The Local Plan is what it is - confusing (possibly deliberately so!), impossibly lengthy and irrational in its conclusions.
That to one side, it is "supported" by the Lichfields documentation, which is of unbelievably poor quality. From an academic perspective, it should be observed the Reports appear to have been written with the sole objective of supporting the Council's declared preferences. Regardless of the merits of any site for its planned purpose, here are some of the more obvious failings of the support documentation:
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Only six criteria have been used for the evaluation of sites
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No consideration has been given to the impact on the local community. Rather, they have excused themselves from a worst-case analysis on the basis that a detailed usage is unknown!!
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All criteria have been given an equal 'weighting'
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No consideration appears to have been given to strategic siting e.g. east or west of the A14 or proximity to a railway line, where required
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Infrastructure development costs have not been properly estimated
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The markings against various criteria are perverse e.g. a mark of 5 is given to land put forward for port-related use, but a score of ZERO is given to land where they haven't troubled themselves to identify or speak to the landowner
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The recently-published Traffic Study does not reflect site use
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Consequently, no conclusions have been drawn about any new road access that will be required for different sites
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There has been no proper assessment of the likely increase in HGV traffic for any proposed development
Documentation: In Section 1.18 of their Draft Plan, the Suffolk Coastal District Council identifies the Port of Felixstowe, Adastral Park and Sizewell as the existing major employers in the Region. In this context, it states: ….. “The Local Plan will seek to ensure that appropriate provision of land, associated infrastructure and supply chain networks are promoted over the plan period to maintain the contribution made by these key economic drivers"
Comment: On the face of it, this is a laudable objective, but it needs to be viewed beyond the needs of the three employers singled out. The Council's own consultants have advised them “office-based jobs are likely to grow but this is not the case with distribution and manufacturing jobs”. Their advisers are almost certainly correct about office jobs and provision does need to be made for growth in this sector (whilst being mindful of the trend towards home-working). However, Distribution-related jobs (in particular Felixstowe Port and it's related port-centric operations) are unlikely to grow at all in the coming years and may decline significantly. This will be an unpalatable message for Councillors, but it is a far more rational analysis of the true position. The good news is that employment could well grow elsewhere, off-setting the possible reduction in employment opportunities within the Port.
Documentation: "...the Port of Felixstowe has fairly consistently maintained market share and position as the UK’s largest and busiest container port...."
Comment: Yes, it has, but this is no logical basis for predicting the future. The Port's management did well to identify the trend towards containerisation many years ago and establish it's current position. However, the game has changed. For some while now, there has been a huge surplus of container handling facilities nationwide and Felixstowe will do well to hold on to its market share in the face of strong competition from the London Gateway and other fast-developing ports, many of which are better-situated. As the Department of Transport's report makes clear, there are significant 'connectivity' issues facing Felixstowe. It states: "Connectivity issues include the need for greater resilience and capacity on key strategic road and rail corridors in East Anglia, including the A12 and A14, and the Felixstowe to Nuneaton (F2N) rail route"
In fairness, other ports have their own issues, so all is not lost. However, most people agree any significant road or rail improvements are a long way off and allocating them Innocence Farm for development purposes solves nothing. The Port is not using its existing warehousing capacity and, within its existing boundaries, has a huge acreage available for future development. It has chosen not to develop this land to date, probably because the trend is away from container splitting, with an increasing number of containers being transported directly from the ship to their final destination. Solving it’s ‘connectivity’ problems is the Port’s most pressing need, particularly the rail link through to the Midlands.
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Documentation: "....The assumptions and implications for Felixstowe are that the Port will retain its historical market share of UK container throughput...."
Observation: Let us hope so, but this is an outrageous unsupported statement from supposedly professional advisers; indeed, it is a triumph of optimism over proper analysis and is based solely on the supposition, ‘the Port has maintained it's market share to date and will carry on doing so'. A proper assessment would take account of the Department of Transport's 2018 Port Connectivity Study, which cites 'connectivity' as probably the most important factor affecting the development of any UK port. About the Haven Ports, they comment: In view of the national hinterland for these ports - especially Felixstowe - connectivity issues reported relate to strategic roads and the rail network where there are capacity and capability issues which may constrain growth. Even the SCDC acknowledges "2018 Local Plan 1.28: The A14 is the only trunk road in the District which connects Felixstowe with Ipswich and locations outside of the District. The A14 is an important freight route and is fundamental to the success of the Port of Felixstowe and the communities surrounding Ipswich. At times the A14 is blocked which creates major impacts for residents, visitors and businesses in the area as there is no suitable alternative route. Over the plan period managing the capacity of the A14 as well as considering alternative strategic routes will be necessary".
