Stowmarket Area Action Plan (AAP) Examination

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1 Stowmarket Area Action Plan (AAP) Examination Main Matters, Issues and Questions Matter 3 - Employment (Appendix) This contains additional information in support of the Hearing Statement and relates to questions: a & b c (a) PPS12 specifies that if other DPDs are produced they should not be used to take the place of the Core Strategy, it is the Core Strategy which should make clear the spatial choices about where development should go. How does this square with the employment allocations of the AAP? (b) Is Mill Lane a strategic site and (c) should alternatives have been considered as part of a review of the CS? a) Clear spatial choices in the Mid Suffolk Core Strategy The Core Strategy text (paragraphs 3.86 to 3.92) describes the criteria for choosing major employment sites for the district as being reasonably close to towns or Key Service Centres with good access to the A14 and A140 major trunk roads. Six broad locations that meet these criteria are identified in paragraph 3.93 and Map 3.2 and distinguished on the map separately to existing site allocations in those locations saved from the Local Plan This is necessary to indicate the clear spatial choices required of a Core Strategy while providing the flexibility to allow site specific allocations to come forward in subsequent DPDs. These broad locations were tested through the LDD examination process and adopted by Mid Suffolk District. The Core Strategy text (paragraph 3.93) further proposes to monitor existing allocated sites in these broad locations on an annual basis and consider them for future growth through expansion, updating and intensification where this option is likely to meet the needs of business with least environmental and social impacts. This plan, monitor and manage approach is formalised in Policy CS11 paragraph 6. In the Council s view the identification of broad locations to meet defined criteria coupled with an intention to review the continuing appropriateness of existing sites in

2 those locations is intended to deliver necessary flexibility to provision within the Core Strategy. This flexibility is offered in CS11 which tries to ensure that sites continue to meet the needs of business whilst minimising environmental and social impacts. It was anticipated that evidence from the West Suffolk ELR would be key; however, this would not be to the exclusion of all other evidence, a view supported by paragraph 4.7 of the RSS which allows the consideration of unspecified additional evidence when preparing LDDs to meet the job targets of RSS Policy E1.. This view of the role of the ELR as an important but not exclusive evidence document was agreed by the cross district, joint working group at the time. There were shared reasons for the stance. Not only does the Mid Suffolk s Core Strategy leave consideration of specific site allocations to future DPDs but other local authorities, who were less advanced in the LDD process, were not prepared to have site allocations in their DPDs pre-determined through the ELR - rather than a proper planning process. This was the reason that employment sites with neither a previous allocation or planning permission were excluded from consideration in the ELR. The Core Strategy CS11 (paragraph 4 and bullet 4) anticipates flexibility extending to the delivery of new employment sites, which as explained above had been excluded from consideration in the Western Suffolk ELR. Policy CS11 provides that consideration of new sites is to be made with regard to the proximity to towns, the need to increase choice and achieve a better balance between employment and housing in the settlement, good access to major transport routes, good access by public transport and a proposed use consistent with the Western Suffolk ELR. In our view the site at Mill Lane, which is in a broad location indicated in the Core Strategy also fulfils the criteria set out in Policy CS11 for the allocation of a new employment site. This allocation is consistent with national policy, regional policy the Core Strategy policy, the ELR and other evidence and does not warrant a review of the Core Strategy? b) Is Mill Lane a strategic site and should alternatives have been considered as part of a review of the CS? Mill Lane is not a strategic site. As explained below this is because national policy PPS4 defers this decision to Regional Policy, the RSS deferred it to the ELRs and the Western Suffolk ELR contained no definition or attribution of strategic to any site. In any case, Mill Lane was excluded from consideration in the ELR, and therefore could never have been designated strategic in the above system. Policy EC2(c) of PPS4 states that it is for Regions either to set criteria or alternatively identify the general locations of strategic sites. There is therefore neither a national definition nor national criteria for identifying strategic employment sites. RSS Policy SS3 identifies Key Centres for Development and Change where there are existing concentrations of development well served by transport nodes as a focus for new development and Bury St Edmunds and Ipswich are both Key Centres. RSS Policy E3 Strategic Employment Sites requires LDDs to provide strategic employment sites (undefined), particularly but not exclusively, at listed regionally strategic sub regions and locations that include the Key centres for development and change. In the adopted RSS it is the general location that is strategic not the site

