Martlesham Heath Householders

Martlesham Heath Householders Ltd.
PO Box 897 Martlesham Heath
IPSWICH Suffolk IP1 9PB
mhh@martlesham.org.uk 01473 612207
http://mhh.martlesham.org.uk/

Head of Planning Services
Suffolk Coastal District Council
Melton Hill
Woodbridge Suffolk IP12 1AU

Response from Martlesham Heath Householders Ltd to BT Planning Application - Further Information January 2010

Martlesham Heath Householders Ltd (MHHL) submits these comments in response to the BT documents placed on the SCDC website on 3rd February 2010.

Virtually all the open land in Martlesham Heath village is managed by MHHL on behalf of the village’s homeowners – all of whom are shareholders in the company by Deed of Covenant. MHHL’s Memorandum of Association require the company "To promote the benefit of the inhabitants of "Martlesham" by which is meant the inhabitants of the Civil Parish of Martlesham ..........and in particular to promote the benefit of the residents of Martlesham Heath"

MHHL wishes to express its serious concern about the limited time available for comment on these documents. Like other organisations, such as parish councils, the company has scheduled meetings, and such short timescales make it very difficult for organisations to garner and submit considered responses. Our shareholders have also expressed their serious concerns about the short timescales. The fact that this documentation was issued almost in parallel with the papers for the 24th February Cabinet meeting suggests disregard for organisations’ and residents’ ability to deal with all the information emanating from the Council. MHHL has previously submitted its objections to the proposal to allocate 2000 homes on the BT site in the emerging LDF. Those objections still stand, and these comments in no way imply that MHHL is condoning the LDF. However, as the Council appears determined to drive through the LDF regardless of the overwhelming public opinion opposed to this proposal, we are forced to make the following comments on the assumption that the Inspector approves the LDF and the development goes ahead.

MHHL also wishes to place on record its views that the LDF consultation process has been badly executed throughout. The latest round of consultation, which was positioned by the Council as a focussed consultation concerning only the changes in allocations, has very been misleading. It seems that, whatever public responses were submitted, there was no circumstance in which the major change (ie the increase from 1050 to 2000 homes on the BT site which was the main purpose of the consultation) would have been influenced or altered.

This is at odds with the role of the consultation process as described in various government policy documents eg Planning Policy Statements 1 & 12.

MHHL also notes the contents of the various document issued in advance of the Cabinet meeting scheduled for 24th February. The company is strongly of the opinion that many of the responses in Appendix 4 - Responses to Public Consultation on Housing Distribution - fail to address the issues raised by the public and merely repeat previous statements.

In the document entitled Habitat Regulation Assessment there are several references to 2000 homes resulting in a population of 1800 people. This figure of 1800 is then used in a calculation in para 11.1 to demonstrate that 28.8 hectares of public open space is required as alternative greenspace. However, as the likely population of the development will be about 4500 -4800 people, the real area of alternative greenspace required using the same calculation is about 72 -74 hectares.

The mitigating effects of alternative greenspace provided elsewhere diminishes rapidly. To the best of our knowledge there is no alternative greenspace which is closer to the development than the various sensitive areas in and around Waldringfield and Newbourne, so the likelihood of residents being diverted from those areas is small. In any event, travel to alternative greenspace sites would be likely to result in further car usage.

The areas of open space in Martlesham Heath include areas of MHHL owned woodland and these cannot be considered as alternative greenspace (c.f. the existing woodland on the BT site is not counted as alternative greenspace in the Environ calculations). The other main area of MHHL open space in Martlesham Heath is the Western Corridor – this is mostly an SSSI and as such should be subject to the same protection and consideration as the areas in Waldringfield and Newbourne; it is not alternative greenspace.

It is therefore an unavoidable conclusion that the Habitat Regulation Assessment demonstrates very clearly that the site is inappropriate for the building of 2000 homes without serious and irreversible environmental impact.

We note that the latest documents make no reference to a second footbridge, and that there is a new reference to cycle lanes at the Foxall junction. However discussions by one of our directors with SCDC planning department and subsequently with SCC have so far failed to establish what plans, if any, exist for an acceptable cycle route through or around Martlesham Heath capable of taking the sort of volume of foot and cycle traffic which 4800 people might generate, plus increased traffic to the enlarged business area and new schools.

MHHL’s position is quite clear. The creation of a route across MHHL owned land is unacceptable. Furthermore, the route from the existing footbridge via Valiant Way and thence past the bus stop and through the houses onto Broomfield is unsuitable for extra load. This route includes a very narrow footpath with two blind corners that already present a safety hazard. The SCC officer previously responsible for the foot and cycle path network in this area has confirmed that he agrees with this assessment. In fact all the narrow pathways through the housing hamlets are similarly unsuitable. Young children going to and from Gorselands and Birchwood primary schools use many of these pathways.

As sustainable travel into Ipswich is a key plank of BT’s application and the LDF, the creation of a suitable cycle/foot route is essential. It is therefore our view that acceptable foot and cycle path plans need to be in place before outline planning permission is granted in the same way as the key road access arrangements are firmed up at this stage. We have offered to hold discussions with SCC about this (once the right person has been identified), but this will not be resolved before the 25th February closing date. We therefore request that we are further consulted on this aspect before any decisions are made about the BT application – SCDC are invited to join us in any discussions with SCC.

