Lowestoft AAP
Appendix A
Summary of Preferred Options Consultation (Jan/Feb 2007) Issues and AECOM Recommended AAP Response
Lowestoft – Consultation Issues and AECOM Recommended AAP Response
Key Themes
Go-East
Comments
Go-East set out following recommendations in terms of
document compliance. The AAP should:
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Respond to the conclusions of the SFRA
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Demonstrate at the Examination that all reasonable
options have been tested and a summary of the
alternatives has been set out in the Preferred
Options DPD
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Consider whether specific policy for individual Action
Areas relating to Environmental Improvements
should more appropriately be merged with other
policy relating to those specific areas.
AAP will be subject to comprehensive review and the refinement of
area-wide policies and site specific proposals/guidance.
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Consider breaking down the housing trajectory table
to specific sites, with caveats if necessary
Site specific housing trajectory will be included as part of revised AAP
document.
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Consider whether sufficient evidence has been
gathered on employment land demand, together
with a review of the quality and quantity of existing
land in order to support the proposals of the AAP
and enable the evidence base to demonstrate that
those proposals are realistic and could be
Employment land demand currently under review and quantitative and
qualitative implications of revised study to inform AAP policies.
1
AAP site proposals and policy approach to be informed by revised
SFRA that underpinned Waveney Core Strategy proposals. Site
allocations to be revised to take account of flood risk and delivery
implications of mitigation.
AAP will be subject to further round of “options” consultation in
accordance with revised Regulation 25. A commentary of this process
will be provided as part of the evidence base.
implementable.
Flood Risk
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Ensure a full, realistic and evidenced ‘means of
implementation’ is set out in the DPD, which is
specific to the proposals of the AAP.
AAP will be underpinned by delivery and implementation strategy
setting out process for implementing AAP, likely phasing and public
sector interventions.
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Ensure only policies and proposals suitable for a
DPD are included in the Submission DPD, and that
financial or Business Planning matters of the URC
are addressed in other appropriate documents.
AAP document will be subject to comprehensive review to ensure that
URC business planning matters are removed.
EEDA also had concerns around tests of soundness in
relation to conformity, coherence, consistency and
effectiveness.
AAP will be fully revised to ensure meets requirements of latest
national guidance and advice of Go-East.
Env Agency and Anglian Water, as well as the public stress
concerns around flood risk which may stymie development
opportunities.
The Strategic Flood Risk Assessments for Lowestoft has been updated
and Core Strategy now adopted.
The EA stresses that the vast majority of the AAP lies within
Flood Zone 3, the high risk zone as classified by PPG25.
For the purposes of sequential testing, the EA notes that
some areas of Lowestoft are likely to be classified as Flood
Zone (functional flood plain) – in which, in accordance with
PPG25, most developments are considered inappropriate.
Exceptions include water compatible uses and essential
infrastructure. The location of such developments in the
functional floodplain is only permissible where they are
designed and constructed to:
 Remain operational and safe for users during floods
 Result in no net loss floodplain storage
 Not impede water flows
 Not increase flood risk elsewhere
2
The AAP will be subject to substantial revision, and land use proposals
will reflect the current understanding of flood risk following changes to
PPS25 and the land raising study undertaken as part of the Core
Strategy.
As part of this process the EA will be fully engaged.
All site proposals will be informed by assessments of financial viability
that include financial implications of flood mitigation.
Preliminary SFRA results from 1 in 200 year flood show
Lowestoft is currently poorly protected from such events by
the quay heading, with the general public exposed to
unacceptable risks. SFRA highlights need for flood risk
overview of area.
The EA recommends that any new flood defences should
offer protection from 1 in 200 year flood event and should be
in place before any development proceeds. Another option
is to raise land to improve protection, with the level of
necessary raising likely to be significant in places.
The EA makes it clear it does not agree with Section 0.5.1 of
the Draft SA accompanying the consultation, and therefore
does not consider the evaluation of alternative options to be
appropriate. Flood risk has not been fully taken into account
since the AAP proceeded in advance of the publication of
the Waveney DC SFRA.
Highways
The EA stresses that it cannot be relied upon to fund flood
protection improvements.
The Highways Agency as well as the public raised a number
of concerns about the impact of proposals on the local road
network. In particular, the Highways Agency suggested the
extent of employment and housing-led mixed use
redevelopment proposed would substantially increase
pressure on the roads. The traffic implications of proposed
traffic calming measures, new bridge crossing, relocation of
the station and spine road should all be further tested,
including cumulative impacts. More information should be
provided on how and when sustainable travel proposals will
be implemented.
Traffic modelling has been undertaken of the cumulative impacts in
the context of the proposed roads infrastructure, however, no
assessment has been undertaken which considers the AAP proposals
in the context of both the sustainable transport investment and the
new roads infrastructure proposed. This is required to maximise the
potential to bring the AAP forward in the short term.