3 itself. This is because the purpose of designating a site as strategic is to ensure that growth in identified regional or sub-regional strategic locations is not constrained by failure of the planning system to allocate an appropriate site. These sites will be identified in ELRs, which RSS Policy E2 requires to be crossborder in scope. LDDs will respond to the RSS by allocating sites in these strategic locations for adoption in future revisions of the RSS. The criteria for strategic sites required in PPS4 is left to the ELRs. The Western Suffolk ELR contains no criteria for strategic sites nor does it name Mill Lane or indeed any other site as strategic. However it does encourage the extension of Suffolk Business Park in Bury St Edmunds (despite the fact that this is all oversupply for St Edmundsbury district), because it fits strategic recommendation (R11). To avoid over-allocation, the support for the extension to Suffolk Business Park in the ELR is dependant on a coordinated phasing out of lower quality sites in the town. It should be noted that the recommendation of R11 to promote the development of high quality mixed use business parks is a general recommendation that applies equally to Forest Heath and Mid Suffolk as well as St Edmundsbury DC. Mill Lane is not a strategic site and therefore there are no implications for the Core Strategy on this account Stowmarket is not identified as a growth area. (a) How does the AAP fit with the development plans of surrounding areas? (b) How would the employment allocations affect development of sites outside the District? (c) Would they undermine the delivery of strategic development sites or sequentially better sites elsewhere? (d) Would that have an effect on infrastructure delivery elsewhere? (e) Would development of allocated sites be port related? c). Would they undermine the delivery of strategic development sites or sequentially better sites elsewhere? PPS4 Policy EC2.1(c) tasks Regional policies with identifying criteria or general locations of strategic sites ensuring that major greenfield sites are not released unnecessarily through competition between local authority areas. This seems to have been interpreted in some representations to imply that there is some unspecified national or regional sequential test that allows a strategic site to be given what might be termed a competitive advantage verging on monopoly. This Council s position is that no such sequential test exists in national or regional policy. That there is no matter of indisputable principle here rather that there is a question of whether Mill Lane is a necessary site in relation to the policies in PPS4 and whether any significant competition exists between this site and another. These are issues of fact and degree to be determined by all the evidence not just the ELR, as intended in PPS4 (Policy EC1) and noted in RSS Policy E1 and subsequent paragraphs 4.6 and 4.7. The Western Suffolk ELR indicates the broad location adjacent to Junction 50 on the A14 as a strong location for growth in the district and a sequentially preferential

4 location to meet the needs of the district and the town. The ELR nominates the Cedars Park site in the short term as the site for growth in this broad location. This site has had a monopoly position for 13 years and no development has been delivered in that time because of the variety of constraints identified in the SAAP, which have grown rather than reduced over time. A site in a broad location that cannot be delivered is not sequentially preferable to one that can. Similarly brownfield sites in the town might in theory be sequentially preferable but there are no such sites. The only Greenfield site in the broad location identified in the Core Strategy adjacent to Junction 50 is Mill Lane; it is therefore the sequentially preferential site in the town. Sites outside the district will do nothing to address the need for the town to achieve a better balance of jobs and housing nor can they provide for the relocation or expansion of existing businesses. In that sense they cannot be sequentially preferential to the site at Mill Lane. Nor can a site, strategic or otherwise, be sequentially preferential if it is a distant long-term prospect (British Sugar) or proposed for types of development and a different economic market to Mill Lane (Suffolk Business Park extension) Is there any conflict of employment allocations with PPS7? There will always be some level of conflict between a decision to locate built development in the countryside and Policy documents seeking to protect the countryside (including agricultural land) from such development. The Council s view is that in terms of sustainable development the town s very long standing need for jobs to balance the existing housing growth and to provide employment opportunities for future growth in appropriate sectors requires a development of the scale of that proposed at Mill Lane. The requirements of PPS7 were incorporated into the SAAP Policies from the outset and influenced the choice of site options, the content of development briefs, provision of informal leisure and recreation. Specific examples are listed below Key Principle 1(v) of PPS7 is that brownfield land is preferable to greenfield unless there are no brownfield sites available. The SHLAA identifies a total of 12 brownfield sites in Stowmarket which between them offer about 10 Hectares of development land. They represent Stowmarket s total brownfield housing supply for the plan period as set out in Table 6.1 of the SAAP. Delivery of this brownfield land for housing is dependant on the several businesses being relocated to a better conforming location such as Mill Lane. There is no other available brownfield land of any significance and there is therefore no conflict with PPS7 in this respect. In line with the philosophy of PPS7 (paras 14-16) and the need to protect wildlife and the most valuable landscape and environment surrounding the town, Greenfield sites in the following areas were discounted for extending the Town s boundaries for either housing or employment development. to the south of the town between Needham Road and Poplar Hill because of the protected landscape features and buildings In the Rattlesden River valley because of its environmental and landscape value Land north of the A14 towards Stowupland because:

5 o o o o it would alter the character and setting of the village, the land is highly visible from most directions the road represents a defined and defensible edge to the built environment of the town, and this area is not an obvious or natural extension to existing development. In effect this leaves 4 possibilities for built development in Stowmarket outside of the town centre: smaller infill sites between existing development and high impact areas at Farriers Road, Union Road and Ashes Farm, land at Chilton Leys the employment land allocation at Cedars Park land adjacent to Junction 50 at Mill Lane. Land adjacent to the A14 Junction 50 is preferred to land elsewhere for significant employment, which means that Cedars Park and Mill Lane are the only reasonable alternatives for extending the boundary of the town for employment. In comparing Mill Lane to the Cedars Park site in respect of the guidance in PPS7 it is noted that Cedars Park has a designated County Wildlife Site on about one third of the area and prior to development was classified as higher grade agricultural land than Mill Lane. However the SAAP takes a wider view than narrow hierarchical comparisons and seeks to address issues arising from PPS7 in a comprehensive approach that maximises the beneficial uses of all development land (PPS7 para26). PPS7 Key Principle (vi) requires all development in rural areas to be in keeping with its location and sensitive to the character of the countryside and local distinctiveness. A major contribution to the Masterplan process that preceded the SAAP was the Environmental Assessment, which included a landscape appraisal specific to Stowmarket. It is this evidence base that identifies the importance of the ridgeline that runs along the spine road adjacent to the Cedars Park site in establishing views in, out and across Stowmarket. The landscape setting of the Town requires planting on this ridgeline at Cedars Park to screen the housing while at Mill Lane planting in Area (1) on Map 7.3 will perform a similar function. Development at Mill Lane should minimise landscape impact by siting the most obtrusive development in the valley bottom adjacent to the railway with existing industry as a backdrop. Development decreases in height as it rises up the valley and is screened by substantial planting at changes of level (gabion area) and along access roads. The ridgeline meets the A1120 at the access to Mill Lane creating a gateway to the town marking the transition from rural to urban, which is the logic supporting landmark buildings in that location. The extensive open countryside adjacent to Mill Lane will be developed but a new and defensible edge to the town defined by thick belts of planting will replace it. There is an opportunity through sensitive design to retain views to open countryside beyond along the site access road vista. Views from Creeting St Peter are currently across open fields to the existing large scale industry in the Gipping Valley. Development at Mill Lane will bring development closer to the village so that the boundary landscape as viewed from outside will become an important element of the design. Because land form renders

6 on-site screening only a partial solution dense off-site screen-planting forms an agreed part of the site plan. PPS7 paragraph 15 requires planning policies to provide a positive framework for facilitating sustainable development that supports traditional land-based activities and makes the most of new leisure and recreational opportunities that require a countryside location. Agriculture obviously cannot be sustained on site but SAAP Policies concentrating future development to one area and creating a defined and defensible edge will help confine future development to the allocated sites. This will protect agricultural uses outside the site from future encroachment. New leisure and recreational opportunities will be delivered as part of the package for Mill Lane and include the 13ha wetland area and the open spaces and footpaths and cycle paths shown on Map 7.3 and in policies This will deliver formal access to the countryside that is currently unavailable and will be of particular benefit to the residents of Cedars Park and for the downtime leisure activities for the future workforce at the adjacent employment allocations. Similar considerations will form part of the development brief for Cedars Park, which has an existing network of adopted footpaths. PPS7 (paragraph 26) requires LDDs to recognise the importance of the countryside around urban areas in providing the nearest and most accessible countryside. Planning authorities should aim to secure environmental improvements and maximise beneficial land uses including improvement to public access and facilitating the provision of appropriate sport and recreation facilities. It is noted that the proposed new cycleway/footpaths will link the housing at Cedars Park to River Gipping towpath and National Cycle Route 51. The substantial planting blocks abutting the site s edges will form a biodiversity corridor linking the riverside and railway corridors to the A14 embankments. Conflict with PPS7 is largely restricted to the necessary loss of agricultural land to create jobs for the town. Significant attention has been paid in the policies of the SAAP to improve retain and enhance the character of the setting of the town while improving public accessibility to the countryside, leisure and recreational activities and biodiversity, as required in PPS7.