Site Allocations Local Plan - Preferred Options (Regulation 18 Stage)

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Preferred sites for allocation in the towns

5. Brandon

View Comments (2) (2) The local area

5.1 Brandon has a population of approximately 9,145 (2011 Census) and is located to the north of the district, on the border with Breckland district. It is defined as a market town in the Core Strategy. This is because of the existing range of services and amenities available and good public transport links with other towns and villages. It is intended that Brandon will serve the retail and leisure needs of the local catchment area.

5.2 Constraints and opportunities to future development

  • European site designations for stone curlew, woodlark and nightjar. The special protection area (SPA) and its buffer zones are described in the Core Strategy. This results in limited settlement expansion in Brandon without first demonstrating mitigation for the presence of the various protected species;
  • there is traffic congestion in Brandon and it has been suggested this could be resolved by the provision of a relief road. However the recent highways improvement to the A11 may have lessened the congestion in the town, such that the bypass is not considered necessary. Further traffic evidence is needed to justify the need for a relief road and the effect of the A11 improvements are currently being studied. In addition building a relief road is dependent on firm funding commitments and mitigation of environmental/habitat constraints. Any scheme would need the participation and support of Breckland District and Norfolk and Suffolk County Councils;
  • a railway line runs east-west in the northern part of the settlement;
  • a railway station is located at Bridge Street providing links to Norwich and Ely. However, the level crossing at A1065 creates a bottleneck for vehicular movement at peak times;
  • airbase noise constraints to the south of Brandon as a consequence of aircraft landing at and taking off from RAF Lakenheath;
  • land within Flood Zones 2 and 3 to the north of the settlement along the Little Ouse river according to the Environment Agency's mapping;
  • a Site of Special Scientific Interest (SSSI) lies to the south and east of Brandon;
  • the town has two primary schools and an 11-16 free school;
  • services in the town include two GP surgeries, two dental practices, one nursing home, a police station and a fire station. There is a library and community centre;
  • the town centre offers a range of shops and services, including several supermarkets, local convenience stores, comparison shops and services;
  • there are open spaces and sports provision, including a leisure centre with a four court sports hall and indoor bowls;
  • the town and its hinterland contain a number of listed buildings and know archaeological sites including a Scheduled Ancient Monument on Chequer Meadow, and the historic centre of Brandon is designated as a conservation area;
  • there may be capacity in the sewage network for some further development however upgrades may be required including possible requirement for new or improved sewer;
  • Brandon is surrounded by an extensive area of forest, Brandon Country Park and High Lodge Forest Centre.

5.3 Further information on constraints and opportunities in Brandon is set out in other evidence based documents which are available online at http://westsuffolk.jdi-consult.net/localplan.

View Comments (1) (1) What you told us

5.4 From August to October 2015, we consulted on a Site Allocations Local Plan Issues and Options document, asking questions about sites that had been suggested to us as being suitable for development. All of the responses to the consultation, and officers' responses to them, are available to view online at http://westsuffolk.jdi-consult.net/localplan.

5.5 Twenty individual representations were received in relation to the Brandon section of the issues and options document. It is important that these responses are read alongside those received in relation to the Core Strategy Single Issue Review consultation. A summary of key points raised in relation to Brandon, in response to both 2015 consultation documents, is set out below:

  • Breckland District Council welcomed the proposed low scale of growth at Brandon, noting that further evidence would be required to address the impacts of any development on the town;
  • Natural England commented that a precautious approach to considering housing distribution and provision in Brandon is appropriate. They confirm that the environmental constraints have been correctly identified and advise that development in areas of land within the Breckland SPA and/or Stone Curlew Nest Constraint Zones may not be deliverable unless it can be satisfactorily demonstrated that suitable mitigation can be provided;
  • Historic England commented that reference should be made to the heritage assets found within and surrounding each settlement to inform site selection;
  • some responses state that the low level of growth being proposed is not a sustainable option, would not ensure the regeneration of the town and would encourage out-commuting;
  • a higher growth should be explored which would deliver infrastructure benefits to the town;
  • mention was also made to the existing potential opportunities for regeneration and development within the settlement boundary.

View Comments (1) (1) Development issues

5.6 It is important to recognise that development in the town will be influenced by the Core Strategy Single Issue Review which will determine housing distribution across the district.

5.7 Taking into account the comments received during the 2015 consultation, and additional evidence based work, a preferred distribution strategy has now been established (see the Single Issue Review Preferred Options document at http://westsuffolk.jdi-consult.net/localplan). For Brandon, this means that a total of 70 dwellings would be provided in the town up to 2031. The reasons for this are summarised below:

5.8 The environmental constraints around Brandon, particularly the environmental site designations, place a severe limit on the extent of development that can take place in the town. Higher growth in Brandon could only be considered if it can be demonstrated that there are no adverse effects of the development on the integrity of the SPA through the Habitats Regulations Assessment process, as set out in Core Strategy Policy CS2. During the 2015 consultation, no evidence was presented to suggest that the SPA constraints could be overcome to allow a higher level of development.

5.9 The council undertook further investigations into the available sites, consulted on in the Issues and Options document, in and around Brandon to ascertain whether they could be delivered without any adverse impact on the constraints identified above, or where adverse impacts were identified, provide mitigation to overcome the impacts. The council found no evidence to suggest that mitigation could be provided to overcome potential adverse impacts on the SPA. In addition, on further investigation it was identified that a number of the sites within the settlement boundary were unavailable or unsuitable for development. The results of this work and a reasoned justification for the discounting of sites are in Appendix B to this document.

5.10 Between 1 April 2011 and 1 April 2015, 55 homes have either been built or have gained planning permission in Brandon. (See table in section 2).

5.11 In the context of the above, three residential sites have been identified as being suitable for allocation in Brandon to meet the distribution needs set out in the Single Issue Review, as outlined in the draft text and policy below.

