SCC Response Stradbroke Queen Street 4005/14 19th June 2015 1

Dear John,

Proposal: Erection of 54 dwellings together with associated garages, hardstanding, drainage infrastructure including new accesses

Location: Grove Farm, Queen Street, Stradbroke Application No: 4005 / 14 Thank you for your consultation letter dated 31st March 2015. Based on the information provided on the MSDC web site, and a joint site visit carried out on the 20th April, I offer the following comments regarding this application. I also forwarded comments to you by email on 22nd April. I have based my response on Site Layout Plan 30-01 Revision H. The site lies within countryside beyond the village envelope and is partly within the Stradbroke Conservation Area. Both Grove Farmhouse and Stradbroke Hall are listed buildings, the medieval moated site is on the Historic Environment Record (SBK003). The two historic barns, Grove Farm Barn and Hall Barn are situated within the Conservation Area. The conversion of these two barns is subject to a separate planning application although they are both linked in with the proposed housing layout in terms of position and access. The development site area extends beyond the ancient field boundary hedgerow and into the low lying meadows which are situated on the east edge of the village. Stradbroke and its surrounding landscape are situated within the Plateau Claylands landscape type (Suffolk LCA 2008/11). At the more local level this site has a special character which is created by a collection of historic landscape elements. These are the ancient hedge, moated farmhouse, listed buildings and barns, mature/veteran trees, and the meadows which follow the watercourse to the east. The combination of historic features and the attractive landscape setting creates a site which will be highly sensitive to inappropriate development.

Your Ref: [ ]

Mr J Pateman-Gee Planning Services Mid Suffolk District Council 131 High Street Needham Market Suffolk IP6 8DL

Ms A Westover Landscape Planning Officer Natural Environment Team Suffolk County Council Endeavour House (B2 F5 55) Russell Road Ipswich Suffolk IP1 2BX Tel: 01473 264766 Fax: 01473 216889 Email: anne.westover@suffolk.gov.uk Web: http://www.suffolk.gov.uk Your Ref: 4005/14 Our Ref: Landscape/MSDC/Stradbroke Date: 19

th June 2015

DISCLAIMER: This information has been produced by Suffolk County Council's Natural Environment Team on behalf of Mid Suffolk District Council, at their request. However, the views and conclusions contained within this report are those of the officers providing the advice and are not to be taken as those of Suffolk County Council.

SCC Response Stradbroke Queen Street 4005/14 19th June 2015 2

There appears to be no LVIA or landscape appraisal of the site, nor an appraisal of the potential impact of development on the area and wider landscape. I would expect an appraisal to underpin proposals for development in such a sensitive location. Three plans in the Planning Statement titled ‘Respecting Stradbroke’, Opportunities for Enhancment’ and ‘Site Analysis’ are useful and have highlighted some key aspects of the site. A set of ‘Landscaping Plans’ Sheet 1-3 have been submitted as part of the barn conversion application 4006/15. These give a very broad indication of proposals for hard and soft landscape detail for the housing scheme and include the two barns. My particular concerns relating to this development are as follows: Site frontage; west site boundary The layout with its new access, visibility splays, crossing point and footway will necessitate the removal of the frontage hedges and three oak trees. Two of these trees located to the front of Grove Farm Barn although mature are suffering from significant crown dieback. The trees are identified as T3 and T4 in the arboricultural report with one, T3 is proposed for removal due to its condition. The third tree grows on the highway verge to the north of the site area and is located within the proposed visibility splay. This large oak tree is not included in the arboricultural report but may be in a declining condition, indicated by the presence of a mass of ivy covering the main trunk and crown of the tree. However the potential for positive management and the likelihood of the tree having habitat value (bat and bird species) means that the loss of this tree needs to be properly evaluated. The loss of these three trees will have a significant effect on the verdant appearance of the street, the proposed layout needs to address the loss of visual amenity and ensure that the design accommodates sufficient space for new hedge and trees. It is unlikely that the new footway can be accommodated without piping the drainage ditch due to its width and the space needed to accommodate a new footway. Highway officers may also comment on this matter. The proposed two/half storey units will impose on the street frontage and will appear out of character and unusually tall in this location. The crinkle-crankle wall alongside the entrance road could create an attractive feature subject to considering how this fits within a comprehensive hard and soft landscape design concept for the development. Rationalisation of paths to properties could also result in more space for hedges and simplicity in the layout. East site boundary and loss of mature field hedge The proposed site area disregards the presence of the field boundary hedge and ditch line. This hedge provides a green corridor linking the moated site with the hedge on the eastern edge of housing off Grove End/Westhall and continuing north to meet the stream running parallel to Rattlerow Hill. It forms a strong and distinctive landscape feature which