The AAP transport proposals will be revisited with a view to improving
the viability of the AAP by reducing the emphasis on roads
infrastructure for which funding cannot be guaranteed.
The HA and Suffolk Highways will be engaged throughout the AAP
revision process.
3
Ports
Third Bridge
Funding/Delivery
Ground
Conditions
Associated British Ports raised concerns over the impact of
several area-based proposals on the viability of port
operations, in particular, viable business providing
employment to Lowestoft. The ABP feel that the AAP
ignores the needs and aspirations of the port and will
oppose any proposals that undermine the ability of the port
to operate and expand.
It is the intention to engage ABP from the outset in revising the AAP
strategy in order to fully understand their operational requirements and
any concerns that will be facilitated by nearby development.
Businesses such as Plasmor and Small and Co. stress the
continued contribution to local economy made by existing
firms and suggest port functions should be supported in
future.
Proposals for residential uses will be carefully reconsidered, taking into
account the operational requirements of existing uses that are likely to
remain in-situ for the plan period.
Concern from ABP and businesses such as Lafarge
Aggregates and Plasmor about locating mixeduse/residential developments with sensitive users in close
proximity to a working port. Similarly, some consultees
question opening up public access to the waterfront.
Third bridge widely viewed as essential catalyst for wider
regeneration and viability of other proposals / action areas.
Some concern over having new ‘opening’ bridge which
accommodates ships but interrupts traffic flows.
Concerns from both statutory and public consultees around
extent of funding required to deliver new bridge/road
infrastructure, especially given the increased costs
associated with the need to mitigate flood risk.
EA suggest that ground contamination is likely to be a major
environmental consideration and stress the need for a
4
The AAP will also engage with other local businesses to ensure that it
provides a supportive policy context to facilitate the preservation,
enhancement and expansion of existing businesses.
The AAP will provide be redefined to include a policy framework for
delivery of the bridge, but also provide flexibility should the bridge not
be brought forward.
The bridge proposals are now firmer (including preferred routing) and
the AAP will be revised to take account of this.
AAP policies and site proposals will be revised to take full account of
market conditions, the need for funding intervention and likelihood of
being brought forward.
The AAP will be underpinned by a robust delivery and implementation
strategy that will set out long term approach to phasing, funding and
monitoring. This will include approach to planning obligations within the
URC area and ensure flexibility should proposals not be brought
forward during the plan period.
Considerable additional work focussed upon ground conditions has
been undertaken on behalf of 1st East for the main intervention sites.
Housing
precautionary approach in the determination of applications
for the redevelopment of brownfield sites. At very least,
desktop studies should be completed and submitted to LPA.
This work will influence revised development proposals, and the AAP
delivery and implementation strategy will take into consideration the
implications of likely remedial works.
Furthermore, ground contamination may have an impact on
the viability of SUDS in some locations
The approach to SUDs will take into consideration ground conditions
and will discount initiatives such as swales where ground conditions
will prove prohibitive.
AAP to establish revised policy approach and site allocations for
housing allocations, taking into account the wide trajectory set out
within the adopted Core Strategy.
Need to ensure housing reflects local need.
Badger Building do not believe housing trajectory is
deliverable and raise concerns over how to deliver family
housing on high density brownfield sites. Badger Building
also suggest Compulsory Purchase should be considered a
first rather than last resort as it is unrealistic to expect
market to deliver land assembly on scale required.
Bidwells suggest the Council should not rely on the AAP to
meet all Waveney’s housing needs given the lack of
uncertainty around public sector infrastructure funding, and
recommend a sustainable urban extension at Woods
Meadow, Oulton.
AAP will set out a policy approach for housing that will provide a
flexible, market responsive framework to delivery housing within the
URC area.
The AAP will be revised to take account for new residential
opportunities that have emerged since 2007, and remove housing
proposals from sites where issues (notably flood risk) will prove
detrimental to the delivery of housing.
Further and on-going consultation with landowners and key
stakeholders will assist in preparing proposals which are deliverable.
Heritage
Broads
SUDS
English Heritage welcomes heritage and re-use of historic
buildings being embodied in the AAP. Cultural heritage
assessment should inform plans.
The RSPB highlight that the AAP lies close to the Broadland
Special Protection Area, which proposals should have
regard to. In particular, development on Lake Lothing
including proposed water taxis.
The Environment Agency supports proposals for SUDS but
highlights that the AAP does not make it clear how they will
be implemented and managed, which should be included
within drainage strategies for sites. It should be noted that
infiltration SUDS may not be suitable on all sites due to
5
The AAP will be revised to include policies that encourage the
preservation and enhancement of heritage features.