View Comments (1) (1) Brandon Planning Constraints map

Brandon Planning Constraints map

View Comments (1) (1) Brandon Settlements map

Brandon Settlements map

View Comments (7) (7) Site B1(a) - Land at Fengate Drove
(formerly B/01)

5.12 This is a brownfield site which lies to the north of the railway line. Part of the site lies within the settlement boundary. An application (DC/14/2219/FUL) was approved (subject to a S106 agreement) in July 2015 for 64 affordable dwellings on the site, extending across the boundary into Breckland District. 38 of these units are within Forest Heath district.

B1(a) Site Plan

B1(a) Site Plan

View Comments (5) (5) Site B1(b) - Land at Warren Close

5.13 This site was proposed by Suffolk County Council during the 2015 call for sites. It lies within the settlement and is a brownfield site comprising the former library, which has relocated to the Brandon Centre, and pre-school.

5.14 The site is within the settlement boundary and would be accessed off Warren Close. There are mature beech trees on this site which should be retained. This could be achieved with a tree preservation order.

B1(b) Site Plan

B1(b) Site Plan

View Comments (4) (4) Site B1(c) - Land off Gas House Drove

5.15 This site was identified by officers in October 2015. It is the site of a former gas works and has recently been subject to soil remediation works to deal with contamination issues on the site. National Grid has informed the council that they are looking to dispose of the site for development in 2016. The mature trees on the southern part of the site should be retained. This could be achieved with a tree preservation order. The former gas works site has already undergone a desk based archaeological evaluation when remediation works were being considered and no further archaeological works are required. Access is directly onto Gas House Lane which is an unadopted road and will restrict the number of dwellings that can be provided on the site.

B1(c) Site Plan

B1(c) Site Plan

View Comments (2) (2) Policy B1: Housing in Brandon

Residential development is proposed in Brandon on the following brownfield sites:

New reference
(former reference)

Location

Area
(hectares)

Indicative
capacity

B1(a)
(formerly B/01)

Land at Fengate Drove

0.96

38*

B1(b)

Land at Warren Close

0.67

20

B1(c)

Land off Gas House Drove

0.3

10

These sites are identified on the Policies Map.

Strategic landscaping and open space must be provided to address the individual site requirements and location.

If the current planning permission or development proposals on site (a) are not implemented or are varied, a project level HRA would be required for any new planning application on the site.

*Allocations are based on the planning situation as at 1 April 2015. Sites where planning applications were approved after the April 2015 base dates are included as potential allocations, as to omit them would not show the complete planning picture. Planning permission for 38 dwellings on Land at Fengate Drove was approved, subject to a Section 106 agreement in July 2015.

View Comments (2) (2) Question 1:

Do you agree with the draft policy above? Are there any other issues which you feel should be taken into account in the policy?

View Comments (1) (1) New cemetery site

5.16 Land is required for a new cemetery in the town as the existing one is at capacity. A site of approximately 1.6 hectares off Manor Road has been identified on the Policies Map for this purpose. The site is located in an area of high archaeological importance, recorded in the County Historic Environment Record. There is a current undetermined application for a cemetery on the site (DC/15/1198/FUL) and it is important that archaeological investigation takes place prior to the determination of this, or any subsequent application.

B2 Site Plan

B2 Site Plan

View Comments (4) (4) Policy B2: Cemetery

A site of 1.59 hectares is reserved for a cemetery at Manor Road, Brandon, as shown on the Policies Map.

Archaeological investigations on the site should take place prior to the granting of any planning permission.

View Comments (2) (2) Question 2:

Do you agree with the draft policy above? Are there any other issues which you feel should be taken into account in the policy?

Alternative options

All the alternative sites included in the 2015 Site Allocations Further Issues and Options consultation draft were noted as having the SHLAA status deferred, and no information was submitted during the consultation period to overcome the reasons for deferral.

The reasons for rejecting the potential alternative sites are set out in more detail in Appendix B.

Employment sites

5.17 A number of proposed and existing employment sites in the town have been allocated in Policies EM1 and EM2 and are shown on the Policies Map. More information about employment uses across the district can be found in section 16 of this document.

Retail and town centres

5.18 The areas to be covered by town centre masterplans and a retail allocation are shown on the Policies Map and addressed by Policies RE1 and MP1. More information about retail and town centres across the district can be found in section 17 of this document.

View Comments (1) (1) Settlement boundary changes

5.19 Settlement boundaries in this local plan, as shown on the Policies Map, encompass the developed area of settlements and all peripheral sites allocated, committed or accepted for built development. Changes are being proposed to the boundary along the southern edge of Brandon as outlined below. These changes are shown on the Policies Map which accompanies this document, with the dashed line indicating the line of the proposed change.

Proposed change to settlement boundary Justification

Tighten the southern part of the settlement boundary so it better defines the extent of existing built development, excluding areas of forest and open land.

The area falls within the Breckland SPA, Breckland Forest SSSI and partly within the Thetford Forest Park County Wildlife Site and has high biodiversity value. These areas are not be suitable for development and should be removed from the settlement boundary.

Draw in the settlement boundary to exclude part of the garden of Brandon Cottage to exclude area of woodland

The wooded area is directly adjacent to the Breckland SPA and excluding this land will provide an additional buffer and help prevent inappropriate backland development.

View Comments (2) (2) Question 3:

Do you agree with the proposed changes to the settlement boundary? Are there any other changes to the Brandon boundary which you feel should be made?

6. Mildenhall

View Comments (1) (1) The local area

6.1 Mildenhall has a population of approximately 10,315 (2011 Census) and it is defined as a market town within the Core Strategy. This is because of the existing range of services and amenities available and good public transport links with other towns and villages. It is intended that Mildenhall will serve the retail and leisure needs of the local catchment area. The town is located just north-west of the A11, approximately seven miles north-east of Newmarket and nine miles south-west of Thetford. Bury St Edmunds lies 12 miles to the south-east.