SCC Response Stradbroke Queen Street 4005/14 19th June 2015 3

provides some natural screening to the site area. The hedge is highlighted on two of the Planning Statement plans but critically not indicated on the Site Analysis plan. When assessed against the 1997 Hedgerows Regulations this hedge qualifies as ‘Important’. We have noted that on the Stradbroke tithe map (1840) and Apportionment (1841) that the hedge is shown between field parcels 244 and 322. This is also included in the Historical and Archaeological statement. Therefore it can be demonstrated that the hedgerow pre-dates the Inclosure Acts and appears to qualify as ‘Important’ under the 1997 Hedgerows Regulations part II, Criteria 5 (a). Its importance also derives from the links to a pond and moat, the presence of mature trees and the adjacent ditch. Other contributory factors may include wild flora species however as the hedge has not been included in the Ecological survey this aspect is not possible to ascertain. The hedge could form a natural boundary to a development area and be managed as a landscape feature offering huge benefits (visual amenity, landscape and ecological value) to the development. Northern boundary hedges and trees The northern boundary hedge with its large trees (ash, oak and field maple) has a high landscape and historic value. The intermittent large mature trees, mainly oak and ash have been surveyed but there appears to be little consideration of their local and wider landscape value and the space they need to continue to thrive. There will be a need to ensure their setting is preserved and enhanced and to ensure that there is space to prevent future conflict with residential amenity and property. There appear to be some anomalies between the arboricultural survey, the Site Layout plan (Rev H) and the actual trees on the ground. Some clarification will be needed to ensure that important trees are not overlooked such as T29 Ash. Further consideration of the needs to protect the visual amenity and habitat value of this magnificent tree line with the accompanying hedge and scrub layer is essential. As currently designed the proposed layout presents an unsatisfactory relationship to the boundary hedge and trees. Examples of the plots that are located too close to certain trees are Plot 5, 6, 16, 24, 25 garages, 29a, 28a, 26a, 27a, 41 and 48. Open space and permeability In order to ensure that the northern boundary trees have a successful relationship to new buildings it would be beneficial to retain them in a public space and/or ownership. These large (in some cases veteran trees) with their wide canopies do not lend themselves to being ‘placed’ in small residential gardens where they will be vulnerable to inappropriate or poor management. The creation of a public open space/walkway along the northern site boundary linking into the new estate road could provide a solution. Trees and hedges would form a boundary landscape feature outside private gardens. There may be scope to create pedestrian links into/from the neighbouring development off Grove End. The provision of the wet meadows to the east of the site as open space could be beneficial in terms of providing accessible natural greenspace when the ground is sufficiently dry. It is not clear whether grazing of these meadows will continue although I note references to

