the day before the poll.

Well done everyone.

Declaration of Result of Poll - Mid Suffolk Neighbourhood Plan Referendum in the Fressingfield Area

JC 13 March 2020

On 27 March 2020 The Fressingfield Neighbourhood Plan was approved by Mid Suffolk District Council. The Plan is therefore ” adopted” and will be a significant material consideration when Planning Applications are considered by Mid Suffolk District Council


Summary of Planning Applications in Fressingfield.

The NDP supports a housing “target” for Fressingfield of 60 houses in the period to 2036. Below is shown the situation in March 2020

0001 (7)

The 28 houses at Red House Farm have Outline Planning Approval. A further Application in respect of reserved matters has been made relating to the design and mix of the proposed housing. Click here to view – DC/20/02053

This Application was withdrawn on the 26th June.


School Lane Housing  DC/20/01820

An Full Planning  Application has been made for the erection of 12  houses on the School Lane site. Click here to access the details. . This is one of the sites the Neighbourhood Plan supported for development


Trustees of Fressingfield Baptist Chapel

Application was made to vary the working hours on the new chapel site (application DC/20/01400).

Permission was refused on 10th July 2020


Appeal Lodged Against – DC/19/05548

An Appeal has been lodged against the decision to refuse building on the land next to the Manse and Baptist Chapel.


SAFE attempts to resolve the Problems with Sewage egress

Following the response from the Peter Simpson CEO, shown later in this section we wrote on 10th May to MSDC and highlighted the 4 areas that we thought to be the most important. As yet there has been no response.

“Dear Philip and Vincent,

I have now received a response from Peter Simpson, CEO at Anglian Water and I am forwarding the paper trail which gives background information and shows the points ignored and not answered. I send this to you for your information and comment. Mr. Simpson is keen on multiagency working not seeing this problem exclusively as his Company’s responsibility.

Whilst he has failed to answer all of the questions I raised he has made some points which are of general interest.

Highways Connections

I think it is now clear that the likelihood of any significant road drains discharging surface water into the sewer is remote. This has been something of a red herring and the water entering the sewer is from historical house connections.

Combined sewer

Anglian Water have now accepted that the sewer in Fressingfield is a combined system. You may remember that their previous position was that the sewer was a foul sewer only and as such the overwhelming of the sewer by surface water was not Anglian Water’s responsibility as the water should not be there! This change of definition is important as Anglian Water must now assume responsibility for the surface water in their sewerage and not only focus on dry flow capacity issues when commenting on major developments.

Planning Application DC/19/05740

You may remember that the Developer, at his own cost has worked with Anglian Water to develop a scheme to reduce pressure on the sewerage to be in a position to justify his two Applications being approved. I key element of the proposed amelioration is the temporary ” storing” of sewage at times of peak overload and gradually releasing the sewage into the network when the peak has passed. Mr . Simpson has confirmed that such storage is for a period of up to 10 hours. This is a figure Anglian Water have repeated on a number of occasions, although the Developer’s Agents stated this could be much longer. This is an important point as a number of incidents have been over 10 hours and one on the 20 December 2019 lasted for over 27 hours.

Statutory Obligations

We have been pushing the issue that Anglian Water have a statutory duty under the Water Act to effectively drain an area. Mr. Simpson makes a fair point that that this is not an absolute duty to guarantee that a sewer never floods, but I would argue that for the sewer to discharge 10 times in a period of under two years is a serious failing in a duty of care.

I did feel that there has been some positive movement from Anglian Water. I was disappointed that Mr. Simpson has not commented on my proposal that in response to Planning Applications in Fressingfield a caveat be placed on the sewage capacity differentiating between dry flow capacity and the capacity issues at times of heavy rainfall.

Kind regards,

John”

Correspondence between SAFE and CEO of Anglian Water

Letter from SAFE

Dear Peter,

Thank you for your response to my previous email shown below.

One finds it difficult to complain at this difficult National time, but this response does not address a number of problems. In my email I posed a number of questions which were not answered.

The data that you supplied seems to be going around in circles with no definitive outcome. Unfortunately you have not provided any information that I was not already aware of. Particularly we are well aware of the surface water hierarchy and the difficulties of surface water drainage in Fressingfield.

To put my position in context. I am the Chairman of SAFE ( Supporters Against Fressingfield Expansion) we have been monitoring sewage egress and flooding in Fressingfield for many years. We are in regular communication with the various departments at MSDC as well as a number of Agencies dealing with water and sewage. My wife and I both sit on the Parish Council Working Party and at Planning meetings we are an interested party. We have our own web site   http://fressingfieldhousing.org

Over the years we have met with a large number of Anglian Water managers. We probably have more background information on these matters than anyone else in the village and as such we would like to be kept informed of any developments on this subject.

Dealing now with your response. You report the CCTV survey at the beginning of the year. In 2018 you also carried out CCTV surveys on part of the network. On both occasions my understanding is that no structural defects were found and there was no ingress of surface water into the system through fractures or defects.

Anglian Water believes that sewer flooding is caused by surface water entering the network and this takes place because of-

  1. Residents’ lifting their manhole covers to prevent surface water flooding their properties . –  We are only aware of two locations where this has happened. This is at the Swan Public House where the Landlord needs to remove surface water in danger of flooding his kitchen. We brought this to your notice inOctober 2018and indeed we have a video which was sent to Nigel Minter at the time. We are not sure where the water comes from. If this is of concern to you have you attempted to resolve this with the other relevant Agencies during last 18 months.

The other location we are aware of is in New Street where there was minor flooding which we believe has now been corrected by Highways.

Do you know of any other locations where this occurs?

  1. Multiple highways drainage connections to the foul sewer.  The Parish Council has particularly mentioned this. From your discussions with the Environment Agency I understand that this is not a cause of ingress into your system . Is this true? If so it can be disregarded.
  2. Connections of surface water drains to the foul sewer  from buildings in the village. We understand that Anglian Water charges 341 properties in Fressingfield for the disposal of surface water via the foul sewer so this seems to be a very significant factor.   You  facilitated a meeting  with relevant parties and  your representatives in October 2018. This meeting was minuted.  Copies were sent to those attending, they were placed on the SAFE web site and were sent to you in 2018. At that time we told these were primarily historical connections which were not illegal and they would be difficult to identify. We are not aware of any progress with regard to these connections during the last 18 months. Perhaps you would correct me if this is incorrect.

We  were told  that  the only way to identify which houses had surface water connections to the foul sewer would be through individual  dye tests, but there was neither the funding or powers to do this.

The recent investigations show nothing new since October 2018 .No progress has been made in resolving the problem and indeed the sewage egress has become more frequent and severe. When responding to Planning Applications Anglian Water talk only of the dry capacity flows . They do not make Applicants/LPA  aware of the severe problems in the village and no caveats are attached. You are obviously aware that there are times when your system is ” overwhelmed” and the sewage from more houses at these times will exacerbate the situation. At a recent meeting of the Parish Group Hannah Wilson asked me what I would  do if I were in her position. The suggestion of a caveat was made.

Dealing with a recent Planning Application ( DC/19/05740) Anglian Water provided a Report at the request of Create Consulting Ltd. This was written by Richard Lyon. SAFE has many concerns over this proposal. It needs a far more critical  assessment.  Have many of these schemes been  developed in the UK? Where are they sited? What volumes can they cope with and for how long? What is their reliability ?  What is the likelihood of the sewage in the Low Road sewer backing up into  the holding chamber and that itself overflowing into a more densely part of the village such as New Street?

If the system works then effective remedial work should be undertaken now  and funded by Anglian Water under their statutory duty and not by a Developer in exchange for more housing. The Department of Communities and Local Government have made it  clear to me that your Company has a statutory obligation to drain an area including surface water run- off from overloaded sewers.

I look forward to your response addressing the points raised in this letter.

Kind regards,

John

Response from CEO Anglian Water:

Dear Mr Castro

Thank you for your patience while we reviewed the issues you have raised.

I can fully understand why the landlord of the Swan Public House takes the action reported to protect his premises from flooding. This is, as you are aware, a private manhole and the surface water entering the system by this route will only be exacerbating downstream flooding issues. We have not identified if there are any other connections upstream or downstream of this manhole as it is frequently surcharged and this manhole and pipe is not an Anglian Water asset. We are also not clear regarding the source of water entering this pipe apart from that there are some known highway drainage connections. We have drawn this situation to the attention of the Lead Local Flood Authority and Highways Agency. In respect of New Street, our understanding is that Highways have undertaken investigations but have not undertaken any corrective works. We are not aware of any other locations where this occurs. Irrespective of ownership of this asset we are prepared to support further investigations as part of a multi-agency response to the management of surface water in this catchment.

For clarity, we have not yet identified any direct highway drainage connections into our sewerage system.