The AAP proposals will be subject to appropriate assessment to
account for the Special Protection Area.
Further detail will be provided on SUDs strategy as part of site
proposals; including the type of SUDs features that will and won’t be
suitable taking into account site constraints (in particular ground
contamination and flood risk).
Railway Station
Sustainable
Transport
Physical
Activity/Sport
Business
Relocation
ground contamination.
Objections to relocation of station from both public and
statutory consultees, local business as well as Essex Rail
Users Federation and East Suffolk Travellers’ Association.
Refurbishment favoured.
Right to Ride Network question whether the third bridge
crossing would relieve congestion in the long term,
especially given the necessary ‘opening’ nature of Lowestoft
Bridges. Efforts to ease congestion are at the expense of
making alternative means of transport more attractive. Lack
of park and ride proposals.
Sustainable Transport for the East of England Region
suggests AAP is dominated by road building proposals, and
that by the time a third bridge comes forward, local priorities
will have changed.
Sport England suggests a number of development proposals
offer opportunity to increase physical activity and sports
participation, an objective which should be made more
explicit. In a number of Action Areas, it is suggested that
scope exists to secure contributions towards off-site open
space/sports facility provision in lieu of on-site provision.
Concerns over the impact on the viability of
businesses/employers and the requirement for some to
relocate.
Further evidence base work has been conducted on the relocation of
the station which is indicating that such a proposal is unviable. The
approach to the planning of the station area/North Peto Square will be
reconsidered as part of the revised AAP strategy.
The AAP will be supported by a deliverable transport strategy which
includes sustainable transport investment across the area, along with a
reasonable understanding of the likely strategic roads improvements
and new infrastructure required, and when those improvements would
be required.
The revised AAP will consider sport and recreation requirements. A
s106 obligation strategy is more appropriate at a District wide level.
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Utilities
Anglian Waters unable to provide full details of wastewater
infrastructure which is required/impacted until firm proposals
come forward in terms of development volumes, timing and
location.
6
Approach to AAP employment proposals is currently subject to
further study, including revision of 2006 employment land
study and econometric forecasting to consider changing
economic circumstances and local business need.
AAP policies and proposals to be revised to take greater
account of needs of local businesses.
Revised AAP likely to take revised approach to business
retention and expansion, rather than relocation.
Revised site proposals and delivery/implementation strategy to take
account of limitations of existing utilities infrastructure.
Utilities providers to be engaged as part of revision to document.
Other
development
sites
EDF Energy’s comments revealed a ‘modest’ level of spare
power capacity. It may be necessary to upgrade parts of
network to serve proposed redevelopment, funding for which
may need to be met or shared by development agencies or
developers as EDF is not permitted to invest speculatively.
National Grid Property Holdings own two sites within URC
area, at Southtown Rd and Admiralty Rd. Both contain
operational gas equipment and depot buildings but include
significant unoccupied space.
This will be taken into consideration in the reformulation of site
proposals.
Lowestoft Intervention Sites - Consultation Issues and AECOM Recommended AAP Response
Intervention
Site
East of England
Park
Key Issues
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Associated British Ports (ABP) – concern over impact on
port and SLP Engineering
Env Agency – Area lies within Flood Risk Zone 2 and 3,
proposals subject to sequential test. Proximity to Ness
Point County Wildlife Area – must consider impact on
biodiversity
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Public
 Priority for regeneration – an eyesore which is long
overdue for redevelopment
 Proposals are key to diversifying economy, improving
skills and creating jobs
 Vital that Lowestoft exploits tourism assets and green
energy expertise
 Flood concerns given climate change scenarios
 Most easterly point should be celebrated as a unique
asset, especially as the area currently under-used
7
Proposals for East of England Park will be reconsidered and
opportunities for the area set out in greater detail following recent
work by 1st East and other stakeholders.
East of England Park/Peto Square areas as identified within the
AAP will be reconfigured in light of emerging proposals for the
Power Park, which is identified to become a hub for the energy
sector.
The Gas Holder site will be given greater consideration through
proposals.
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Fishers’ Wharf
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Peto Square
Wind turbine is an eye catching landmark – support for
investment in cutting edge renewable technology
Some objections based on concern that unviable until 3rd
bridge opened
Gas holder as eye sore to address
Redevelopment brings about opportunity to consolidate
main cycle/pedestrian route
ABP – concern over SLP Engineering operations, need
to retain bulk cargo handling on Hamilton Quay; no land
will be given to marina use unless ABP satisfied there will
be no impact on port operations
Highways Agency – concerns over proposed traffic
calming
Env Agency – Within Flood Risk Areas 2 and 3. Support
continued fishing industry use (water compatible use).
Need to assess impact of marina.