SCC Response Stradbroke Queen Street 4005/14 19th June 2015 4

this form of management in the Planning Statement. It is not clear to what extent they will provide for the need for active play for young children and teenagers. Formal play equipment and kick-a-bout space will appear out of character in this landscape. There may be an aspiration to enhance existing Parish facilities but these are not suitably located to benefit children living within the new development. I would imagine that provision of some play space on a development of this size will be needed. The relationship of housing to the open meadow is not satisfactory. The loss of the boundary hedge and the layout showing new houses positioned such that they back onto the meadows will compromise their landscape value. With the existing hedge removed the view from the open space will be of rear gardens, fences and sheds. The end gable of the terrace proposed in the south east corner of the plot will cut into the meadow and is likely to appear harsh and imposing. The Landscape Plan sheet 3 of 3 indicates how the new development edge will form a hard straight edge to the meadows. The view of new houses and the existing estate will become more prominent if the field hedge is removed. The resulting cumulative impact of estate houses on the valley landscape will be significant. It is this same landscape, the grazing meadows and woodland which has been identified as being preserved under the development scheme but it is not clear how this will be managed nor whether there will be wider public access. There are currently no footpaths traversing the meadows. Impact on the moat and setting of the Conservation Area The plots 15 – 20 are placed relatively close to the moat on its northern side. This proximity and impact on trees could impact visually on the setting of the moat/Conservation Area. The trees located to the east of Grove farmhouse could offer a buffer between the historic elements and new housing but these are shown to be removed by Plot 12 and its garden area. The proposed track to the Hall barn is tight to the hedged edge of the moat on its eastern side. Depending on the detail required here there could be an impact on this vegetation. Careful design treatment and management will be needed. The conversion of the Hall barn (4006/14) raises some queries. There is little detail relating to the design and extent of the property and the subsequent impact on the field pond, the moat and existing trees on the moat edge. The space to create a new property with usable garden area and parking is limited. The management of the pond and treatment if its surrounds could become problematical especially if it becomes dissected in terms of ownership. In terms of the conversion Grove Farm barn clarity over the proposed treatment on the road frontage (and the loss of the two oak trees) and the frontage area to the estate road is needed. I assume the rear garden or parking area will extend across the current access drive to the boundary with Grove Farm House but this can also be clarified. Cumulative effects in relation to other proposed development The proposed COOP store site to the south of The Hall and moat is another development which if it proceeds in the future will have an effect of the landscape setting of this part of

SCC Response Stradbroke Queen Street 4005/14 19th June 2015 5

the village and conservation area. The cumulative effects of both developments on the setting of the Conservation Area and moated site are likely to be significant. If a new store is needed to serve the village then perhaps this should be considered in conjunction with the current application. Development of the road frontage areas to the north and south of The Hall with the resulting loss of vegetation may undermine the high quality of the landscape surrounding the moated site and listed buildings. If the site/s area developed then there is a question relating to the management, farmed or other use of the remaining meadow land. The matter of field access for management may also need to be considered. Any change in access arrangement which results in the need for further hedge loss would be unwelcome. CONCLUSION I have concerns relating to the lack of an assessment, landscape design input and the impact of development. My concerns are discussed above and relate to the following key aspects:

The lack of a comprehensive landscape appraisal of the site area and assessment of the landscape impacts arising from development of this site has resulted in a scheme design which will have significant detrimental landscape impacts. Such an assessment should inform scheme design and landscape mitigation.

The site area extends into the meadow land to the east resulting in an ancient hedge, (defined as ‘Important’ under the 1997 Hedgerows Regulations) and ditch system being destroyed and compromising both landscape, (and associated habitat value), in this area.

The development will compromise the presence of a significant hedge and large trees particularly along the northern site boundary.

The proposed design for the frontage of the site does not respond effectively to the local character of the village and the street frontage.

There are aspects of the design of the external spaces within the scheme which have not been sufficiently addressed and which cannot be left to condition. Given that the application is in full design matters such as the arrangement of parking, alignment and treatment of boundaries and space for new planting (whether tree/hedge/shrub) need to be resolved prior to determination. The detail of hard and soft landscape work can be required by condition as needed and if the development is approved.

RECOMMENDATION Based on the information provided to date the proposal is not acceptable and I recommend that it should be refused for reasons as follows: Reasons

1) The provision of a landscape and visual impact assessment is required as it is relevant, necessary and material in accordance with paragraph 193 of the NPPF.

SCC Response Stradbroke Queen Street 4005/14 19th June 2015 6

2) The proposed design for the frontage of the site does not respond effectively to the local character of the village and the street frontage.

3) The proposal as presented does not adequately safeguard the large trees and

hedge particularly on the northern edge of the site

4) The proposal as presented does not retain the hedgerow in the eastern portion of the site

5) The proposal as currently presented will result in housing becoming overly

prominent in views from within the neighbouring areas of the village and the landscape to the east.

Please let me know if you have any queries relating to matters raised in this letter. Yours sincerely Anne Westover BA Dip LA CMLI Landscape Planning Officer