The sewerage system in Fressingfield is actually a combined system in that it takes both foul and surface drainage.  Any of our customers who are recorded as having a surface connection can challenge this if they believe no actual connection exists and we would be pleased to review any such requests.  A  property level survey would be required to determine if individual properties are, or are not, connected to the sewerage system. We would be prepared to consider undertaking such surveys as part of a multi-agency response to the flooding issues in Fressingfield and I would hope that such surveys could be undertaken in the spirit of goodwill rather than reliance on powers of entry. Such surveys could also consider if there were other points of discharge for surface water as an alternative to the sewerage network.

In respect of Planning Application (DC/19/05740) and active or real time control systems, as identified in the planning report, these are not new technologies; they are currently in widespread use across our networks. The volume is based on the receiving network and acceptable limits of storing foul water in the network.  We seek to avoid retaining foul water for more than 10 hours in a network to avoid septicity causing noxious gas and odours. The storage would be sited in a position where the controlling valve is at a higher level than the surcharge level in the network so it could not back flow into the storage volume. However, we must stress that Anglian Water’s position with regard to the proposed developments has not changed. As we have previously advised, a connection to the nearest accessible point on the foul water sewerage is acceptable. In response to local concerns raised over the surcharge risk posed by surface water flows entering this foul water only sewerage system, the developer has requested that we consider the proposed strategy as an alternative approach. As this strategy has been devised at the developer’s request, the proposed diversion and attenuation facility would be entirely at the developer’s cost.

Regarding Our Statutory Obligation, Section 94 of the Water Industry Act 1991 places a general duty on us to empty public sewers in our area. It is not an absolute duty to ensure that no sewer ever floods and it is not a duty that is directly enforceable by individuals/corporate bodies against us. All sewerage companies are entrusted with a discretion as to where to apply their funding for improving sewers, so as to ensure that the money is spent as efficiently and effectively as possible. As a matter of law, in certain circumstances, a developer may be obliged to pay for works to a sewer that are necessary to facilitate its development.

I can readily appreciate your concerns regarding flooding and assure you that we are fully prepared to support any further multi agency investigations going forward. I do not believe this is a matter for Anglian Water to solve alone and would be best resolved as part of a multi-agency response.  We will again make contact with Suffolk County Council to discuss how we move matters forward in this respect.

Yours sincerely

Peter Simpson

Anglian Water

SAFE is concerned that the position of Anglian Water to accept Planning Applications, without adding caveats, will increase the incidents of flooding and sewage egress which is already unacceptable.

Anglian Water is a commercial enterprise and, therefore, has an interest in increasing their customer base. We have been in contact with Agencies with responsibilities for flood management and governance and all agree that the position is unacceptable.

Local Planning Authority – Mid Suffolk District Council as the lead player in the decision making process took an extremely robust view over  the capacity of the sewerage to accommodate more houses. The LPA Planning Officer Stated in his report to the Inspector ” It ( the village) does not need to accept medieval drainage problems merely to facilitate a few more speculative houses”. The LPA position could not have been better argued  and at the time of the initial hearing their case was supported by photographic evidence. The Planning Officer was in no doubt that the extra houses at Post Mill would exacerbate the serious problems with the sewerage. The Application was unanimously rejected at Committee by Members.

Environment Agency

The Environment Agency have been  concerned over the egress from the sewer polluting an adjacent stream which discharges ultimately into the River Waveney. ( see attached photo of sewer discharging into the Beck) They are holding meetings with Anglian Water over this breach.  On 10th Feb 2020 the Agency wrote ” Agree that unpermitted discharges are not acceptable.”

We are dealing with these incidents as an unpermitted water discharge activity which is an offence under regulation 38 of the Environment Permitting Regulations 2016″.

Local MP – Dr Dan Poulter 

The local MP has been aware of the issue for some time. He wrote on 30th January 2020 ” there seems to be an ongoing problem with the foul sewer flooding and building more houses certainly will not help the problem.” 

Anglian Water

 Anglian Water clearly  recognise that there is a problem with the ingress of surface water into the foul sewer. In a  letter of 14th November 2019 Peter Simpson, CEO of Anglian Water wrote “Unfortunately, our foul sewer is being overwhelmed by other water sources.”  As indicated above this problem has been known for many years and no solutions have been proposed.  

Ofwat

 Ofwat clearly see the LPA as the key decision maker on these issues. LPA clearly saw the sewage issue as a significant plank of their submission for rejection of the Post Mill Application. Why the Inspector chose to ignore the LPA is not  stated and runs contrary to the requirements for transparency in the decision making process. See – Baroness Cumberledge v Secretary of State & DLA Delivery Limited.

Ofwat wrote on 30th January 2020  ” In terms of the flooding and surface water  infiltration to the sewer. I will pick this issue up with Anglian Water and ask them to update us on the issue and solutions they have planned.”  We await the outcome of these discussions.

Suffolk County Council

The lead at SCC Flooding and Water Management has personally been heavily involved in this issue and has confirmed that flooding by sewage egress and not solely by surface water is within his remit. He has accepted that the problem with the capacity of the sewer is due to the ingress of surface water.

Director of Public Health 

Dr. Abdul Razaq the Director of Public Health and Protection at Suffolk County Council wrote on 11 May 2018 “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. ”  ” I have informed Public Health England of the situation although they are advisory only and have no legal powers” He then went on to give advice on protective measures to be taken if individuals are subjected to the sewage. 

Department of Communities and Local Government

The Department of Communities and Local Government wrote on 9th January 2020 ” Water and Sewerage Companies  are under a statutory duty under S94 of the Water Industry Act 1991to effectively drain an area and should be mindful of this duty in any response.” ( to Planning Applications) .

In Policy terms The Department also clearly confirmed that paragraph 163 of the NPPF is relevant to all sources of flooding ” Including surface water run- off and over loaded sewers and drainage systems.”

*********

SAFE has now consulted a large number of agencies and all agree that more houses will increase the likelihood of sewage egress and flooding.

J.C.

10 March 2020 


Planning Application for Weybread

A Planning Application has now been submitted for the old chicken factory. The Application is for 80 houses.

This will, of course, have implications for Fressingfield, especially the roads, surgery, and school.”


Major Building Applications for Fressingfield.

Three new Planning Applications for Fressingfield were submitted over the holiday period.

At Post Mill ( DC/19/05956) – there is no planning gain, just another 18 houses.

Click here to access the Application

At John Shepherd Road ( DC /19/05740) – an Application has been made for 27 houses to the rear of John Shepherd Road.

Click here to access the Application.

At Stradbroke Road ( DC/19/05741) – Application has been made for 21 houses together with the relocation of the village shop from New Street. The site of the Stradbroke Road development is immediately opposite the road leading to the primary school.

Click here to access the Application

These three Applications totals another 66 houses. We already have 52 with Planning Permission, but not yet built, making a total of 117 possible new houses putting pressure on our already overstretched infra structure.

Consultation on these three Applications has now closed.


SAFE ( Supporters Against Fressingfield Expansion)- Comments on Proposed Mitigation of Sewage Egress in Fressingfield

Anglian Water has provided a report at the request of Create Consulting Ltd acting on behalf of George Brown to mitigate sewage egress related to the two proposed developments in Fressingfield. A copy of the Anglian Water Report ( PPE-0040559) can be found on the MSDC Planning Portal under appendix B  of the drainage Strategy on Application DC/19/05740. 

We are concerned at  the involvement of Anglian Water in these proposals. They are a commercial company with financial interests in more properties being connected to their system. Herein lies a possible conflict of interest.

The scheme was presented at Fressingfield Parish Council by the Developers on 7th January 2020. A full discussion was held and SAFE argued against the proposals as being inadequate and unproven. The Application was not supported by the Parish Council.

SAFE Repost

Fressingfield has only a foul sewer. Surface water is conducted through a series of conduits and ditches and in most cases to the Beck. I am only concerned here with the foul sewage from the proposed developments as I assume the surface water will be managed using the standard hierarchical system and will not enter the foul sewer.

Sewage egress  is long standing , a health hazard, unpleasant and worsening problem . Human sewage and sanitary products  are dispersed over the road, walkways and gardens as well as polluting the water course. This has happened 9 times in 2 years and 5 of these have been since October 1st 2019.

It is because  ” our foul sewer is being overwhelmed by other water sources. ” ( CEO Anglian Water 14 Nov ember 2019)

It was previously suggested that this was due to the ingress of surface water from houses with historical connections. More recently Anglian Water informed the Environment Agency that multiple Highways connections were also important. 

“The removal of surface water flows from the FW sewer network is a complex and iterative process that will require commitments from other agencies and property owners. It is often a prolonged process, taking several years to identify and remove the most prominent pathways.” ( Richard Lyons Anglian Water 13.3 2019)

There is NO obvious deliverable solution . Therefore egress of sewage in Low Road will continue. (joint meeting with Anglian Water October 2018 – Hannah Wilson)

“A mitigation solution has been devised to ensure new development does not significantly increase flood risk when the FW sewer network is surcharged due to inundation with surface water flows that enter the network during severe rainfall events.” ( Richard Lyons wrote 3/2019 ) By implication this means new development does increase flood risk at times. A position that SAFE has stated many times

The same report clearly states ” should the anticipated flow rates increase due to a change in the development composition, we may need to evaluate an alternative connection  point or methods for controlling the discharge rate. “Again indicating that more houses increase the risk of foul sewage egress.