6.2 Constraints and opportunities for future development:

  • this market town provides a broad range of shops, services and facilities that serve the needs of its catchment area. These include Sainsbury’s and Co-op supermarkets, a range of town centre comparison shops, local convenience shops and parades, banks, a post office, public houses and restaurants;
  • education and community facilities include a library, community centres, two primary schools and an upper school;
  • higher levels of growth are likely to require an additional or expanded primary and secondary school;
  • the town is served by seven GPs in two surgeries and six dentists in two practices, three nursing homes, police, ambulance and fire stations;
  • sport and open space facilities include Mildenhall Woods, sports grounds, non pitch sports provision, allotments, play space, a swimming pool and a leisure centre and sports hall;
  • road junction capacity in the town is limited;
  • there is capacity at the receiving Mildenhall Water Recycling Centre to accommodate growth although depending on the location and scale of development the existing sewage network may require upgrading;
  • there are special protection areas (SPA) designations for stone curlew, nightjar and woodlark. Very limited settlement expansion is possible to the east of the settlement without first demonstrating appropriate mitigation for the presence of the protected species;
  • there are aircraft noise constraints to the north of the town associated with RAF Mildenhall airbase flight paths;
  • a significant area of land to the south of the settlement lies within Flood Zones 2 and 3 according to data provided by the Environment Agency;
  • land to the east of the settlement lies within the Breckland Forest Site of Special Scientific Interest;
  • there is uncertainty over the consequences of the withdrawal of USAFE from RAF Mildenhall post 2022 and the future use of the site;
  • the historic core of the town is designated a conservation area and contains many listed buildings and two Scheduled Ancient Monuments (SAM). There are also many known archaeological sites within the town and in its immediate hinterland;
  • coalescence with surrounding settlements such as Barton Mills, Worlington and the Rows ought to be avoided;
  • many of the buildings currently housing public services in Mildenhall are either coming to the end of their planned lives, or need major investment. Any growth in the town will put extra demand on these facilities. There is the potential to bring together a number of public services on to one site in order to create a Mildenhall Hub. This would help reduce running costs and improve public access. Services could include Mildenhall College Academy, the district and County Councils, Mildenhall swimming pool, the Dome leisure centre and gym, the fire service, police and health services. Other services such as the library, pre-school, the Job Centre and Citizens Advice Bureau could also be involved;
  • provision of a public services hub could see a number of vacated sites within the existing settlement boundary released for other uses;
  • there is the potential for a district heating network to be provided as part of any Mildenhall Hub project, future-proofed to serve any new residential development in the vicinity.

6.3 Further information on constraints and opportunities in Mildenhall is set out in the other evidence base documents available online at http://westsuffolk.jdi-consult.net/localplan.

View Comments (1) (1) What you told us

6.4 From August to October 2015, we consulted on a Site Allocations Local Plan Issues and Options document, asking questions about sites that had been suggested to us as being suitable for development. All of the responses to the consultation, and officers’ responses to them, are available to view online at http://westsuffolk.jdi-consult.net/localplan.

6.5 104 individual representations were received in relation to the Mildenhall section of the issues and options document. It is important that these responses are read alongside those received in relation to the Core Strategy Single Issue Review consultation. A summary of key points raised in relation to Mildenhall, in response to both 2015 consultation documents, is set out below:

  • Natural England pointed to the fact that Mildenhall has areas of land within the Breckland SPA and/or Stone Curlew Nest constraint zones and advised that development within such areas may not be deliverable unless it can be satisfactorily demonstrated that suitable mitigation can be provided;
  • similarly, Suffolk Wildlife Trust noted that any growth in Mildenhall (particularly on the eastern side) will be constrained by the need to protect the integrity of the site of European nature conservation importance;
  • Historic England commented that reference should be made to the heritage assets found within and surrounding each settlement to inform site selection. More detailed comments were given to individual sites;
  • several respondents commented on the potential availability of the USAFE air base at Mildenhall for development and that this should be considered within the context of the district council’s emerging plans and policies;
  • in terms of transport, Suffolk County Council identified that Mildenhall has some internal constraints on capacity that may impact on the level of growth within the town and the location of this growth will be key to assessing this impact. The County observe that there has been a long term aspiration for a relief road for the town, although the environmental constraints and fact that growth may not be on a scale to deliver the relief road through development contributions are acknowledged;
  • in terms of (secondary) education, Suffolk County Council suggest that different options exist for managing growth within the catchment of Mildenhall College, including expansion of the current school, additional pupils attending IES Breckland and/or Newmarket College, or a new secondary school to meet additional demand arising from development.

View Comments (3) (3) Development issues

6.6 It is important to recognise that development in the town will be influenced by the Core Strategy Single Issue Review which will determine housing distribution across the district.

6.7 Taking into account the comments received during the 2015 consultation, and additional evidence based work, a preferred distribution strategy has now been established (see the Single Issue Review Preferred Options document at http://westsuffolk.jdi-consult.net/localplan). For Mildenhall, this means a total of 1,359 dwellings are proposed for allocation up to 2031. The reasons for this are summarised below:

6.8 The environmental constraints around Mildenhall, particularly the environmental site designations to the east, place a severe limit on the extent of development that can take place in and around the town. Higher growth in Mildenhall could only be considered if it can be demonstrated that there are no adverse effects of the development on the integrity of the SPA through the Habitats Regulations Assessment process, as set out in Core Strategy Policy CS2. During the 2015 consultation, no evidence was presented to suggest that the SPA constraints could be overcome to allow a higher level of development.

