24 April Mr Charles Judson Planning Officer St. Edmundsbury District Council West Suffolk House Western Way Bury St Edmunds IP33 3YU

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1 24 April 2017 Mr Charles Judson Planning Officer St. Edmundsbury District Council West Suffolk House Western Way Bury St Edmunds IP33 3YU Dear Mr Judson Re: DC/17/0521/FUL Creation of municipal operational hub comprising waste transfer station, household waste recycling centre (including reuse building), fleet depot (including offices), public realm maintenance depot and associated infrastructure including accesses, internal roads, parking, weighbridges, landscaping scheme and shared use path to connect existing footway on Barton Hill to proposed accesses Introduction The Suffolk Preservation Society (SPS) responded to the previous consultation exercise for this proposal and we raised concerns regarding the appropriateness of the use of this unallocated site which is located in countryside outside the town boundary (see our letter dated 30 March 2015). We called for a thorough assessment of alternative sites and a sequential approach to be taken to them. We are pleased that this was subsequently carried out but disappointed that the exercise arrived at the same conclusion. SPS remain opposed to the choice of site for this facility due to the significant landscape and visual impacts which will arise following construction and operation. The site primarily relates to the open countryside (not to the British Sugar site to the south) and we consider the impacts on countryside to be unacceptable. Therefore we have commissioned professional landscape advice to inform our representation and, while we remain unconvinced by the suitability of this site for such a large scale and strategic waste use, we wish to make the following comments and recommendations regarding the details of the proposed scheme: Loss of existing landscape features The SPS notes Figure 12 Identified growth potential around Bury St Edmunds. It is in this figure/plan that Nathaniel Lichfield and Partners highlight the area to the north east of the proposed site as being a landscape buffer. Given this informal designation we welcome the placing of new buildings in the lower parts of the site but have concerns regarding the lack of value placed on protecting existing landscape features within the landscape buffer area.

2 The site forms a buffer between the built up industrial edge of the town and the countryside and is therefore sensitive to change. The landscape character of the site is formed by its wider countryside setting to the north and the mature oak trees that are important features within it. The northern boundary to the site area, Fornham Road, is particularly attractive and relates to the wider open and rural landscape. A key feature of this landscape is the scattered mature oak trees which form both a strong visual landscape element and important habitat refuge for wildlife. The roadside trees contribute to the local landscape character and the need to recognise and address this is highlighted in the 2010 Core Strategy DM Saved Policy DS3. Two of the oaks lie on the northern edge of the proposed site, one in the highway verge and one set back at the edge of the track leading to the collection of farm barns (Hollow Road Farm). The latter tree is particularly magnificent in terms of its size and form and both trees reflect and enhance the character of the area and road. The larger oak has been classified as a Category A tree within the Arboricultural assessment. As these and the other roadside oak trees mature both their wildlife and landscape value will increase. This will also add to the value that mature trees have in an area which is increasingly under pressure for development. We object to the loss of these trees and given the substantial extent of the site area we consider that it should be feasible to retain these two oaks, and request that they be designed into the scheme as key landscape features. This should be possible through minor design changes to the access arrangements and the alignment to the proposed roadside footway. We have seen no explanation in terms of design detailing as to why the access cannot be designed to accommodate the important oak tree. A previous design iteration (shown in DAS Fig 3-1) included one access only into the site and it is clear that from a landscape impact perspective this arrangement would be less damaging to the local environment. Furthermore, we suggest that further detailed consideration be given to the design of the 1.8 metre wide footway/cycle way from Barton Hill to the A134 roundabout. The submitted plans indicate that this footway will conflict with the semi-mature oak trees growing along the back of the verge. Again we are disappointed that there has been little attempt to retain and enhance the existing landscape character of the area. No compensatory planting roadside planting has been promoted by the applicant and yet it is these highway trees which offer a measure of visual compensation and add to the landscape character and quality of the road scape. Light Pollution We have concern over the lighting strategy and plan, and note that the larger proportion of the site area (in green) is proposed to be lit from 05:30 to 22:30 with the orange area just two hours shorter than this period. This will create light pollution for extensive time periods. Many of the lighting positions coincide with proposed tree planting (oak, field maple and alder) particularly in the vicinity of the eastern access into the site. These obvious conflicts should be addressed by the applicant. The impacts from light spill arising from this portion of the site are likely to extend beyond the site to the east, as no additional landscape mitigation to the countryside edge has been proposed. Cycleway and Footpath location Noting that SCC are joint applicants to the development, we request that the roadside boundary treatment is reconsidered by locating the new footway/cycle route into the site area behind the 2

