Objection to DC/25/3412/FUL Land East of Woodbridge Road

Thank you to everyone who has taken the time to write in or attend our meeting to give views on this application.

The Town Council has now submitted this response to East Suffolk Council:

Framlingham Town Council

Objection to Planning Application DC/25/3412/FUL
Land East of Woodbridge Road, Framlingham

Having examined the documents and discussed this application at a meeting at which 49 residents attended and shared their views, we would like to object strongly to this application. The proposal conflicts with national, local and neighbourhood planning policies and would result in significant and irreversible harm to heritage assets, landscape character, drainage systems and the balanced growth objectives defined in our Neighbourhood Plan.

1. Conflict with the Neighbourhood Plan and planning policy
The majority of the proposed site lies outside the Framlingham physical limits boundary. The Plan remains a key part of the statutory development plan and we think that its policies should carry full weight until the review process is complete.

While it is true that the review has not yet been finalised, substantial progress has been made. The call for sites and the town-wide survey have been completed, and both the Housing Needs Assessment and design code are now finalised. It is therefore wholly inaccurate for the applicant to claim there has been "no discernible progress" on the Neighbourhood Plan Review. The review process is progressing very well and its emerging evidence should be taken into account.

The existing Neighbourhood Plan identifies housing targets extending to 2031, with only around 100 additional homes to be delivered towards the end of that period. Approving 128 homes now, most of them outside the defined settlement boundary, would completely undermine the community-led plan and make a mockery of the review process.

The proposal fails to satisfy the NPPF's requirement to protect and enhance the significance of designated heritage assets and their settings. Development within the visual and historic context of Framlingham Castle Keep, St Michael's Church and the Framlingham Conservation Area would cause substantial harm to their significance, contrary to paragraphs 208–210 and 216–227 of the NPPF. The scale and prominence of the development would not represent "sensitive development" in line with national guidance.

East Suffolk Local Plan Policies

The proposal conflicts with the following policies of the East Suffolk (Suffolk Coastal) Local Plan:

SCLP3.2 (Settlement Hierarchy) – The scale and cumulative quantum of new dwellings far exceeds that reasonably expected for a Market Town and undermines sustainable growth planning principles.

SCLP3.3 (Settlement Boundaries) – The site lies outside the defined settlement boundary and fails to demonstrate exceptional justification.

SCLP10.4 (Landscape Character) – The development would cause unacceptable impacts on landscape character and settlement edge views, with inadequate mitigation or integration.

SCLP11.1 (Design Quality) – The density and layout do not reflect local distinctiveness or respond positively to our heritage context.

SCLP12.4 (Historic Environment) – Harm to nearby heritage assets is not outweighed by public benefits, contrary to policy objectives.

2. Housing mix and need
The Framlingham Housing Needs Assessment identifies the following preferred mix for future delivery: approximately 10–20% one-bedroom homes, 35–45% two-bedroom, and 45–55% three-bedroom, with little or no need for additional four-bedroom or larger properties. The mix proposed in this application does not reflect these findings. The development instead favours larger family houses, failing to address local need for smaller and more affordable homes.

3. Landscape and visual impact
The proposed site lies on rising ground forming part of the rural setting of the town.

The development would have an intrusive visual presence, eroding the soft transition between the built form and open countryside in this part of our town. Its visibility from key public vantage points identified under FRAM5- including views northwards to the Castle Keep and across the valley- would cause lasting harm to the rural character and town setting.

Development at this scale would cause significant harm to the landscape character and views from the surrounding countryside, including from the local footpaths. The East Suffolk Design and Heritage team has already stated that "the proposal would cause clear and demonstrable harm to the character of the area", a view that we very much share.

4. Cumulative impact
This proposal must be considered alongside other recent and pending developments in Framlingham, including the adjoining Castle Keep site and approved development at Victoria Mill Road. The cumulative effect on local infrastructure, traffic, drainage, education and healthcare provision would be severe. The town is already absorbing substantial growth and this scheme would intensify that unsustainable pressure.

5. Flooding and drainage

We note that Anglian Water has formally objected to this application, highlighting the lack of available capacity within the existing system. This is very alarming and must be treated as a serious constraint to development.

Framlingham has a long history of flooding issues, most notably during Storm Babet when numerous houses and businesses in the town were badly flooded. Residents remain deeply concerned about flooding risks and fear that this development would exacerbate existing problems.

The proposed site itself flooded during Storm Babet and converting this area to buildings and hard surfaces would only increase runoff and the speed at which water is channelled towards the lower lying Woodbridge Road, industrial areas and villages further down the River Ore such as Parham and Hacheston.

We note that the attenuation basins in the adjoining Castle Keep development failed to operate effectively during Storm Babet. The tarmac roads acted as a conduit for floodwater, directing it towards Fairfield Road where homes were inundated.

Approving further large-scale development on known flood-prone land, in an area where existing systems are already overwhelmed, would be irresponsible and contrary to the principles of sustainable development.

6. Design, scale and layout
We think that the overall layout of the scheme is suburban in form, with little regard for local character, density or the rural edge location. The proposed housing types and materials do not respect the vernacular of our town or its transition to open countryside in this area. The development does not comply with our new Design Code.

7. Highways and access concerns
Woodbridge Road already experiences high traffic volumes, with particular issues at the Brick Lane/B1116 junction and at the single-lane bridge on Woodbridge Road near the development site. There have been several crashes and incidents in recent years at both of these sites. The introduction of a further 128 dwellings and employment units will add significant additional traffic, worsening safety and congestion.

8. Sustainability and the tilted balance
While we recognise that East Suffolk Council currently lacks a full five-year housing land supply, this does not automatically make all sites sustainable or suitable for development. The tilted balance must still weigh benefits against the harm identified. In this case, the harm is substantial and demonstrable: loss of countryside, conflict with the development plan, visual and landscape harm, highway safety concerns and unresolved drainage objections.

We are dubious about some of the sustainability claims within the application.

We have concerns that the applicant's transport statement overstates the sustainability of the location. Safe walking routes to shops, schools and services are in reality longer than those timings suggested and bus services from the nearest stop are infrequent. Thomas Mills High School, in particular, is not within a realistic walking distance for pupils, which undermines the claim that the site is sustainable for family housing and will increase car-dependency in the town. We think the development fails to meet the definition of sustainable development under the National Planning Policy Framework.

9. Alternative sites and plan-led growth
The ongoing Neighbourhood Plan Review could identify other potential sites that are better located, closer to the town centre, schools and services. These sites could potentially deliver housing more sustainably, in accordance with the plan-led system that national policy seeks to uphold. Granting permission now would pre-empt and undermine that process.

10. Conclusion
We are of the view that the proposed development is premature, unsustainable and contrary to both the adopted Neighbourhood Plan and findings from our current review of the Plan. This application would cause harm to the landscape character, increase flood risk, strain local infrastructure and deliver the wrong type of housing for local needs.

The Town Council notes the reservations expressed by statutory consultees including the Environment Agency, Suffolk County Council Floods Team, Historic England and the Suffolk Preservation Society. Those objections align with our concerns and should be afforded substantial weight in your decision-making process. We would urge you to refuse this application.