6.9 The council undertook further investigations into the available sites, consulted on in the Issues and Options document, in and around Mildenhall to ascertain whether they could be delivered without any adverse impact on the constraints identified above, or where adverse impacts were identified, provide mitigation to overcome the impacts. In addition, on further investigation it was identified that a number of the sites within the settlement boundary were unavailable or unsuitable for development. The results of this work and a reasoned justification for the discounting of sites can be seen in Appendix B of this document.

6.10 It was announced on 18 January 2016 that the Government will be selling RAF Mildenhall once the United States Air Force vacates the base by 2022. Until there is certainty from the MoD over the deliverability and timescales for bringing the site forward, it is not possible to include the site as an option in the Site Allocations Local Plan. Should this position change during the plan period, the council will immediately commence a review of the local plan and a masterplan will be prepared.

6.11 The Mildenhall Hub project is an ambitious partnership initiative to rationalise and improve the public estate in Mildenhall for the benefit of local people. It could potentially include relocating/replacing a variety of public buildings, currently split across five separate sites across Mildenhall, to one location on the western side of the town. The services that could potentially be included are:

  • Mildenhall College Academy;
  • pre-school;
  • council offices (including FHDC, SCC, DWP, health and CAB);
  • improved leisure facilities (pools, sports hall, fitness suite, outdoor pitches);
  • health centre;
  • library;
  • police station;
  • fire station;
  • primary school (later phases).

Prior to any planning application being determined, a development brief will be required to demonstrate that issues around traffic, amenity and the local environment have been understood and addressed.

6.12 Between 1 April 2011 and 1 April 2015, 177 homes have either been built or gained planning permission in Mildenhall. (See table in section 2).

6.13 In the context of the above, three residential sites have been identified as being suitable for allocation in Mildenhall to meet the distribution needs set out in the Single Issue Review, as outlined in the draft text and policies below.

View Comments (1) (1) Mildenhall planning constraints map

Mildenhall planning constraints map

View Comments (5) (5) Mildenhall settlement map

Mildenhall settlement map

Focus of growth – Land west of Mildenhall

View Comments (9) (9) Site M1(a) – Land west of Mildenhall
(formerly M/19, M/21 & M/40)

6.14 This site comprises a large expanse of (Grades 2 & 3) agricultural land to the west of Mildenhall. The site lies outside of the settlement boundary. The council considers that this site should be allocated for appropriate mixed use development. The site is bound by existing residential development and employment areas to the east and open countryside to the west. Development will need to have regard to areas of known archaeological interest, the setting of a listed building, Wamil Hall, to the southwest and conservation area to the east.

M1(a) site plan

M1(a) site plan

View Comments (3) (3) Policy M1: Focus of growth - Land west of Mildenhall

The following site is allocated for mixed use development in Mildenhall:

New reference
(former reference)

Location

Area
(hectares)

Indicative capacity

M1(a)
(formerly M/19, M/21 & M/40)

Land West of Mildenhall

95

Mixed use to include 1,250 dwellings, a minimum of 2.6 ha employment, schools, leisure facilities and public services.

95 ha of land to the west of Mildenhall, as identified on the Policies Map, is allocated for mixed use development to accommodate residential, employment and other appropriate uses in connection with the Mildenhall Hub project, including strategic open space, allotments, public services, leisure facilities and provision for a Gypsy and Traveller site (see Policy G1). Precise numbers and the distribution of uses and access arrangements will be informed by a detailed masterplan for this site.

Applications for planning permission will only be determined once the masterplan for the whole site has been approved by the LPA.

Strategic landscaping and open space must be provided on all sites to address the site requirements and location.

All development must provide measures for influencing recreation in the surrounding area, to avoid a damaging increase in visitors to Breckland SPA through the provision of suitable alternative natural greenspace (SANGS) which is well connected and the enhancement and promotion of dog friendly access routes in the immediate vicinity of the development. A strategic (masterplan) approach to the provision of suitable alternative natural greenspace and access is required so that smaller sites coming forward independently can contribute to this approach.

Proposals should incorporate the protection and enhancement of the existing hedgerows, scrub and woodland habitat through retention and connection to the River Lark corridor and the wider landscape providing a framework of interconnecting green corridors for people and wildlife.

A substantial buffer should be retained adjacent to the River Lark to maintain the amenity and allow enhancement of the important ‘blue green’ corridor which could be the focus of the SANGS.

Development will need to have regard to the setting of Wamil Hall a listed building southwest of the site and the conservation area to the east. Archaeological evaluation should be carried out at an early appropriate stage in the development management process to allow preservation in situ, where appropriate, of any unknown sites of importance and appropriate strategies to be designed.

Permeability between the existing settlement edge and new development for pedestrians and cyclists must be provided. The Hub will provide a focus for community facilities and activities.

View Comments (5) (5) Question 4:

Do you agree with the draft policy above? Are there any other issues which you feel should be taken into account in the policy?

Other residential development in Mildenhall

View Comments (5) (5) Site M2(a) – Land at 54 Kingsway
(formerly M/28)

6.15 This brownfield site comprises land located between Kingsway and Robin Close and was previously in use as a commercial plant nursery. The site is to the east of the town centre and within the existing settlement boundary. Part of the original site has recently acquired planning permission for 5 units (DC/15/0828/OUT) and the area under consideration as part of the Issues and Options consultation has subsequently been reduced to reflect this. This site has been subject to archaeological evaluation and no further work is needed.

>M2(a) site plan

M2(a) site plan

View Comments (5) (5) Site M2(b)– District Council Offices, College Heath Road
(formerly M/46)

6.16 This is the site of the council offices, surgery and library on College Heath Road and it might become available with the delivery of the Mildenhall Hub project. The site is bound by College Heath Road to the north and west and existing residential development to the east. This is a predominantly residential location within the town. The site includes a known area of archaeological interest and will require pre-determination desk-based evaluation. This location is potentially suitable for apartments and a higher density of 40-45 dwellings per hectare (dph).