3 highway verge and new planting belts (more akin to the DAS Fig 3-2 and 3-3). A new roadside hedge (set back from the verge) could be included with the SUDS areas and additional planting lying to the south side of this. This would result in a softer roadside frontage and a scheme better relating to landscape character. We are not entirely clear whether new highway footway lighting is proposed to be included as part of the scheme or at a later date. However, as highlighted above, we have significant concerns about light pollution into the wider countryside that will arise from the scheme. Proposed Mitigation The character of the Fornham Road is described in the LVIA at Table 9. This also describes the substantial change that will arise from the introduction of the new access to the site, footpath, lighting and road markings. We anticipate that this change will be significant and adverse (not slight ) even after the new planting has become established. It is therefore essential that the proposed mitigation is sufficient to adequately mitigate the many harmful visual and landscape impacts that will result. The SPS note the following extract taken from page 16 of the DAS but question whether the submitted scheme will achieve the elements described in this statement: The planting layout has been designed to reflect not only the existing landscape character of the surroundings but also to enhance amenity and mitigation in the form of screening and loss of vegetation. A native woodland mix along the western boundary is proposed which would tie into the existing vegetation on the embankment and would also link up well with the proposed bund along the northern boundary. The landscape design opens up to the east in a more exposed nature and the landscape proposals for this area of the site are for hedgerows with sporadic trees to reflect the existing hedge along the eastern access road whilst providing a positive arrival into the site. However, having considered the planting layout in detail, we would make the following observations: The LVIA viewpoint 1 shows the wider significance of the two oak trees proposed to be removed in addition to highlighting the need for a strong boundary hedge and new trees. The lack of suitable space for internal screen planting is of concern. Internal tree/hedge planting would help provide many obvious benefits including visual relief for the large expanse of car parking and welcome shade for vehicles in hot/sunny weather conditions. Filtering of dust and pollutants, internal visual screening and masking of lighting may also be important considerations. The LVIA viewpoint 2 shows how prominent the development will be when viewed from the east. We suggest that further landscape mitigation could be provided by additional tree planting alongside the existing boundary hedge, and located within the blue line indicating the applicant s ownership. However we also note that the field hedge (hawthorn with some elder) is subject to a proposed new opening labeled as occasional access and informal turning head (farmland). This is indicated on Plan Proposed site layout Sheet 1 of 2. An opening of some twenty metres wide is indicated further opening up views of the site from the east and fragmenting another key landscape feature. We have not located any justification for this hedge removal and are unclear why the farm or field access cannot continue to be from the existing point of access to the south, off the current farm track. It is also noted that the Landscape Proposals plan does not make matters 3

4 clear with respect to the retention or otherwise of the remaining hedge. There are no proposals put forward to compensate for hedgerow or tree loss and yet there is scope to achieve this within the applicant s ownership and application area. Please also note our concerns (above) about the impacts arising from proposed road access lighting in this location. The LVIA viewpoints 3 and 4 highlight the vulnerability of the site area to the wider views and the need for good landscape mitigation. The proposed planting to the west boundary is of a width of between 1 and 7 metres. The roadside boundary vegetation is transparent in winter/spring months so a planting belt of some 10 metres minimum would be needed to provide adequate visual mitigation for the WTS. On the south boundary it is not clear why the new tree belt is not continuous. A point of detail to note is that the highway tree planting would benefit from the removal of all plastic tree guards and positive long term management. In summary, we acknowledge the inclusion of some new boundary hedges but are concerned that more hedging has not been accommodated along the site boundaries. Limited sections only are proposed around the north east corner of the site area. We note the inclusion of a high percentage of hazel, proposed to be used in groups of We suggest this is kept to a maximum 5% and used in single numbers only. Whilst hazel is a welcome species and prevalent in Suffolk it grows in an open form and will not provide the density of hedge needed for good screening. Policy Considerations We consider that at present the scheme fails when measured against the West Suffolk local plan policy DM13 Landscape Features and Suffolk County Council Waste Core Strategy 2011 Objective 8: To minimise adverse impacts on landscape quality and the built and historic environment. Furthermore the proposals are contrary to Suffolk County Council Waste Core Strategy Policy WDM2 which states (among other considerations): In general waste management development will be acceptable so long as the proposals adequately address, where appropriate, the following: d) Potential impact upon landscape; e) Potential impact upon biodiversity; Also to Policy WDM19 which states (among other considerations) that: Waste management facilities will be considered favourably where they incorporate: c) Schemes for the retention of existing and provision of new landscape features; d) Measures which will protect, preserve and where practicable enhance the natural, historic and built environment. Accordingly, SPS considers that the proposals and associated mitigation are not in accordance with the local policy framework for the reasons set out above. Conclusion Having studied the proposal in detail we remain concerned about the landscape and visual impacts and consider that the scheme could be designed in a more sensitive manner. Furthermore, 4

5 we do not consider that the proposed scheme demonstrates sufficient measures to mitigate the adverse landscape and visual impacts. Accordingly, we urge the two Councils to consider the details of this proposal further and urge for amendments to the scheme namely: the retention of the two identified oak trees and enhanced landscape mitigation, both within the site and alongside the boundaries and on highway/scc land where a more comprehensive landscape scheme could be achieved. We trust that you will find these comments helpful in the assessment of this case. Yours sincerely, Fiona Cairns IHBC MRTPI Director Ccs: Anne Westover, Westover Landscape Ltd Mr David Rees Chairman, St. Edmundsbury SPS District Committee Bury St Edmunds Town Council, Julia Dyball Chairman, Bury Society, Karen Hurden Ward Councillor, Rebecca Hopfenspurger, Sarah Broughton Great Barton Parish Council Fornham St Martin Parish Council Suffolk County Council, John Pitchford West Suffolk / Bury St Edmunds Jaki Fisher Suffolk County Council, Bryn Griffiths Simon Harding, Suffolk West Action Group Sarah Bartram 5