At a meeting of the Sewerage and Drainage Group, set up by the Parish Council,  held on 10th January 2020 Hannah Wilson from Anglian Water stated that the mitigation proposals from the Developer were not necessary  and need not be proposed as there was already sufficient “dry flow” capacity in the sewerage to accommodate more development. If this is true the proposals and the concomitant development by Brown is unnecessary, but if it is not then it supports the SAFE position that potential developers should always be made aware of the shortcomings of the sewerage and  further development not approved until a sustainable and proven solution to the problem is found. 

Mitigation Proposal 

The new system of sensor signals  activates a foul sewer valve. When the sewerage is over loaded the system is designed to hold back sewage for up to 10 hours from homes in the John Shepherd area. This will stop the flow from 105 homes ( which includes the 27 new homes) increased proximal storage for temporary  holding of sewage would be required. The effect of holding back proximal sewage is unknown. Will there be odours or back flow or both?

At least four of the recent surcharging events have lasted more than 10 hours ( there may be more , but darkness prevented examination) The proposed 10 hour valve attenuation  would be ineffective in the majority of cases.

Once  the mitigation measures became public we have monitored timings. The surcharge on 20/12/19 lasted in excess of 27 hours  and the pumps had been working efficiently for 15 hours. Yet the chamber outside the Old Vicarage was full after 36 hours. A 10 hour cut off will be useless and not prevent the problem. Geoff Everett ( work order 57014585 ) checked the sewerage and nearby pumping station and found them to be working well but overwhelmed due to high flows. 

It is assumed that these are desk top analysis . The accuracy of such analysis is notoriously unreliable ( as evidenced , for example , by  the Imperial College analysis of the current virus pandemic .) At a meeting held in October 2018 , Luke Crump ( from Anglian Water) confirmed that without knowing the amount of rain water entering the system it was impossible to know the starting point of capacity. The model does not factor in exceptional storm events.

 “The solution will also provide the facility to gather more accurate  information on sewer performance that will enable further investigation to the causes of the surcharge condition”   (Richard Lyons 3/19) as such it must still be regarded as experimental with no guarantee of success. I would suggest that the existing problems are resolved PRIOR to any additional development.

Financing

This Developer is suggesting that this unproven and flawed mitigation plan is financed by  the approval of more house building, at a profit to them and the possibility of more future Applications.   In any event more development goes against the approved NDP and takes no account of the other deficiencies of sustainable development in Fressingfield.

On 9th January 2020 the Department of Communities and Local Government wrote stating the following.    

“We are quite clear that the policy approach of assessing and managing flood risk applies to all sources of flooding, including from surface a water run off and overloaded sewers and drainage systems. The Framework expects local Planning Authorities to plan for the development and infrastructure required in their area , including infrastructure of waste water and utilities.. They should work with other providers , such as sewerage companies, to assess  the quality and capacity of infrastructure and its ability to meet forecast demands. Water and Sewerage Companies ( WaSc) are under a statutory duty under S 94 of the Water Industry Act to ” effectively drain an area” and should be mindful of this duty in any response. If a WaSc fails to undertake any aspect of their statutory duty then the independent economic regulator , OFWAT , has the power to take action.”

Clearly we do not need further building to correct an existing unacceptable drainage infrastructure. Proper drainage  would seem to be the responsibility of Anglian Water.

Housing Numbers

The mitigation proposal diverts sewage from 78 existing houses in the John Shepherd area and makes allowance for the 27 proposed to be built at John Shepherd  on onto an attenuated system activated at times of overload and temporally “stores” the sewage at the time of peak flow . 

The mitigation proposals consider only  the impact of the two proposed developments at Stradbroke Road  (21 Houses )and John Shepherd (27 houses) . This is understandable as the developer has no interest in any applications other than his own. BUT as a village we are concerned with  the overall cumulative impact of developments on the sewerage.  The 53 houses approved , but not yet built plus the Post Mill Application ( 18 houses ) and the two Applications mentioned above  (48 houses) result in a total of 119 houses. The mitigation proposal puts a total of 105 houses on the attenuated system , including the proposed  27 at John Shepherd , this would result in suggested ” betterment ” for 78 houses . ( 105-27). This ignores all the other developments and approvals and in fact under this scenario an additional 14 houses will be added to sewerage outside any “betterment.” 

Weybread

A further consideration relates to the Weybread  water recycling centre ( WRC). The Environment Agency ( 10th February 2020) reports that the WRC has “some capacity” and notes that the Draft Local Plan indicates growth of 60 houses for Fressingfield and this has recently been endorsed by the NDP. In fact permission has already been granted for 53 of these houses plus a new larger Baptist Chapel and Scout Hut. The spare capacity has already been taken up. The  Application for the “chicken factory ” site at Weybread has been submitted for 80 houses. As this is a brown field site following Government policy guidance it is likely to be approved in some form . The sewage from this site will also utilise the WRC.

In Summary

The concept of bargaining more development for the installation of a sewerage mitigation proposal of dubious reliability is contrary to the wishes of the vast majority of  people in the village. This is especially so when there are clearly defined responsibilities for dealing with sewage egress and when the village has expressed its views for development through the Neighbourhood Plan .

JC.    

28 March 2020 


SAFE response to Major Application DC/19/05956- Post Mill Lane

To view this as a PDF, click here

SAFE strongly opposes this Application

This is an Application for 18 houses as an extension to the  existing Post Mill development giving an urban housing estate of 39 houses. No Planning Gain is  proposed.

Policy Background

Since November 2018 when the original Post Mill  Application was heard a number of significant policy changes have come about.

*MSDC have now confirmed a minimum 5 year housing land supply. This is important as without this number a number of Planning Policies can be ignored.

*The Joint Draft Local Plan has been consulted upon and whilst not yet adopted it does carry some weight. The Plan has corrected the error of our being a ” core ” village . We are now correctly identified as an “Hinterland” village capable of sustaining limited development. Currently there is no timetable for the adoption of the Plan.

*The Neighbourhood Development Plan is due to go to referendum in late January/ early February 2020. Whilst not yet adopted it does carry some weight. The NDP does not identify Post Mill as a potential development site. To include this site would push the agreed housing ceiling, of 60 houses over the Plan period, well over target. To support this Application would undermine the validity of the NDP.

* The site is not within the Settlement Boundary. Policy CS2 does carry some weight and should be applicable to Post  Mill..

*Any potential development in Weybread should be factored in as  it is integral to the infrastructure in Fressingfield. This would impact on highways, the medical centre, the school and pollution.

Post Mill Appeal

In November 2018 the Post Mill Application for 24 houses was not approved by MSDC for the following reasons

1. Outside the Settlement Boundary.

2. Contrary to Local Planning Policy

3. Would result in localised flooding

4. Would impact on a listed building.

The decision was appealed by the Developer. The Appeal was overruled and costs were not awarded. The plank of  Inspector’s argument was the visual impact of the proposed development of Ladymeade Cottage, a listed building. In this Application the Developer has partially addressed this issue by removing all buildings directly behind Ladymeade and compressing 18 houses with very small gardens into a tight space. Whilst the development does not impede upon Ladymeade it does compromise the setting of both Ladymede and an adjacent Listed Building.

The Inspector did not give weight to the  flooding /sewerage issue because Anglian Water raised no objection. Critically, since the time of the Inspector’s Report Anglian have changed their  position. Whilst accepting that there is capacity within the sewerage for normal dry flows at the time of persistent rainfall the sewerage is flooded. The CEO of Anglian Water wrote on 14th November 2019 ” Our foul sewer is being overwhelmed by other water sources.” It is significant that the Applicant is reliant on Preplanning advice from Anglian Water on the original scheme ( para7.4.2 ) this has not been updated. It is also significant that the developer for the John Shepherd and Stradbroke Road sites is proposing mitigation measures to reduce the capacity within the sewer at times of heavy rainfall to allow extra capacity for surface water. For the developer of Post Mill to  ignore this and rely on an outdated Appeal decision is not sensible.

SAFE believe that this Application clearly runs contrary to paragraph 163 of the NPPF and will increase the risk of flooding elsewhere.

General

The majority of the supporting reports and data collection is seriously out of date and relates to the previous Application. Decisions cannot be reached on  information which is no longer valid.

Highways

The cumulative impact of the this and the proposed two developments would increase the number of cars in the village by approximately 100 cars.

Whilst the Transport Study is dated March 2019 all of the data relates back to the previous scheme as do the drawings. The correspondence log between SCC highways and  the developer ends abruptly on 13/11/18 – ten days before the initial hearing.