>M2(b) site plan

M2(b) site plan

View Comments (1) (1) Policy M2: Other residential development in Mildenhall

Residential development is also proposed in Mildenhall on the following sites:

New reference
(former reference)

Location

Area
(hectares)

Indicative
capacity

M2(a)
(formerly M/28)

Land at 54 Kingsway

0.7

20*

M2(b)
(formerly M/46)

District Council Offices, College Heath Road

2.1

89

These sites are identified on the Policies Map.

Strategic landscaping and open space must be provided on all sites to address the individual site requirements and locations.

All development must provide measures for influencing recreation in the surrounding area, to avoid a damaging increase in visitors to the Breckland SPA through the provision of suitable alternative natural greenspace which is well connected and the enhancement and promotion of dog friendly access routes in the immediate vicinity of the development.

Site (a) requires pre-determination desk-based archaeological evaluation.

*Allocations are based on the planning situation as at 1 April 2015. Sites where planning applications were approved after the April 2015 base dates are included as potential allocations, as to omit them would not show the complete planning picture. Planning permission has been granted for 5 dwellings on Land at 54 Kingsway, however it is considered that this site has additional capacity.

View Comments (3) (3) Question 5:

Do you agree with the draft policy above? Are there any other issues which you feel should be taken into account in the policies?

View Comments (1) (1) Alternative option

One alternative site was identified as being potentially suitable for allocation in Mildenhall: M/30 – The Old Railway Station site.

Although this is a relatively unconstrained site (in environmental terms) it has been omitted on the basis that there are considered to be more suitable and sustainable options. Development on this site could potentially lead to coalescence issues with Barton Mills and have detrimental impacts on the landscape to the south of the town.

View Comments (1) (1) Existing commitments in Mildenhall

6.17 Planning permission for 9 dwellings at the former builder’s yard north of Worlington Road (DC/14/2320/FUL) was granted in February 2015. Planning permission for 78 units on land south of Worlington Road & adjacent to former Dairy site (DC/13/0927/OUT) was granted in December 2014. These sites do not abut or relate well to the settlement boundary therefore it is not considered appropriate to allocate them under policy M2. However once implemented the sites will make a contribution towards the overall housing provision for Mildenhall, so have been counted as an additional provision of 87 dwellings.

Employment sites

6.18 A number of proposed and existing employment sites in the town have been allocated in Policies EM1 and EM2 and are shown on the Policies Map. More information about employment uses across the district can be found in section 16 of this document.

Retail and town centres

6.19 The areas to be covered by town centre masterplans and a retail allocation are shown on the Policies Map and addressed by Policies RE1 and MP1. More information about retail and town centres across the district can be found in section 17 of this document.

Settlement boundary changes

6.20 Settlement boundaries in this local plan, as shown on the Policies Map, encompass the developed area of settlements and all peripheral allocated sites. The settlement boundary will be redrawn to incorporate those sites considered for allocation within this Preferred Options document. Further changes are being proposed to the boundary along the eastern fringe of the settlement, to include relatively new development, and to the west, to encapsulate the Mildenhall Hub project. These changes are shown on the Policies Map which accompanies this document, with a red dashed line indicating the line of the proposed change.

Proposed change to settlement boundary Justification

Relatively minor adjustment to settlement boundary along eastern limits of Mildenhall.

To reflect the built form of the settlement and in particular to include all of the relatively recent residential development off College Heath Road within the boundary.

Extension of settlement boundary so that Site M1(a) adjoins the existing settlement boundary to the south-west of the settlement and as a consequence incorporates the former middle school (and potential site for the Mildenhall Hub) within the settlement boundary.

This will result in a more logical settlement boundary that incorporates existing development (the former Riverside Middle School site) in addition to the Mildenhall Hub and associated development within the settlement. It also includes land south of allocation EM2(l), which is considered suitable for employment use, but has not been formally allocated as such due to uncertainty on deliverability.

Extension to industrial area west of Fred Dannatt Road to include site EM2(l)

To reflect planning permission DC/14/1460/FUL

View Comments (4) (4) Question 6:

Do you agree with the proposed changes to the settlement boundary? Are there any other changes to the Mildenhall boundary which you feel should be made?

7. Newmarket

View Comments (4) (4) The local area

7.1 Newmarket has a population of approximately 16,615 (2011 Census) and is located south of the A14, some 11 miles west of Bury St Edmunds and 10 miles east of Cambridge. It is Forest Heath's largest settlement defined as a market town in the core strategy. Newmarket is considered to be one of the more sustainable locations for new development within the district because of the range of services and facilities available within the town and because of its good transport links. Newmarket is a centre for the British Horse Racing Industry (HRI) which has an important economic and cultural role in the town. Newmarket town centre should serve the retail and leisure needs of the local catchment area.

7.2 Newmarket is described as the international home of horseracing with over 3,000 race horses, 89 licensed trainers, 62 stud farms, 1,133 hectares of training grounds and hundreds of stable staff within and around the town (more than anywhere else in the world).

7.3 In 2013 Forest Heath District Council and the Newmarket Horsemen's Group sought to obtain an up to date understanding of the scale and economic significance of the Horse Racing Industry in the Newmarket area and commissioned SQW to produce a report on the 'Economic Impact of the Horseracing Industry Centred Upon Newmarket'. This study found the total economic contribution of the Horse Racing Industry to be in the region of £208 million, with 6000 jobs related to the racing industry in the East Cambridgeshire and Forest Heath areas. More recently, the council commissioned Deloitte to look at the 'Local National and International Impact of the Horseracing Industry in Newmarket'. The report was published in September 2015 and findings included that the industry provides 8,500 jobs both directly and indirectly; 28% of all British flat/dual-purpose horses are trained in Newmarket making it the largest UK training centre by a factor of 4 and that Newmarket is a unique training centre with no comparable location in the world.