Suffolk Preservation Society – Fishers’ Wharf needs
major demolition, landmark building welcomed
Public
 Area in need for regeneration
 Support delivery of affordable housing
 Flooding concerns
 Fully exploit potential waterways
 Opportunity for new bars/restaurants/cafes
 Are proposed uses compatible with working port?
 Should protect and enhance cultural heritage
 ABP – Second bridge near Bascule Bridge technically
problematic, needing to raise to accommodate
commercial shipping. Town centre/mixed use expansion
would compromise port function. Also concerns over
proximity of residential development to dry dock and
grain silo. No waterfront development/berthing until
assessment of safe passage of marine craft. Similarly,
public access to waterfront needs to consider safety and
8
Proposals for Fishers Wharf to be removed from AAP – reallocated as
“Power Park” and “Peto Square” with establishment of hub for energy
sector. Proposed residential and mixed use floorspace to be
redistributed within AAP area.
Revised proposals will be refined in accordance with ongoing
consultation with landowners, business and other stakeholders.
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Bridge near to Bascule Bridge has been ruled out, although there
may be scope for a pedestrian bridge structure.
ABP to be fully engaged in revision of AAP proposals.
Station relocation is unlikely to occur following feasibility studies
since 2007. Network Rail will be fully engaged in producing revised
proposals for North Peto Square/Station surroundings, which may
include a greater level of retail.
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Kirkley
Waterfront
Brooke
security.
Network Rail – concern over relocation of station and
apparent disregard for previous objections. Further
consideration could be given if sufficient safeguards for
local retail in place
Highways Agency – Resi/Mixed use developments would
increase traffic in Battery Green Road / Bascule Bridge.
Moving station could affect patronage
Env Agency – Peto Sq and Kirkley Waterfront proposals
adjacent to the Main River Lake Lothing Landspring and
lie almost entirely within undefended Flood Zone 3 –
must assume in functional flood plain. Proposed
residential developments dependent on findings of SFRA
and outcomes of sequential/ex exception tests.
SCC – concern over relocating station
Public
 Strong opposition to moving station – will reduce
accessibility and public transport use. Centrally located
station is an asset/strength which should be retained
 Support for linking high street and waterfront
 Impact of station relocation on local business
 New bridge should be further west
 ABP – proposals incompatible with port uses
 Highways Agency – Impact of mixed-use development on
road system. New Spine Road needs further analysis
 Env Agency – cannot support proposals due to flood risk
until SRFA confirms otherwise
Public
 Support for employment creation but concerns over flood
risk and relocation of existing businesses
 Support for western third bridge in Kirkley/Brooke
Peninsula
 ABP – inappropriate residential development close to
9
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Residential development unlikely to take place in this area
following outcomes of SFRA. The proposed residential quantum to
be redistributed across the AAP area.
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Proposals for Kirkley Waterfront have evolved since 2007 and AAP
will be revised to include an alternative land use strategy. ABP will
be engaged in process to ensure that their concerns are
addressed and mitigated.
Residential proposals may be brought forward if land raising takes
place following adoption of Waveney Core Strategy.
Preferred Site for third bridge likely to be between Kirkley
Waterfront and Brooke Peninsula and will be subject to further
consideration through the AAP process.
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Brooke Peninsula is currently subject to detailed design
Peninsula
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port facility
Highways Agency – need to test proposals to gauge
impact on trunk road
Env Agency – area within undefended flood zone 3 cannot support proposals due to flood risk until SRFA
confirms otherwise.
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Lothing
Crossing
Other
Interventions
Public
 Some support for marina development
 Support for western bridge location – any such bridge
needs to accommodate passing ships
 Residential development should reflect local need
 Should maximise water assets – leisure boating industry
is a growing industry
 ABP – cost concerns, impact on boat manoeuvring.
Oppose Lake Lothing Crossing that passes through
Varco site.
 Env Agency – cannot support proposals due to flood risk
until SRFA confirms otherwise
 Right to Ride Network – third crossing would not reduce
congestion
Public
 Strong preference for western bridge location
 Possible tunnel
EA supports continued use of Shell Quay for port/marine
uses. Unable to offer support for Lake Lothing West and
Clifton Rd/Horn Hill until publication of findings from full
SFRA.
Broads Authority – strong support for Lake Lothing West
proposals
21/09/09
10
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development by PRC architects who are proposing a residentialled mixed use scheme.
This is set to address flood risk through land raising as specified
within the SFRA.
This will include an enhanced marina offer and employment
opportunities.
The Sanyo site (which is now unoccupied) presents further
opportunity for residential led mixed use development and will be
subject to further consideration through the AAP revision process.
Proposals for highways to be developed in consultation with
County.
Preferred site for third crossing identified at Brooke Peninsula;
Will be subject to further consideration through the AAP process.
May not be delivered during the plan period.