In attempting to present the development as being close to many local amenities numerous bus stops and a post box are cited. As there are no public buses the proximity to bus stops is a complete irrelevance.

The increased traffic will impact significantly on New Street as New Street is the only way in and out for the Post Mill residents. We have produced papers on congestion and pinch points as well as the large number of unreported and reported accidents  fressingfieldhousing.org    New Street is of particular concern as it is at the centre of the village.  The War Memorial is another worrying junction being a four way junction. It is just statistically untrue to state that the increase in the number of cars will not increase the number of accidents. If you have more cars statistically there will be more accidents. None of the proposals within the transport document meet the requirement for green and sustainable transport. Policy T 10 is of relevance .

Pedestrian safety 

The highways report does not examine pedestrian trip rates either now or projected into the future. The Report does state that short sections of 4 pedestrian routes are ” unsafe” then does proposes almost nothing in mitigation  ( para 2.6.4.)

On Road Parking 

Throughout the area many roads have no walkways and on street parking is very common. The Medical Centre, shop, and Anglican Church all have insufficient “off road ” parking. With an increase in population and increased use of these venues there will be more parking on very narrow streets. Parking for the Anglian Church is not limited to Sundays because of bell ringing , meetings and choir practice . There is permanent on street parking on Church Hill as very few houses have off street parking this is very narrow and there are no footways in this area .

The entrance to Post Mill is a particular problem as increasing numbers of cars park in this area as overspills from the Medical Centre

Local Employment

There 58 whole time equivalent posts in the village. ( Total population 1021) Part time work is available at the shop and Fox and Goose. Full time posts are at the surgery and School, although most of these full time personnel choose to live outside the village. CP Davidson, the main employer is based outside the village. The vast majority of villagers leave the village by car to go to work in neighbouring towns. There are no cycle lanes and the roads are narrow and overcrowded. Some people commute to London, therefore driving to the station at Diss.

Medical Care

The small amount of spare capacity at the surgery will be taken up by the residents of the 51 new houses approved , but not yet built. Waiting times for consultations have already significantly increased and this will get worse. Parking at the surgery is already inadequate and more patients will result in more overspill parking  in New Street. There is no space to expand the car park because of adjacent recent house building.

A new medical centre, providing a full range of services is professionally priced at £12 million. There is no funding available for either a rebuild or enlargement  ( which would be physically difficult). The only alternative would be funding by the developer.

Education

One of the major planks of the Applicants submission is the support from the School Governors in needing the Post Mill Development to support pupil numbers at the school. Whilst SCC have not commented on this Application in response to the proposed development at  John Shepherd Suffolk County Council wrote on 20th December 2019 “The existing primary is at capacity and it is clear that the site proposal will add to challenges in terms of adding capacity.” The viability of the school is therefore not an issue.

There is no local secondary school. School Buses or private cars are the only means of getting to the secondary school.

Affordable Housing

A perceived major advantage of the Application is the inclusion of 6 affordable homes. Currently there are 11 families on the local waiting list these can be accommodated in the affordable home provision within the developments approved, but not yet built. Further Affordable housing is surplus to need in the village.

Green Credentials

There will be more residents all with cars as realistically there is no alternative travel in Fressingfield. This will mean more pollution and certainly is contrary to all relevant Guidance

Heritage

The proposal is contrary to Policy HB1 of the adopted Local Plan (1998) which states that the Council places a high priority on protecting the character and appearance of buildings of architectural  and historic interest and that attention will be given to protecting the settings of listed buildings. This site is designated as “countryside ” and the proposed development will further erode the villages connection to that countryside. Whilst no longer impacting directly on Ladymeade .

The view from Harleston Hill will be compromised  as the Post Mill housing estate of 39 houses will be visible in winter. This vista is protected under the NDP.

Flooding and Sewage Egress

Flooding and sewage egress are very serious issues in Fressingfield and of great concern to villagers. They affect the quality of life and create health issues., which have been brought to the attention of Public Health England by Suffolk’s Director of Public Health.

There are two discrete, but linked issues. Firstly surface water flooding and secondly the egress of sewage onto the highways and into gardens.

Flooding

We believe that significant flooding is underreported. It occurs primarily in Low Road/Cratfield Road, but serious flooding has also occurred in other parts of the village. We know that it occurred four times in five months between 22 December 2017 and 24th April 2018 and twice in 2019 . It is a long standing problem and has occurred over a number of years.   ( see SAFE web site fressingfieldhousing.org  “Low Road historic flooding” where there are representative photos at 20 year intervals )  The problem does not only occur in Winter, but also occurs in Summer ( 12 July 2016) .Flooding is caused by 3 factors- the overtopping of the Beck, the sewer manholes being raised and the excessive surface water running down from the high point of the village to the low point, Low Road. Fressingfield is unique in being surrounded by hills , to the east (Buckingham) west ( Harleston)  north (Church Hill)and south ( Canser) .The soil is heavy clay and impervious . The roads themselves act as conduits bringing water to the low point of the village, eventually entering the Beck . Increased water into the Beck increases the likelihood of overtopping.

With climate change this situation would be expected to worsen..

Sewage Egress

In Low Road, at times of heavy rainfall the sewerage manhole covers lift and raw sewage and sanitary products spill onto the road and into gardens. The contaminated water flows into the Beck to be dissipated further. The reason for this is that surface water is entering the closed foul sewer thereby reducing the functional capacity of the sewer.

This is a very long standing problem. There exists correspondence between the then MP Michael Lord and the CEO of Anglian Water, Peter Bray. The Chief Environmental Health Officer was also involved.

The problem is becoming more common and more severe.  The contamination has been such that Anglian Water have had to provide teams to clean up the debris. Sewage egress has occurred 9 times in the last 2 years.

In May 2018 Dr. Abdul Razaq, the then Director of Public health wrote ” I would agree that the situation relating to sewage  leaks is not acceptable and unpleasant.”

More foul sewage that is discharged into the sewerage the less space there is  for surface water thereby increasing the risk of the manhole covers being elevated.   This development will impact on the sewerage and result in off site flooding. It is significant that the Applicant for John Shepherd and Stradbroke Road recognises this serious issue and has chosen to investigation possible mitigation. The Applicant for Post Mill ignores the problem and falls back on the Appeal Report which has now been superseded with Anglian Water recognising that under certain circumstances the sewerage does not have capacity.

*********************************************
This objection from SAFE gives many reasons why further significant development should not occur in Fressingfield, primarily because of lack of sustainability.
SAFE   Pam Castro on behalf of SAFE – John Castro, John Kelsall , Tim Eastoe, Elizabeth Manero, Abi Maydon, Paul McCann, Michael Miles.
The Old Vicarage, Fressingfield IP21 5QL

Addendum.

Since this paper was written it has become known that the affordable/ rental houses proposed fail to meet the minimum sizes required under the legislation. The layout and size of the houses would have to be redesigned.”


SAFE Response to Major Application DC/19/05740- John Shepherd Road

To view this as a PDF, click here

SAFE strongly opposes this Application

This is an Application for 27 houses at the rear of the current John Shepherd development. There is no Planning Gain. Included is a large holding pit for surface water.

Policy Background

Since November 2018 when the last major Applications were heard a number of factors have moved in our favour.

*MSDC have now confirmed a minimum 5 year housing land supply. This is important as without this number a number of Planning Policies can be ignored.

*The Joint Draft Local Plan has been consulted upon and whilst not yet adopted it does carry some weight. The Plan has corrected the error of our being a ” core ” village . We are now correctly identified as an “Hinterland” village capable of sustaining limited development. Currently there is no timetable for the adoption of the Plan.

*The Neighbourhood Development Plan is due to go to referendum in late January/ early February 2020. Whilst not yet adopted it does carry some weight. The NDP does not identify John Shepherd as a potential development site. To include this site would push the agreed housing ceiling, of 60 houses over the Plan period, well over target. To support this Application would undermine the validity of the NDP.

* The site is not within the Settlement Boundary.

*Any potential development in Weybread should be factored in as it is integral to the infrastructure in Fressingfield. This would impact on highways, the medical centre, the school and pollution.

General

Both Applications ( John Shepherd Road and Stradbroke Road) use the original reports and public consultation for the schemes considered in 2018. To rely on these reports is unsafe. For example the flood information is over two years out of date . There have been at least two floods notified since that period and several episodes of sewage egress.

Fressingfield is a small rural village of approximately 440 houses of which 350 are in the centre. There are currently 51 houses approved, but not yet built. ( In addition small infill developments have been occurring at around 3 per annum ) The current Applications would increase central housing by 14 %. When the houses not yet built are factored in the increase is 29%.( excluding Weybread)

This will significantly alter the rural ambience of the village setting.

Whilst there can be cumulative effects common to all development in Fressingfield. There are specific issues relating to the John Shepherd proposal.

Highways

The cumulative impact of the two developments would increase the number of cars in the village by approximately 70 cars.