7.4 However, the town also has its own issues, which include a lack of affordable housing to meet the needs of people within the town, including those employed within the racing industry itself. While equine is the largest single employment sector, some 65% of the overall employment in the town is in other businesses, including financial/business services, retail and manufacturing/engineering.

7.5 Newmarket's High Street runs for one mile from the Jubilee Clock Tower to the Cooper Memorial Fountain. The High Street and its surrounding streets contain Newmarket's historic core, the main shopping area (including a twice weekly outdoor market and the Guineas Shopping Centre), training stables and visitor attractions including the soon to be opened Home of Horseracing.

7.6 The Home of Horseracing project will be a major tourist attraction centred on Palace House and stables on Palace Street, just off the High Street. The five acre site will include a state of the art horseracing museum. Palace House itself will become the national gallery of British sporting art. There will also be space to accommodate live horses as an essential part of the visitor experience.

7.7 Recently several large supermarket chains have been vying for a presence in the town. The High Street's independent retailers face the same problems afflicting many market towns across the UK in the form of competition from internet shopping, the proliferation of chain stores, an over-representation of charity shops and bookmakers, and a night-time economy which serves a young demographic.

7.8 Constraints and opportunities for future development

  • there is a significant area of land within Flood Zones 1 and/or 2 running north/south through the middle of the settlement. Any site allocated in the Site Allocations document that falls within or partially within these zones must be subjected to a Flood Risk Assessment (FRA) to determine the proportion of the sites that can be developed safely and without risk of inundation;
  • settlement expansion is significantly constrained by the Horse Racing Industry and its associated land uses. Other policies within the local plan seek to safeguard the racing industry and its assets;
  • land to the east and south-west of the settlement is within the Newmarket Heath Site of Special Scientific Interest (SSSI);
  • there is a need to carefully manage the movements of vehicles and horses within the town itself;
  • there is an opportunity to build on the tourism opportunities created by the opening of the new Home of Horseracing project;
  • there is an opportunity to improve the offer and vitality of Newmarket High Street including its market;
  • Newmarket benefits from good public transport infrastructure which includes a railway line that connects the town to Ipswich, Bury St Edmunds, Cambridge and beyond and there are trunk road links with the A14 and A11. The council is working with Suffolk County Council and other stakeholders to identify improvements in the delivery of rail and other transport networks;
  • open space and sports facilities include 6.2 hectares of sports grounds, 0.9 hectares of non-pitch sports, 1.6 hectares play space, a swimming pool and sports hall/leisure centre;
  • there is a good range of health and emergency services including 18 GPs in three surgeries, 13 dentists in six practices, two nursing homes, a hospital providing outpatient services, police, ambulance and fire station;
  • the town has five primary schools with capacity for 1,155 pupils and an upper school with capacity for 922 pupils. There is no available capacity within the town's primary schools;
  • community and leisure facilities include a library, the Memorial Hall, Kings Theatre and Studlands Park Community Centre
  • the town centre has a substantial comparison goods offer and comprehensive range of services;
  • an existing retail park and employment area lie to the north of the town;
  • the town is rich in archaeology and listed buildings with the historic core of the town and historic racing yards and stables designated as a onservation area. Devil's Ditch a Scheduled Ancient Monument is situated to the southwest of the town;
  • coalescence with the settlement of Exning to the north-west of Newmarket should be avoided;
  • Newmarket has an air quality management area (AQMA) centred on the High Street from the clock tower to the junction with The Avenue. The impact of any future growth on air quality needs to be considered;
  • growth in surrounding settlements such as Kentford and Exning may have the potential to impact on Newmarket's infrastructure.

7.9 Further details can be seen on the on the council's webpages. At: www.westsuffolk.gov.uk/Council/Policies_Strategies_and_Plans/newmarketvision.cfm

7.10 Further information on constraints and opportunities in Newmarket is set out in the other evidence based documents available online at http://westsuffolk.jdi-consult.net/localplan

What you told us

7.11 From August to October 2015, we consulted on a Site Allocations Local Plan Issues and Options document, asking questions about sites that had been suggested to us as being suitable for development. All of the responses to the consultation and officers' responses to them are available to view online at http://westsuffolk.jdi-consult.net/localplan.

7.12 155 individual representations were received in relation to the Newmarket section of the issues and options document. It is important that these responses are read alongside those received in relation to the Core Strategy Single Issue Review consultation. A summary of key points raised in relation to Newmarket, in response to both 2015 consultation documents, is set out below:

  • a number of respondents considered there to be existing traffic congestion issues within the town and expressed concern that the current situation might worsen were any further (significant) development to take place in and around Newmarket;
  • the Newmarket Horseman's Group (NHG) and others considered that significant residential development cannot be delivered in Newmarket without a detrimental impact on the Horse Racing Industry;
  • there was recognition that Newmarket is a relatively sustainable location for development (a market town) albeit it was constrained, particularly in terms of land in use by the equine industry.
  • Historic England commented that reference should be made to the heritage assets found within and surrounding each settlement to inform site selection. Detailed comments were given to individual sites;
  • in terms of transport, Suffolk County Council identify the key issues that need to be considered for growth in Newmarket as being the impact of additional traffic on horse movements, junction 37 of the A14 and the AQMA at Newmarket High Street. The local highway network has also been identified by the county as requiring improvements. Further, the County Council emphasised their commitment to working through the Newmarket Vision structure to consider opportunities to improve walking and cycling routes in Newmarket, such as the Yellow Brick Road route from Studlands through to the town centre;
  • Suffolk County Council is committed to working with local partners to consider ways in which Newmarket can grow in a balanced way; protecting and promoting Newmarket's status as an international horseracing centre of excellence, whilst also meeting the needs of all residents and other economic sectors;
  • Newmarket Racecourses suggested that for the district council to state that Newmarket had good transport links is 'wildly optimistic'.