It is of great concern to MHHL that none of the BT planning application documents or the LDF documents makes any significant reference to mitigating the effects of the development on the existing residents of Martlesham Heath.

Many of the houses in Martlesham Heath are close to the A12, and local residents have expressed a high level of concern about noise and pollution from this road (in a recent survey 73% were very concerned about this).

We are unable to declare a preference between the two phasing options because there are inconsistencies between the two as presented, and there is no narrative explanation of the detailed implications of those two options or the pros and cons for each one.

For example, option 2 shows perimeter planting being part of each phase, whereas perimeter planting is not mentioned in option 1. Previously we had been led to believe that perimeter planting would be carried out at the outset to minimise dust travel during mineral extraction. Option 2 specifies the length of the strategic access route at various stages, but it does not make it clear which parts make up that route length, nor at what stage those routes are capable of taking the main construction traffic and traffic to the growing commercial area. Option 1 does not contain any information about the length of the access routes at various phases. Both options state that the southern access delivery is to be determined by the transport assessment – without a clear statement as to when this will be.

These options therefore are not comparable nor detailed and complete enough to allow consultees to submit a meaningful response to them; we request that clear and complete information is provided for further consultation before these options are finalized.

In considering the options, the Council should agree measures with the highway authority to ensure that access to the whole site from the new southern entrance is provided at the outset to reduce the increased volumes of traffic that would otherwise pass alongside the village, especially heavy goods construction-related vehicles.

In addition, outline planning permission should be conditional on the following:-

We need to make it clear that we do not agree with BT’s statements that these are “junction improvements”.

The scheme to signalise the three nearby roundabouts seems to have been proposed without consideration of other options. For example, the early opening of the southern access road would mean that (using BT’s figures in their previous documents) the peak hour load on the BT roundabout would not increase beyond its 2007 levels for very many years and therefore signalisation would not be needed. The creation of the southern access route would also mean that the volume of northbound traffic turning right in the morning would fall, so the southbound queues at that junction would reduce.

Our residents are concerned that full time signalisation would mean much more stop-start traffic across the 24-hour period so that pollution and noise levels will increase. It will also increase the average journey time across the network (ie from the approach to the police roundabout to the exit onto the A14 (and vice versa) over the whole 24 hour period. We realise that the objective is to flatten the peak hour spikes but there is no sign of a cost/benefit or environmental analysis to compare alternative strategies. This is not acceptable. Previous requests for the Highways people to present their plans publicly to local residents have been ignored.

The introduction of signals at the two roundabouts on the A1214 resulted in major delays for people exiting Grange Farm and our residents are concerned that the same will apply to Martlesham Heath.

In addition, we note the signalisation of the junction after turning east at the BT exit – this becomes a new T-junction with signals. It seems likely that the capacity of that junction will limit the ability of traffic to leave the A12, which in turn will result in more peak hour queuing traffic on the A12 – thereby further increasing pollution and noise.

We also note that the proposed signalisation pushes the centre of the highway nearer to Martlesham Heath by about the width of one carriageway. This is apparent in the diagram which overlays the new junction on the existing roundabout. We see no reason for this to be the case and request that the centre line be move eastwards so that it is aligned with roundabout centre.

The two left hand lanes on the northbound approach are outside the area of the existing carriageway. We request that we be supplied with cross sectional diagrams of the proposed road changes so that we can judge their impact on the bunding and land that we own adjacent to the A12 at this point.

We note that the revised photoshop image of the junction shows the native landscaping along the A12 being retained, which we endorse; and the hard landscaping previously proposed for the quadrants left behind by removing the roundabout now appears to have soft landscaping. We believe that more could be done to lessen the visual impact of the changed junction - especially when facing into or out of the village. For example, increasing the height of soft landscaping on those quadrants so as make the entrance appear narrower, and introducing some sort of feature on either side of the village entrance road so as to visually mark the boundary between the trunk road and the village entrance more clearly. A modern interpretation of the mini gates sometimes seen at the boundary of villages might be appropriate so that it complements the village sign further in. We would like to discuss this before any detailed designs are firmed up.

If the BT roundabout is replaced by full time signals then we believe that an AQMA should be established there to assess the actual impact of those changes on the air quality rather than relying on theoretical modeled calculation.

Any new road lighting introduced on the Martlesham Heath section of the A12 should be the minimum necessary, and should be state of the art directional lighting so that it minimises skywards light pollution and does not intrude on houses adjacent to the A12.

We note that Section 3 of the Design and Access statement has a table which details some sample block diagrams. In that table, SB7 states that there might possibly be 3-4 story houses in that area. As SB7 is immediately opposite Martlesham Heath we consider that no more than 2 storeys should be permitted on the immediate western edge – so that the new residential area is fully screened by the perimeter planting and the overall visual effect is in harmony with the existing landscaping on the western side of the A12. This would also help to avoid the creation of a noise “canyon”. Please note there is currently no sound bunding along the east side of Martlesham Heath in the area opposite SB7.