Both developments would increase the strain on Jubilee Corner, especially so if the shop is relocated to Stradbroke Road. Jubilee Corner is a 5 way junction. It is proposed to improve the situation by coloured anti-skid surfacing on the road.

Review of the literature shows there are good studies on reducing skid potential when high friction surfacing ( HFS ) is used. The method of application is critical, there are high costs and have a high carbon footprint as they do need frequent renewal either because of wear or polishing. This has important revenue implications which need to be addressed.

Although skidding is reduced the hard evidence for accident reduction is far less certain. To assess the value of anti-skid surfacing we corresponded with Nick Lloyd, Road Safety Manager at ROSPA and Mr. Howard Robinson, Chief Executive of the Road Safety Treatment Association Ltd.. ( original correspondence is available.)

The following information was obtained- – 50 metres of each road approaching a junction would normally be treated with High Friction Surfacing or anti -skid. It is less effective in snow and ice as the tyre surface has to be in direct contact with the road.

Accident reduction data are incomplete. Work done in the 1960s in London did show a 50% reduction after treatment. However these data were collected before the introduction of ABS and there are no data after their introduction. There are no data on accident reductions on specific risk sites, such as a 5 way junction( because accidents are dealt with by the police and not the Local Authority). As mentioned, the original work was done in London before ABS in an environment very different to the situation in Fressingfield.

In the Irish Government’s Policy Document ( DN-PAV-03024 dated 2017) it reports that high friction surfacing cannot compensate or correct adverse alignment or drainage problems. Accidents are usually the result of multiple factors and HFS may have no influence on the outcomes. The Report states ” It should be noted that the adoption of HFS may encourage drivers to rely on the additional grip and consequently increase speed. The conspicuity of HFS may lead certain drivers exploiting its potential when they are aware that it offers the highest level of skid resistance. This is a constant concern for those with responsibility for highway safety. This is a result of experience at some sites where accidents have increased after treatment.”

Road bumps are also proposed. Many local authorities have been reducing the number of bumps because drivers accelerate each side of the bump. which increases noise pollution. Emergency vehicles and wheelchair users have difficulties with speed bumps, they may also cause water retention on the road and subsequent icing.

The increased traffic will impact on other roads in the village. We have produced papers on congestion and pinch points as well as the large number of unreported and reported accidents fressingfieldhousing.org New Street is of particular concern as it is at the centre of the village. The War Memorial is another worrying junction being a four way junction.

On Road Parking

Throughout the area many roads have no walkways and on street parking is very common. The Medical Centre, shop, and Anglican Church all have insufficient “off road “street parking. With an increase in population and increased use of these venues there will be more parking on very narrow streets. Parking for the Anglian Church is not limited to Sundays because of bell ringing , meetings and choir practice . There is permanent on street parking on Church Hill as very few houses have off street parking this is very narrow and there are no footways in this area .

The analysis of the projected increase in traffic movements makes absolutely no reference to the projected increase in pedestrian activity. This is a serious omission.

Access to John Shepherd

The access to the proposed John Shepherd development is very difficult. Immediately before the entrance there is a cross roads, with a very narrow access on one side from which vehicles frequently reverse as there is insufficient room to turn. There are poor sight lines on both sides and beyond the cross roads there is a sharp bend as the main John Shepherd Road joins Samuel Vince Road. This will become the main thoroughfare into Back Road which in turn joins the VERY busy multi junction at Jubilee Corner. With the projected increase in vehicles the junctions will become untenable . At the opposite end of Back Road speeding down Harleston Hill into Back Road has been a long standing and dangerous problem.

Public Transport

There is NO public transport in Fressingfield . The buses referred to in the Application are school buses which only run in term time and there is no flexibility in the timetable. The bus company operating the school buses has NEVER known a member of the public attempt to use the service.

Local Employment

There is only a tiny amount of local employment. Part time work is available at the shop and Fox and Goose. Full time posts are at the surgery and School, although most of these full time personnel choose to live outside the village. CP Davidson, the main employer is based outside the village. The vast majority of villagers leave the village by car to go to work in neighbouring towns. There are no cycle lanes and the roads are narrow and overcrowded. Some people commute to London, therefore driving to the station at Diss.

Medical Care

The small amount of spare capacity at the surgery will be taken up by the residents of the 51 new houses approved , but not yet built. Waiting times for consultations have already significantly increased and this will get worse. Parking at the surgery is already inadequate and more patients will result in more overspill parking in New Street. There is no space to expand the car park because of adjacent recent house building.

A new medical centre, providing a full range of services is professionally priced at £12 million. There is no funding available for either a rebuild or enlargement ( which would be physically difficult). The only alternative would be funding by the developer.

Education

Mr. Neil McManus from Suffolk County Council on 7th August 2019 reported that the Fressingfield Primary School did not currently have vacancies and projected to be full for the foreseeable future. Funding would have to be found to expand the school.

Affordable Housing

A perceived major advantage of the Application is the inclusion of 9 affordable homes. Currently there are 11 families on the local waiting list these can be accommodated in the affordable home provision within the developments approved, but not yet built. Further Affordable housing is surplus to need in the village.

Green Credentials

There will be more residents all with cars as realistically there is no alternative travel in Fressingfield. This will mean more pollution and certainly is contrary to all relevant Guidance on sustainable transport.

A green field arable site will be lost. Residents living close by report barn owls and a variety of deer in the area. The churchyard is 125 metres away and 250 metres away there are breeding tawny owls, flycatchers, tree creepers, greater spotted and green woodpeckers as well as the more common birds.

Heritage

The proposed development adjoins or faces a comprehensive area of heritage buildings: Richmond House ( grade 11); Knoll House( Grade 11); Coety Barn ( Grade 11*)and the extremely rare, if not unique, Grade 1 stable, which is actually a medieval hall house. This complex of historic houses form an important nucleus of some 58 listed buildings within this rare and rural historic village with architecture of the local vernacular style.

The topography of the village, recognised and safeguarded in the new Neighbourhood Development Plan, means that the proposed development at John Shepherd Road would sit on the brow of the 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 when the trees are not in leaf. The development would harm the character and appearance of the countryside and would have a negative impact on the setting of the listed buildings and would not be sympathetic to local character and history, including the surrounding built environment and landscape setting as advocated in the NPPF.

The proposal is contrary to Policy HB1 of the adopted Local Plan (1998) which states that the Council places a high priority on protecting the character and appearance of buildings of architectural and historic interest and that attention will be given to protecting the settings of listed buildings.

Flooding and Sewage Egress

Flooding and sewage egress are very serious issues in Fressingfield and of great concern to villager. They affect the quality of life and create health issues., which have been brought to the attention of Public Health England by Suffolk’s Director of Public Health.

There are two discrete, but linked issues. Firstly surface water flooding and secondly the egress of sewage onto the highways and into gardens.

Flooding

We believe that significant flooding is underreported. It occurs primarily in Low Road/Cratfield Road, but serious flooding has also occurred in other parts of the village. We know that it occurred four times in five months between 22 December 2017 and 24th April 2018 and twice in 2019 . It is a long standing problem and has occurred over a number of years. ( see SAFE web site fressingfieldhousing.org “Low Road historic flooding” where there are representative photos at 20 year intervals ) The problem does not only occur in Winter, but also occurs in Summer ( 12 July 2016) .Flooding is caused by 3 factors- the overtopping of the Beck, the sewer manholes being raised and the excessive surface water running down from the high point of the village to the low point, Low Road. Fressingfield is unique in being surrounded by hills , to the east (Buckingham) west ( Harleston) north (Church Hill)and south ( Canser) .The soil is heavy clay and impervious . The roads themselves act as conduits bringing water to the low point of the village, eventually entering the Beck . Increased water into the Beck increases the likelihood of overtopping.

With climate change this situation would be expected to worsen. The surface water drainage strategy currently proposed for John Shepherd subject to an Holding Objection.

Sewage Egress

The sewerage was planned in the late 1930s and building was delayed because of the war. The system was completed in 1946.

The design of the system is well documented. Sewage from the current Post Mill development is pumped up hill into New Street and continues to Church Hill , down to Low Road ( 150mm pipe) where it joins at the War Memorial another 150mm pipe coming from the John Shepherd development. The two pipes then join and form a single 225mm pipe which runs 100yrds to the pumping station and continues along the Weybread Straight to the treatment plant in One Eyed Lane.

In Low Road, at times of heavy rainfall the sewerage manhole covers lift and raw sewage and sanitary products spill onto the road and into gardens. The contaminated water flows into the Beck to be dissipated further.

This is a very long standing problem. There exists correspondence between the then MP Michael Lord and the CEO of Anglian Water, Peter Bray. The Chief Environmental Health Officer was also involved.

The problem is becoming more common and more severe. The contamination has been such that Anglian Water have had to provide teams to clean up the debris. Sewage egress has occurred 9 times in the last 2 years.

In May 2018 Dr. Abdul Razaq, the then Director of Public health wrote ” I would agree that the situation relating to sewage leaks is not acceptable and unpleasant.”