Development issues

7.13 It is important to recognise that development in the town will be influenced by the Core Strategy Single Issue Review which will determine housing distribution across the district.

7.14 Taking into account the comments received during the 2015 consultation and additional evidence based work, a preferred distribution strategy has now been established (see the Single Issue Review Preferred Options document at http://westsuffolk.jdi-consult.net/localplan). For Newmarket, this means a total of 654 dwellings to be allocated up-to 2031. The reasons for this are summarised below:

7.15 Opportunities for growth in and around Newmarket are severely restricted by environmental constraints, the geography, history, and economy of the town. The town is situated very close to the district and county administrative boundaries to the east, south and west, and the A14 forms a physical boundary on the northern edge of the town. This physical boundary protects against coalescence with the village of Exning to the north, making undeveloped land to the north-west of the town particularly important in helping to maintain a gap between the two settlements. The constraints noted above affect areas to the east and south-west of the town, and archaeology and the character of the historic built environment restrict opportunities for development in the town itself. On top of this natural, physical and historic framework lays the land uses associated with the Horse Racing Industry, and the policy protection afforded to this historic, culturally and economically important activity.

7.16 In addition to these constraints, the further Issues and Options consultation carried out between August and October 2015 removed some sites from consideration as they were revealed to be either unavailable or unsuitable for development. Further work was carried out to find sites or identify elements of sites in sustainable locations that can be delivered without any adverse impact on the constraints identified above, or where adverse impacts were identified, provide mitigation to lessen those impacts. The results of this work and a reasoned justification for the discounting of sites can be seen in Appendix B of this document.

7.17 Between 1 April 2011 and 1 April 2015, 288 homes have either been built or gained planning permission in Newmarket. (See table in section 2).

7.18 In the context of the above, six residential or mixed use sites have been identified as being suitable for allocation in Newmarket to meet the distribution needs set out in the Single Issue Review, as outlined in the draft text and policy below.

Newmarket planning constraints map

Newmarket planning constraints map

View Comments (2) (2) Newmarket settlement map

Newmarket settlement map

View Comments (5) (5) Site N1(a) - Land at Brickfield Stud, Exning Road
(formerly part of N/09)

7.19 This site is part of a much larger site including Brickfield Stud and land to the west of Exning Road which was included in the Issues and Options Site Allocation document August 2015. The larger 18.2 hectare site (N/09) was discounted as unsuitable, due to its equine use and location. However, given the shortage of unconstrained sites in the town and need for housing land, a smaller 2.9 hectare site is considered an appropriate option. The preferred site is currently paddock adjoining the existing settlement boundary. This site is not constrained by any of the environmental, historic or physical constraints noted above, and is separated from the majority of Brickfield Stud by Exning Road. By keeping development south of the Brickfield Stud buildings and east of Exning Road the impact on the important green gap between Exning and Newmarket and loss of land in equine use is minimised. The remainder of the larger N/09 site considered in the August 2015 Issues and Options consultation will remain in the countryside and in HRI use. The council considers that this site should be allocated for residential development.

N1(a) site plan

N1(a) site plan

View Comments (7) (7) Site N1(b) - Land at Black Bear Lane and Rowley Drive junction
(formerly N/11)

7.20 This site comprises the historic (listed) Queensbury Lodge and adjacent paddocks. The grade II listed stables; cottage and lodge are all identified as listed buildings at risk in the Suffolk Register. There are tree belts on the paddocks and around the periphery of the site and it is identified as an important open space in the Newmarket Conservation Area Appraisal. The site lies adjacent to the High Street with residential development to the north and south. There is a complex planning history to this site. The site has recently been the subject of a proposal for a new large food-store, four retail units, a bar/restaurant, a petrol filling station, drive through restaurant, art gallery and picture framing and restoration business and parking (application numbers F/2013/0102/FUL). This proposal was refused at appeal. Any development on this site would need to facilitate the sympathetic restoration and viable reuse of the listed buildings, retain a horse racing industry related use on the site, and preserve or enhance the character and appearance of the conservation area. The potential uses and capacity of the site will be explored by the council and other stakeholders through the preparation of a development brief in line with Policy DM4 of the Joint Development Management Policies Document 2015.

N1(b) site plan

N1(b) site plan

View Comments (6) (6) Site N1(c)- Hatchfield Farm
(formerly N/14)

7.21 This is an area of farmland (Grades 3 & 4 agricultural land classification) bound by the A14 trunk road to the north, the Studlands Park housing estate to the west and open fields to the south and east. This site has been the subject of a planning application that was refused in June 2010 - reference F/2009/0713/ESO - for mixed use development to include 5 hectares of employment land and 1200 homes. An appeal was lodged against this efusal and a public inquiry was held in July and September 2011. The appeal was recovered for determination by the Secretary of State. The Secretary of State in accordance with the recommendation of the independent inspector (report reference APP/H3510/A/10/2142030) resolved to dismiss the appeal on grounds of prematurity (decision letter dated 22 March 2012).

7.22 Latterly the site has been the subject of planning application reference DC/13/0408/OUT for 400 dwellings which was recommended for approval by the council. The application was called in for determination by the Secretary of State and a public inquiry took place in April 2015. A decision is anticipated in early 2016.

N1(c) site plan

N1(c) site plan

View Comments (14) (14) Site N1(d) - Grassland off Leaders Way and Sefton Way
(formerly N/20)

7.23 This site comprises a strip of grassland (used for exercising horses) with an associated access track from Hamilton Road and is located within the existing settlement boundary. Residential uses are to the north and east and a gallop to the south. This site was allocated for residential development in the Local Plan 1995 (policy 4.4) with occupation tied to the needs of those employed within the racing industry. This site is reallocated for residential use to meet the needs of people employed in the Horse Racing Industry.