Straight from the horse's mouth, no less! What, pray, are they intending to actually do? Who amongst us is willing to speculate on the timing of a North/South A12 'motorway', a second Orwell Bridge or a double-track rail link from Felixstowe to the Midlands. Common sense tells us these remedies won’t happen, not in the short-term and probably never.
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With regard to customers, we are aware the Port has a very strong relationship with Maersk, by far its largest customer. Also, the Port’s operators, Hutchinsons, are probably well-placed to offer deals involving other ports. For this reason, alone, a rapid decline is unlikely. However, other, smaller Port users may not be so tied in. It is in this context, we pose the question: "If you are the managing director of a worldwide distribution company, currently using Felixstowe, but given the new range of options available to you, are you going to automatically renew a long-term contract when it expires? We think not! In the next year or two, this question will be addressed by many shippers and the Port will do well to hold on to them.
CONCLUSION: EXPANSION OF THE PORT'S WAREHOUSING AND STORAGE CAPACITY IS CERTAINLY NOT GOING TO BE A REQUIREMENT
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Documentation: Office based jobs are expected to record the most significant growth, and to a much lesser extent, distribution based jobs. Manufacturing based jobs are forecast to decline across all local authority areas in the IEA over the period to 2036.
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Comment: This is probably a sound judgement-call and we should do all we reasonably can to ensure plots are available for the development of small and medium-size office-based businesses. However, there are ample brownfield sites, within and outside the Port’s boundaries, earmarked for this purpose already. It is acknowledged many of these have underlying issues affecting the cost of developing them. However, this fact does not justify grabbing hundreds of acres of prime agricultural land for development purposes - just because it is a cheaper option.
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Objective 3 - Identifying The Main Issue
If you can cope with a plethora of detailed information, please see the Joint Parish Councils' response to the Draft Plan at http://kirtonandfalkenham.suffolk.cloud/link-to-scdc-local-plan/. This superb document should leave you in no doubt about the case we are making.
As stated on our Home page, developing Innocence Farm, as proposed within the draft SCDC Local Plan, would give rise to a catastrophic level of noise and light pollution. Those behind the proposal offer bland reassurances these issues can be overcome. That is not the case and any suggestion to the contrary is wholly misleading - existing light and noise pollution throughout our locality testifies to that fact. Developing Innocence Farm, as proposed, would simply blight the lives of everyone living in Kirton, Falkenham, Trimley and far beyond.
All of this said, such a proposal might have merit if there were extremely strong economic, social or similar arguments to support it. In the event, the Council's own consultants state employment growth in the SCDC area will come mainly from the Office Sector and hardly at all from Distribution / Shipping. Land in the area, already approved for industrial development purposes far exceeds the Council’s stated requirements and those requirements will later be shown to be highly suspect. No – this is land-banking on a grand scale and, later in the web site, we will identify the driving forces behind this headlong, mindless rush to include Innocence Farm within the Local Plan. We think we know the reasons the Council’s Officers are turning a deaf ear to anyone trying to talk sense to them. Let us be clear though,
THERE IS NO ECONOMIC, SOCIAL OR SIMILAR ARGUMENT FOR THE INCLUSION OF INNOCENCE FARM WITHIN THE SCDC LOCAL PLAN
Also, we ask what has happened to the Council's earlier Policy? To quote the Council:
"Felixstowe Peninsula: General Policies The Local Plan states that further large scale development would be inappropriate because of the potential damage to the character of the Peninsula and its settlements. New Housing: Scale and Location The Structure Plan does not include specific housing requirement figures for the Felixstowe Area. The Trimleys Trimley St Martin and St Mary have been identified as Villages for a number of reasons: 1. to protect and recognise their individual character; 2. to allow a period of assimilation after two decades of rapid growth; 3. to maintain the open character of the land which separates them from each other and from Felixstowe. Estate-scale development, therefore, will be strongly resisted"
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So what is going on here and what is the true reason the Council feels they have to perform a U-turn, don the blinkers and drive blindly forward to include this huge parcel of greenbelt countryside in their Plan? We think they are doing so for two reasons;
1. Although adjacent Districts are required by law to work together for the common good, all the evidence suggests Babergh, Mid-Suffolk, Waveney and Suffolk Coastal are doing the opposite. Each District Council appears desperate to offer relatively cheap business development land, presumably because of the potential business rates income that might accrue. They will claim they are working together, but all the evidence is to the contrary and the result is a huge over-allocation of development land across those Districts. Statistics will be published in this site in the next day or two, supporting this statement.