The most recent incidents are well documented and the details are relevant to the mitigation measures suggested by Anglian Water.

1st October 2019 – On 30th September Suffolk County Council cleaned out all of the surface water road drains in Low Road. Four manholes were lifted and there was surface water flooding.

6th October 2019- 7 manholes were elevated the egress of sewage started at 9 am and was still flowing when it was dark. This incident was the worst contamination yet seen.

14th November 2019 – The rain was continuous, but not especially heavy. 3 manholes were elevated and the Beck over topped in two places.

27th November 2019 The rain was continuous, but not heavy. 4 manhole covers were elevated . The sewage egress was noted at 7.30am ( but had obviously been running earlier) and was still flowing when it was dark.

20th December 2019- The rain was continuous , but not heavy. 3 manhole covers were elevated. Sewage egress was already heavy at 7.30am and was evident at 5.30pm. Human waste and loo paper were visible on the road and walk ways and was particularly heavy.

Anglian Water Pre- Planning Addendum Report-

Anglian Water has put forward proposals to mitigate the impact of an additional 27 houses as Anglian Water do now concede that more houses result in more sewage which in turn means there is less capacity in the system for surface water. We have concerns over the how robust the proposal for mitigation actually is?

Anglian are confident that the sewerage has capacity for baseline dry weather flows BUT surcharging is caused by the ingress of surface water from direct and indirect connections.

At present ” there is no viable intervention that would enable the FW sewer network to accommodate the volume of water from a water course. Therefore the operation of the FW sewer network is reliant on all connected properties having adequate disposal route for rain water to a water course and having sufficiently robust protection against high river levels draining into the FW drainage.”

It is accepted that removal of surface water egress would take several years. Firstly properties discharging to the FW sewer would need to be identified and secondly alternative disposal would have to be agreed and finally no householder is obliged to re-route their surface water and there would also be a serious issue as to who would fund this!

The report is based on inaccurate data. Quite correctly Anglian Water have looked at the cumulative impact of both the John Shepherd Application and the Stradbroke Road Application. They have assumed Stradbroke Road to be 9 houses . The Application is for 21 an additional 12 houses. The report clearly states ” should the anticipated flow rates increased due to a change in the development composition, we may need to evaluate an alternative connection point or methods for controlling the discharge rate.” A 33% increase in new housing numbers on the site is significant .

The new system of sensor signals activates a foul sewer valve. When the sewerage is over loaded the system is designed to hold back sewage for up to 10 hours from homes in the John Shepherd area. This will stop the flow from 105 homes ( which includes the 27 new homes). Increased proximal storage for the temporary holding of sewage would be required. Herein are two problems. Will the attenuated flow for 10 hours be sufficient? At least three out of the surcharging events have lasted more than 10 hours.( there may be more, but darkness prevented examination.) The proposed 10 hour valve closure would be ineffective in the majority of cases. It is acknowledged that additional sewerage capacity is required. No evidence is produced that guarantees that the problem will not be pushed up stream. In times of normal in put, flow maybe slowed by the larger capacity and cause odour.

Anglian Water recognise that the proposal is designed ” to ensure that new development does not significantly increase flood risk when the FW sewer network is surcharged”. This statement implies that there is in fact a risk.

We assume that these are primarily desk top analyses and as such can be inaccurate. Our understanding is that accuracy cannot be certain without knowing the volume of ingress and it is difficult to allow for the severity of weather conditions ” the solution will also provide the facility to gather more accurate information on sewer performance that will  enable further investigation to the causes of surcharge condition” as such it must still be regarded as experimental with no guarantee of success. We would suggest that the existing problems are resolved PRIOR to any additional development.

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This objection from SAFE gives many reasons why further significant development should not occur in Fressingfield, primarily because of lack of sustainability.

SAFE John Castro on behalf of SAFE – John Kelsall Pam Castro, Tim Eastoe, Elizabeth Manero, Abi Maydon, Paul McCann, Michael Miles.

The Old Vicarage, Fressingfield IP21 5QL


SAFE Response to Major Application DC/19/05741 – Stradbroke Road.

To view this as a PDF, click here

Dear Mr Pearce,

On behalf of SAFE ( Supporters Against Further Expansion ) I wish to strongly object to the above planning application for Stradbroke Road, Fressingfield.

As far as we are concerned the basic guidance as to the building in an hinterland village has not changed and there can be no reason to approve this development or indeed Applications DC/19/05740 and DC/19/05956 as they fly in the face of published national and local policies.

GOVERNMENT POLICY
‘ We will focus housebuilding 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.’

MSDC HOUSING POLICY
‘The Council will 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.

MSDC REVISED LOCAL DEVELOPMENT PLAN
As this document nears acceptance Fressingfield, rightly, has been downgraded to an hinterland village. This means that its new housing contribution has been reduced and there is an expectation of some 5/6 houses a year. As we already have 51 new builds agreed by MSDC but not yet built there is absolutely no requirement for new agreements for the next ten years.

FRESSINGFIELD NEIGHBOURHOOD DEVELOPMENT PLAN
Fressingfield’s NDP has been approved by the inspector and awaits ratification by the villagers ( something which will happen!). It confirms a build of 60 houses maximum over the next ten years which includes the 51 already in the pipeline. It does not identify STRADBROKE ROAD as a potential site for development.
IF ALL THE ABOVE CARRY ANY WEIGHT AT ALL (AS THEY CERTAINLY DO) then this proposed development must be refused. Not to do so would contradict all presently held policies and soon to be implemented ones, both local and national.
OTHER  FACTORS

SUSTAINABILITY ( or lack of it!)

The village is many miles from the nearest transport hub let alone A road. The roads into and out from the village are, on most cases, winding and narrow. The nearest railway station is in Diss, 10 miles away. In the centre of the village roads are narrow, congested and ,in large parts, have no pavement.
There are NO regular bus services, the last one was discontinued last year. There are two school buses operating only in Term time and therefore useless to, and totally unused by, the general public. (Safe guarding of children regulations would prohibit such a mix in any case.)
There are 58 f/t equivalent jobs in the village. ( I carried out a comprehensive survey last year). Nearly half of these require a Degree qualification i.e. doctors, nurses and teachers. An influx of people to this new development would create a massive, new carbon footprint as they travelled distances to work. This is totally against government and MSDC policies.
There are hardly any services in the village. A village shop with one till cannot be described as a super store ( more on the store later). There is a Primary School, surgery, three churches, a public house and a restaurant. The school is full ( Suffolk C.C. declaration in August 2019) and the surgery under increasing pressure with longer waiting times and on street parking problems at busy times. Amenities are limited to two tennis courts, a bowling green and a children’s play area. Villagers have to raise a significant carbon footprint every time they wish to access other, higher order amenities such as cinemas, theatres and sporting activities.

ENVIRONMENTAL HAZARDS

Anglia Water have admitted that there is an extremely serious and totally unacceptable problem with sewage egress in Low Road in Fressingfield. With increasing frequency (5  SINCE OCTOBER 2019) at times of heavy OR prolonged rainfall sewage, including human faeces, sanitary towels, loo paper and other materials are forced out through manhole covers to flood Low Road, adjacent gardens and the beck. Increased housing in Stradbroke Road will exacerbate this problem creating more and more serious AND frequent flooding. Anglia Water have stated that it is likely to take years to solve this problem.  NO COMMUNITY SHOULD BE SUBJECTED TO SUCH DISGUSTING CONDITIONS AND TO ADD TO IT BY ALLOWING YET MORE HOUSING IS TOTALLY UNACCEPTABLE.

Indeed you, Mr Pearce, at the Planning Committee meeting in November 2018 stated, when urging the Committee to refuse all three applications, that until the effect on the village of the approved build of 51 houses had been assessed no further house builds should be agreed. THIS MUST STILL BE THE CASE TO-DAY.

SCHOOL  SAFETY

The opening of School Lane by MSDC Planning Committee to allow the building of houses and a new Baptist Chapel beyond the school means that faster, more frequent and larger vehicles are already destined to drive past the entrance to the school. If the Stradbroke Road development is allowed then there will be more traffic passing the entrance to School lane at school opening and closing times; this in itself creates a greater danger to youngsters but the proposed provision of a new shop presents even greater danger. I was Headmaster of a school in the north where, just across the road from the school was a grocers shop selling sweets. So great was the pull of this shop to youngsters at the end of the day AND at lunch-time that I had to organise staff to patrol at these times and to persuade the owner to limit his opening times. Hungry, impulsive youngsters were a danger to themselves  in their desire to cross the road. Locating a new village shop just across the road from School Lane could well have this same effect. I know that many planning authorities look very carefully at such proposals for this very reason, namely child safety.

SHOP ACCESSIBILITY

The developer believes he has made a clever move by persuading the shop owner to re-locate into the Stradbroke Road. However, what he is proposing will mean that the many elderly shoppers who presently walk to the existing shop will have much further to go and many will have to negotiate Jubilee Corner which is seen as a major danger spot. Coupled with the increased danger to school children I believe that the disadvantages of re-location outweigh the advantages.