7.24 It is considered that a density of 20 dwellings per hectare should be applied given the prevailing site constraints including access issues. The site could be linked to the adjoining site, N1(f) - Land at Phillips Close, which is under the same ownership, (primarily for reasons of securing an appropriate access).

N1(d) site plan

N1(d) site plan

View Comments (6) (6) Site N1(e) - Former St Felix Middle School Site
(formerly N/32)>

7.25 This site comprises playing fields, hard-standings and some other outbuildings associated with the former school and lies to the north-east of the town within the settlement boundary. The site, as featured within the Issues and Options consultation document (2015) comprised the footprint of the former school only. It is considered that the site should be allocated in its entirety although the suggested residential capacity reflects the fact that there should be no net loss of the audited open space. It is considered that an approximate capacity of 50 units would be appropriate.

7.26 The site is currently being held by the Suffolk County Council pending possible future education need(s). The future of this site will be clearer once the Secretary of State's decision on the called in Hatchfield Farm application is known. However the fact that provision has been made (by legal agreement) for a new school on the Hatchfield Farm site (Site C - formerly N/14) should growth be sufficient to trigger this requirement suggests that this former school site is likely to be deliverable for residential purposes within the plan period.

N1(e) site plan

N1(e) site plan

View Comments (7) (7) Site N1(f) - Land at Phillips Close
(formerly N/33)

7.27 This existing residential site is adjacent to residential development on two sides, and land within equine use on the other two sides. The site has been developed at a relatively low density and it is considered that redevelopment/ intensification of the existing use would achieve a more efficient use of the site. This is an area of the town where equine related land uses are prevalent, and the developer is promoting the site for residential use by those connected with the industry itself. The development should be designed to ensure an appropriate access into the adjacent site N1(d) can be provided if required.

N1(f) site plan

N1(f) site plan

View Comments (4) (4) Policy N1: Housing and Mixed Use Development in Newmarket

The following sites are allocated for residential or mixed use development in Newmarket:

New reference
(former reference)

Location

Area
(hectares)

Indicative capacity

N1(a)
(formerly N/09)

Brickfield Stud, Exning Road

2.9

87

N1(b)
(formerly N/11)

Land at Black Bear Lane and Rowley Drive junction

3.3

TBC (Design brief required)

N1(c)
(formerly N/14)

Hatchfield* Farm

64.7

Mixed use to include 400 dwellings, a minimum of 5ha employment and 1.5ha school site.

N1(d)
(formerly N/20)

Grassland off Leaders Way and Sefton Way

2.2

44

N1(e)
(formerly N/32)

Former St Felix Middle School Site

4.5

50

N1(f)
(formerly N/33)

Land at Phillips Close

2.09

73

These sites are identified on the Policies Map.

Strategic landscaping and open space must be provided on all sites to address the individual site requirements and location.

Site (a) strategic landscaping and open space must have particular regard to the existing field pattern and existing hedgerows. Sustainable travel provision including facilities for pedestrians and cyclists and links to existing networks should be made.

Site (b) will be the subject of a development brief that will be prepared in consultation with the landowner and approved by the council prior to any planning permission being granted. Any scheme for development of the site must facilitate the restoration and appropriate reuse of the listed buildings, have regard to their setting, be sympathetic to the character and appearance of the conservation area, and retain a horse racing related use on the site.

Site (c) strategic landscaping and open space must have particular regard to the relationship between the site and the Breckland SPA and with other designated nature conservation sites in the vicinity. The development must provide measures for influencing recreation in the surrounding area to avoid a damaging increase in visitors to sensitive ecological sites. The site will provide a minimum of 5ha employment land and a 1.5ha school site. Precise numbers and the distribution of uses and access arrangements will be informed by a detailed masterplan for this site.

Site (d) is allocated for residential use to meet the needs of those employed in or retired from the Horse Racing Industry subject to compliance with all other policy requirements.

Site (e) development must make provision for the retention of the existing tennis courts and audited open space for public use and provide access and connectivity to this facility and open space from George Lambton playing fields.

Site (f) is allocated for residential use to meet the needs of those employed in or retired from the Horse Racing Industry subject to compliance with all other policy requirements. Archaeological evaluation of this site will be required at an early stage.

Development briefs compliant with Joint Development Management Policies Document Policy DM4 will be required for all sites where appropriate.

*The Hatchfield Farm site is subject to a current planning application which is yet to be determined. This policy will be reviewed, if necessary, following the secretary of State's decision.

View Comments (14) (14) Question 7:

Do you agree with the draft policy above? Are there any other issues which you feel should be taken into account in the policy?

Alternative option:

7.28 No suitable alternative site options were available.

Employment sites

7.29 A number of proposed and existing employment sites in the town have been allocated in Policies EM1 and EM2 and are shown on the Policies Map. More information about employment uses across the district can be found in section 16 of this document.

Retail and town centres

7.30 The area to be covered by a town centre masterplan and a retail allocation are shown on the Policies Map and addressed by Policies RE1 and MP1. More information about retail and town centre masterplans can be found in section 17 of this document.

Settlement boundary changes

7.31 Settlement boundaries in this local plan, as shown on the Policies Map, encompass the developed area of settlements and peripheral allocated sites. The settlement boundary will be redrawn to incorporate those sites considered for allocation within this Preferred Options document.

Proposed change to settlement boundary Justification

Extension to the east of Fordham Road and south of the A14 to include Hatchfield Farm.

To reflect allocation N1(c)

Extension to the east of Exning Road and south of Brickfield Stud.

To reflect allocation N1(a)

View Comments (10) (10) Question 8:

Do you agree with the proposed changes to the settlement boundary? Are there any other changes to the Newmarket boundary which you feel should be made?

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