2. Setting Reason 1 to one side, the inclusion of Innocence Farm is only rational if credence is given to the claimed needs of Felixstowe Port; no other employment sector has called for the inclusion of development land on this scale. It is easy to demonstrate the Port doesn’t need the land, so why ask for it? With some level of certainty, we can say Innocence Farm has only been included in the Local Plan following considerable lobbying by the Port's Owners, acting in concert with the landowners. We know meetings have taken place, both in Felixstowe and Cambridge, involving the Council, the Port and the Trustees of Trinity College, Cambridge. We will take a closer look at the landowners later on. We note Bidwells are advertising this land for sale already, ahead of any approval of the Local Plan. Many will agree this indicates a high level of collusion between the Council and Trinity College. Also, the consultation process is clearly a sham, as the decision to include Innocence Farm would seem pre-determined. One suspects Trinity College wish to be granted any form of planning consent for Innocence Farm, as long as it’s not for the purpose of farming! Innocence Farm (approximately 112 hectares) is worth approximately £2.352M to Trinity College with the existing planning consent. If developed for Office or Industrial use it would be worth £67.76M. If developed for housing it would be worth £291.2M. Let us be in no doubt about what is really driving this - it is "money", not the needs of Felixstowe Port!! It is not a huge mental leap to imagine the considerable pressure Trinity College has applied to the Port's owners and the Council's representatives.
All involved will deny this to be the case, of course, but the true position does need exposing. A very close examination of the Port’s stated requirements is warranted and we will do just that.​
Objective 4 - Identifying Self-Interest
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ABOUT TRINITY COLLEGE - SOME INTERESTING STUFF
What’s Trinity College Worth? – we’ll let the media answer that
https://www.varsity.co.uk/news/14626
It would appear Trinity College is probably the wealthiest college in the UK, and certainly the wealthiest of all Oxbridge colleges, with land assets under management valuing close to £1.34 billion pounds. They have a broad and diverse investment strategy – we find nothing wrong with that (on the face of it - read on!).
What Is Their Land Investment Policy?
Trinity bought the Trimley Estate in 1933 with a "long view " to commercial and residential development. Their time-line of 85 years points to an underlying intention to sell every acre of the Trimley Estate for high-value residential use and profit. The current proposed industrial usage would appear to be no more than a way-point in their eventual plan, which is probably housing. This said, affordable homes appear not to figure! Please follow the link
What Is Their Moral Position?
Again, we would let others comment on Trinity’s moral integrity. For our part, we recognise the Trustees have a responsibility to optimise the assets of their Trust. However, we argue an institution of Trinity’s standing is bound, also, by a social obligation, which should guide their investment strategy. The article at the following link makes horrific reading
https://thetab.com/uk/cambridge/2013/10/02/trinity-making-a-killing-26545
We would highlight a quote from this article that reads:
“‘It’s simple: if it’s wrong to do something it’s wrong to profit from that thing.”
Here is a link listing their investments (it may not be right up-to-date).
All of this needs to be viewed in the context of the college motto, which reads
"Virtus Vera Nobilitas" (Virtue is true nobility)
The information above combines to suggest Trinity’s thirst for making money far outweighs any consideration of what is virtuous or noble. Indeed, they appear to represent the unacceptable face of elitism in this country, fully prepared to set aside their stated principles and worship at the Altar of Wealth Creation. They have applied this rule to our own situation at Trimley and Kirton. It would seem they are quite willing to allow communities to be sacrificed, if they can make more money by doing so.
Trinity College, Cambridge is an organisation we can reasonably expect to be a shining example of virtue and moral fortitude. One that sets a moral example consistent with their world-wide reputation for academic rigour. Yet, they appear willing to flunk this responsibility, by acting as eco-vandals and social pariahs. As an organisation that prides itself on its reputation, we believe Trinity should be beyond reproach in all its actions, especially if virtue is the true nobility!
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Objectives 4 & 5 - Join Us
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It is predictable we will continue to hear placatory noises about the likely effects of including Innocence Farm in the Local Plan. We will be accused of behaving as NIMBYs (Not In My Back Yard), which is a label, easy to pin on people. However, it is a tag that cannot apply if a particularly anti-social proposal is unsupported by reasoned argument. It follows, what is most important is what you believe deep down. Do you believe the Port needs this Trinity College owned land, or not?
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If you are persuaded by the arguments this site presents, then please consider committing to an active role in the campaign. This issue is of huge significance to everyone living within 5 miles of Kirton. You may feel you can take limited actions only, perhaps by writing a letter and displaying a house placard. On the other hand, you may recognise you can have a much greater impact by doing no more than bringing this site to the attention of your social media contacts. With only a modicum of effort, everyone can help, if only by canvassing the support of their immediate neighbours.
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If you have personal skills that might help and a little time to give, please make this known to klg@innocence.uk.com The website author is a neanderthal when it comes to social media and could do with help on this, web site management and other fronts! It would be good to know what part you are willing to play in the Action Plan.
It follows this web site is WORK IN PROGRESS. Skilled help is needed! It is hoped a multi-skilled steering group can be put together prior to the end of August, 2018. The Steering Group will be asked to lead the campaign and ensure it snowballs over the course of the coming weeks.