IN CONCLUSION

This proposed development, if approved, would fly in the face of all published national and local planning policies, including, importantly, that of MSDC. It would be at odds with your new Local Development Plan and our rapidly emerging Neighbourhood Development Plan. ( a cynic would say that these applications have been made to get in ahead of the revised plans of MSDC and Fressingfield). The grounds for rejecting it on the basis of unsustainability are just as strong as ever and in the case of public health and damage to the environment the argument against the development is MUCH stronger now than it was 14 months ago. The evidence has been piling up (literally!) and a visit to Low Road on a rainy day  would convince anybody of the need to reject applications for yet more house building in the foreseeable future.

Once again, if you take into account the THREE, new proposed developments and add them to the 51 in the pipe-line you come up with a figure of over 110 new houses. This is totally out of proportion to a settlement of this size. There should only be one outcome, a refusal of the application.

Thank you for taking the time to read my submission on behalf of SAFE
Yours sincerely

John Kelsall

On behalf of SAFE ( John Castro, Pam Castro, Elizabeth Manero, John Kelsall, Michael Miles, Abi Maydon, Paul McCann, Tim Eastoe).


How to Access Objection Papers

To look at the objections received to date click of on the links above for John Shepherd, Stradbroke Road and Post Mill. Then click on ” documents ” and click on the objection on the right hand side.

Do check that your own objections are on the web as some seem to have been omitted


ADVANCE NOTICE: Mid Suffolk Planning Committee is likely to consider these three applications in April at the earliest. As happened last time we need a huge turnout of village support at Endeavour House in Ipswich. WATCH THIS SPACE FOR FURTHER DETAILS!


Planning Application DC/19/05548

This is a new Application to build a house adjacent to the Old  Baptist Chapel.
SAFE , as a corporate body, will not be involved as this is a single dwelling. However, individual members are concerned about many aspects of this Application, particularly the aesthetics and practicalities.

The building is inappropriate to its setting, crammed into a small space, and will add more sewage into the Low Road sewerage. It is also one of the very few green spaces in the central area of the village.

SAFE Members will register their individual objections and you can do the same if you wish by contacting planningyellow@baberghmidsuffolk.gov.uk

The current consultation runs to 25th February 2020. It may well be prolonged so watch this space.

Click here to access the Application.


Planning Application DC/19/05352

This is an application relating to South View, New Street, Fressingfield, Suffolk   IP21 5PJ

It is to demolish the existing dwelling and to build a large residential house.

SAFE , as a corporate body, will not be involved as this is a single dwelling

Public objections can be registered  in the usual way by contacting planningyellow@babergmidsuffolk.gov.uk

Click here to access the Application


Results of Road Traffic Survey

The Road Traffic Survey has now ended. To view the results and analysis, please click on the link below:

SAFE Fressingfield Road Safety Survey – Results


Correspondence with Dr. Dan Poulter MP.

SAFE have written to Dr Poulter. Click here to view. The correspondence is ongoing and encouraging.


Occurrences of Sewage Egress

Although this is a long standing issue, in recent years we have been recording these and have 11 episodes of sewage egress as follows:

27 December 2017

IMG_0518

12 March 2018

25 March 2018

31 March 2018

IMG_0718

2 April 2018

Low Road 2 April 2018

31 July 2018

1 October 2019

On 1st October we again had flooding in Low Road and also egress of sewage from some manholes.

The surface water flooding occurred despite Suffolk County Council Highways clearing the surface water drains 24 hours beforehand.

At least four manholes in Low Road had egress of sewage and sanitary products. This was spread over the road, into gardens and flowed into the Beck. It continued funtil into the night.

On this occasion the Beck did not over top and the surface water flooding was due to the water flowing from the higher part of the village down Church Hill and Back street and also from the sewer covers.

The next morning Anglian Water sent a clear up team to remove the offending debris. Inspection by them at this time showed that 5 sewer covers had been elevated. Considerable muddy debris was deposited at the Lower end of Church Hill and Low Road. Highways were informed. The incident was reported to the Environment Agency

Representative pictures of the incident are shown below.

6 October 2019

On 6th October 2019 there was further flooding and extensive egress of sewage into Low
Road and adjacent areas. This is only 5 days after the last episode. We understand there was flooding in other parts of the village.

On this occasion egress of sewage started at 9 am and continued until dark. Seven manhole covers were leaking sewage. Contamination with biological and sanitary material was the worst we have seen and was particularly bad opposite the Baptist Chapel, suggesting that that the sewerage is backing up towards the end point near the Old School.

Surface water flows from the upper part of the village with Church Hill and Back Road acting as conduits before mixing with the sewage water and then discharging into the Beck.

This has again been reported to the Environment Agency and Suffolk County Council.

14 November 2019

On Thursday 14th November 2019 there was again sewage flowing out of 2 manhole covers in Low Road.  This is the eighth time this has  happened in under 2 years.  On this occasion there was only moderate rainfall. The sewage flowed into the Beck and was therefore polluting a water course.

We have informed the Environment Agency and Anglian Water, and as a result a field engineer from Anglian Water has visited.”

27 November 2019

On Wednesday 27th November 2019 there was again sewerage egress from manhole covers in Low Road. At least 4 manhole covers were leaking . One of the cover s had been recently repaired and modified because of previous leakages, but his has not cured the problem.

Egress started at 7.30am and continued until dark. Contaminated material was around one cover and flowed along the road. Sewage flowed into the Beck at several points. In the afternoon a team from Anglian Water attended to inspect the problems. They reported that the pumping station was working well .

As with the episode on 14th November  the rain was continuous, but not especially heavy. This is of concern as previously it was believed that sudden torrential heavy downpours were responsible for  overwhelming the sewers, not normal persistent rain.

On this occasion the Beck overtopped in two places, particularly where the Beck enters a culvert.

We immediately  informed Anglian Water  and the Environment Agency of this event and other Agencies subsequently.

This is the fourth time in the last 2 months that sewage egress has occurred in Low Road and is the 8th time in 2 years.

20 December 2019

On Friday 20th December 2019 once again there was severe sewage egress and overflow of the Beck. Three manhole covers lifted. Human waste and loo paper were clearly visible and widely dispersed over the road and walkways. They also flowed into the Beck, so polluting the water course. All of the relevant Agencies were informed.

20 Dec 19 Low Road 2

The sewage egress was not associated with heavy rainfall, but persistent low intensity rain. In view of the mitigation proposed regarding sewage egress we have kept a close observation on the flow times at the manhole in Low Road. Egress of sewage was first noticed at 7.30am. (but may have been occurring much earlier) At 5.30pm it was still flowing and when observed by torch light at 11.00 pm it was still flowing ( a total period in excess of 15.5hours). The next day at 11am there was still discharge from the same sewer despite only minimal short term rain. ( Total 27.5 hours- video verification available).

20 Dec 19 flood 5

Malodorus smell extended up Church Hill as far as the church and up Back Street to the Swan.

20 Dec 19 sewage

On this occasion the Beck overtopped so the contamination was widespread. The flooding occurred from the War Memorial to the Baptist Chapel.

On Saturday 21st December at Team from Claret/Anglian Water came to clean up and investigate. The overflowing chamber was full, the water ammonia level was 3 ( N 0- 10). They reported that the pumping station was working , but was overwhelmed due to high flows. A ” clean up” of three contaminated areas of highway was undertaken. ( job number 57014585)

There have now been 9 episodes of sewage egress in the last 2 years and this is the fifth since 1st October 2019.


Sewage and Drainage Working Group

The Parish Council has set up a working group to focus on the long standing drainage and sewage issues facing the village and to challenge  hold to account the agencies involved to remedy the two interrelated issues of flooding and sewage egress.

Members of the group   are:-

Di Warne ( chair)- Parish Councillor

Alex Brockhurst- Parish Councillor

Andy Roberts- Resident.

John Secker- resident.

John and Pam Castro- residents

The first meeting of the  Group was held on 6th December.


Fressingfield Flooding and Sewage -Action

SAFE has become increasingly concerned with flooding and the egress of foul sewage because of our fragile infrastructure in Fressingfield and the potential impact major developments will have upon it.

After the recent four episodes of sewage egress and flooding in an 8 week period SAFE has been actively communicating with many relevant Agencies. The dialogue continues and many of these are interactive and hopefully will produce some positive results. The agencies involved are:

Anglian Water ( CEO and various departments); Suffolk County Council ( Flood Management , Public Health; Flood Reporting); Mid Suffolk District Council ( Planning, Environmental Health);  Public Health England; The Environment Agency; Suffolk Wildlife; The Water Council.

All of the above have been very helpful and we hope for positive results as the dialogue continues.


Letter sent to Peter Simpson, CEO of Anglian Water

Letter in full below, with meeting notes following. Also available as a PDF by clicking here

Dear Mr. Simpson,

Planning Applications in Fressingfield and the position of Anglian Water

On 4 September 2018 I wrote to you about the sewerage problems in Fressingfield and you very kindly facilitated a meeting with your representatives, LPA and ourselves which took place on 12 October 2018. The meeting was very helpful in allowing me to gain an understanding of the issues, but failed suggest a solution to the problems. ( notes of the meeting attached)

Flooding and sewage are very serious issues in Fressingfield and of great concern to villagers. They affect the quality of life and create health issues, which have been brought to the attention of Public Health England by Suffolk’s Director of Public Health.

There are two discrete but linked issues. Firstly surface water flooding, and secondly the egress of sewage onto the highways and into gardens. The latest incidence of flooding and sewage egress was on 1st October 2019 when 5 sewer covers were elevated. There was sufficient serious contamination for your Company to send a “clean up ” team.

History of Flooding and sewage egress

I recognise that whilst flooding is not the responsibility of Anglian Water it does impact on the sewerage in Fressingfield. We believe significant flooding is under reported. We know that it occurred four times in five months between 22 December 2017 and 24 April 2018. In addition to the recent event. It is a long standing problem and has occurred over a number of years (see SAFE web site fressingfieldhousing.org “Low Road Historical Flooding”) where representative flood pictures are shown at 20 year intervals. This is not only a problem in winter, but also occurs in summer (12 July 2016.) Flooding is caused by 3 factors, the overtopping of the Beck, the excessive surface water running down from the high point to the low point of the village in Low Road and the sewerage manholes being raised.

The sewerage was planned in the late 1930s and building was delayed because of the war and was finally completed in 1946. 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 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 150mm pipe 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.

In Low Road, at times of heavy rainfall the sewerage manhole covers lift and raw sewage and sanitary products go 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 exists correspondence in 1985 between our then MP, Michael Lord and the then Anglian Water CEO Peter Bray. The Chief Environmental Health Officer was also involved. 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.

020418
Sewage overflowing during flooding in Low Road 02/04/18

The problem is becoming more common and more severe. The contamination has been so severe on occasions that Anglian Water has sent a “Clean Up Team “, including the incident which occurred on 1st October 2019. The rain on this occasion was so torrential and the flooding so sudden that water butts would have had no effect on the flooding in the village. The volume of water was so great it would have been impossible to ameliorated the effect.

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 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.

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

At the meeting held last October with your representatives the cause of the sewage egress was finally understood. When there are high volumes the pressure in the pipe coming downhill from the John Shepherd development is greater than the connection from Low Road because of gravity. This results in back pressure on the sewer in Low Road causing the manholes to “pop”. The functional capacity is also unable to cope of times of heavy rainfall for reasons to be discussed.

Detailed investigations by your staff have confirmed 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 . I understand that 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. Your representatives explained that 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. I understand that Anglian Water are not funded to invest in laying “storm pipes” for storm only events.

It seems that the basic capacity of the sewer is satisfactory, but that the functional capacity at times of heavy rainfall is not, because a large amount of capacity is taken up by surface water. At the meeting no solution to this problem was presented. The real issue for the village is that more houses will take up capacity in the sewer leaving less capacity for the surface water making the “tipping point “for egress of sewage lower. I.e. there would be less capacity for surface water than at present. The percentage of sewage in the leaking manhole effluent will also be greater. ie more concentrated

Flooding and the egress of sewage onto the public roads and into private gardens within Fressingfield are serious and unsavoury. These problems will be exacerbated by climate change.

This represents a serious deficiency in the infrastructure in Fressingfield and one, at this point seems incapable of any remedial action. As summed up by the Planning Officer in his report to the Planning Committee on deciding upon Applications 1432/17, 1449/17 and 1648/17, ‘the pollution of parts of the village and the Beck, however occasional, with raw sewage, sanitary products and toilet paper is unacceptable pollution that will only worsen with significant levels of new development connecting to the Fressingfield foul water system. As it becomes increasingly common to experience extreme weather conditions in the UK it seems ridiculous and completely unacceptable to expect local people to endure what at times looks and smells like a medieval living environment.’

Anglian Water ‘s Current Position on Planning Applications in Fressingfield.

There is some confusion in my mind as we have been repeatedly been told there that there is only one sewer in Fressingfield and that Anglian Water’s statutory responsibility relates to the sewerage and have no role in Flood Risk Assessment . In response to Application 3872/16 – Land at School Lane, Anglian Water have approved an attenuated discharge of surface water into an “Anglian Water surface Water sewer. ” This discharge will , we presume ultimately discharge to the Beck . If this is so Anglian Water do have a role in surface water management which is very relevant to flooding issues in Fressingfield.

Recently an Application for 24 houses at Post Mill Lane was unanimously rejected by the Local Planning Authority . A main plank of the Planning Officer’s Report ( as identified above ) centred on the problems around flooding and sewage egress. The Applicant Appealed the decision (App/W3520/W/19/3227159). The Appeal was rejected, but the flooding and sewerage issues formed no part of the grounds for rejection. In Paragraph 30 of his Report the Inspector stated “Anglian Water raises no objections to the proposal subject to a condition requiring compliance with the agreed drainage strategy. This response from the relevant authority confirms that the development would not cause harm to the capacity of the sewer, and I have no reason to take a different view from their professional advice.

I think we have a real paradox here. Your Company is taking a purist view that their sewerage in Fressingfield is fit for purpose and there is capacity within the system, in this case to accommodate a further 24 houses in terms of foul drainage. Undoubtedly this is a point of fact and is true under normal circumstances. The fact that in times of heavy rainfall there is not sufficient capacity is not seen as an issue for your Company as the domestic surface water connections to the foul closed system should not be there.!! The reality of the situation is that the surface water connections (number unknown) are there. There is no mechanism or budget for removing them. The villagers therefore are faced with a real dilemma as Anglian Water, unless they take a policy decision, will continue to approve Applications in Fressingfield in the knowledge that this will increase the incidence of sewage egress. Whilst the Local Planning Authority fully recognised the argument the Inspector did not leaving the village very exposed in terms of future Applications.

I am sure that you appreciate the issues. I think the latest incident on 1 October really highlighted the need for me to do something, hence this letter. The contamination really was unacceptable with sanitary products floating in the flood water along the road and trapped in the manhole covers. I know that your member of staff who came to clean this up next day took a number of photos , which I am sure will confirm that I am not exaggerating . I have a large number of photos and a video of the incident itself should any of your staff wish to see them.

I would be very grateful if you could review your position when responding to Planning Applications in Fressingfield in the light of the arguments presented in this letter. I strongly believe that Applications should only be approved there is local a ” on-site ” facility for treating sewage ie a septic tank or similar and Applications from Fressingfield should be assessed by those who are aware of the conditions that exist in this village.

Yours sincerely,

Dr. John Castro

ADENDUM

Since writing this a further episode of severe egress of sewage and flooding occurred in Low Road/ Cratfield Road. On 6th October2019 egress of sewage started at 9am and was still continuing at dark. Seven manhole covers were leaking sewage and the contamination with biological and sanitary material was the worst we have seen.

Contaminated water flowed back into the Beck to be dissipated further.

Below are some photographs of today’s events.

Notes of an Informal Meeting held on 12th October 2018 to discuss Sewerage Issues with Anglian Water

Present 

From Anglian Water

Luke Crump

Hannah Wilson

Nigel Minter

Grant Tuffs

From MSDC

Lavinia Hadingham

Vincent Pearce

From SAFE

John Kelsall

Elizabeth Manero

John and Pam Castro

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.


Health Precautions After  Sewage Egress.

During episodes of sewage egress in Fressingfield some people, including children, were seen walking in the contaminated water.  On 11 April 2018 the previous Director for Public Health and Protection for Suffolk County Council made the following statement as to what action should be taken following the egress of sewage  :-

  • Keep children and pets away from the flooded areas.
  • Wash children’s hands frequently- particularly after playing outdoors and always before meals.
  • Wear protective clothing such as rubber gloves if you’re cleaning up and cover up 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 your doctor straight away.
  • The Food Standards Agency advises people not to eat any food that has been touched or covered by floodwater or sewage. This includes advice not to eat any produce grown on an allotment or garden that has been flooded.

Flooding in the News

The two floods documented below are reported in the local press.

Diss Express 11 October 2019 – Page 5

East Anglian Daily Times 12 October 2019 – Page 19


Babergh and Mid Suffolk Joint Local Plan. – 

Click here to view . Public Consultation closes on 30th September 2019.

SAFE has produce d a very detailed response – Click here to view


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


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. On the Parish Council minutes of September 2019 it was reported that there was a near accident on the Laxfield road which could have caused injury to a cyclist’

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

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.”


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

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.

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

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

General Implications for Post Mill Development

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

Sewerage & Flooding

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.

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.


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.

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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!?


Draft Mid Suffolk Local Plan.

The above document is now available.

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.

23/06/19


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.


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.

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.

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.


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

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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.