BMSDC Joint Local Plan Consultation Document (Interactive)

Ended on the 10 November 2017
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(68) Introduction

The Babergh and Mid Suffolk Joint Local Plan – consultation document (hereafter referred to as ‘the Consultation Document’) is an important document which will provide the strategy for the growth of the Districts, setting out what and where development will take place up to 2036. Once adopted, the new Joint Local Plan will replace the existing local planning policies for both Babergh and Mid Suffolk. The Plan will set out a vision for the area and will include policies and land allocations.

What is the purpose of this consultation?

The purpose of this consultation is to identify the issues, put forward options and, in some instances, to indicate an initial preference  for  the new Joint Local Plan for Babergh and Mid Suffolk.

This consultation is your opportunity to identify any planning issues that you think the new Joint Local Plan should address, and comment on possible ways that the plan might address these important issues in your communities (including informing where you consider development should be located). The more information you can inform us of at this initial stage, the greater your opportunity to shape the future of the area. Please send us your thoughts and comments on the new Joint Local Plan – this affects everyone and once adopted will influence the area for years to come.  

Why do we need a Plan for Babergh and Mid Suffolk?

The role of the planning system is to contribute towards the achievement of sustainable development. Planning involves weighing up economic, social and environmental factors to achieve the most balanced and sustainable way forward for the benefit of the public interest.

Following a number of significant changes in the local, county and national context since the current Local Plans (see Development Plans section below) were developed it is considered appropriate to revisit and realign our priorities, objectives and vision for the future of Babergh and Mid Suffolk. This will ensure the spatial planning framework for the Districts is up to date and will provide a sustainable basis upon which to shape communities and manage development up to 2036 and beyond.

The policies set out in an up-to-date Local Plan will provide the primary consideration in weighing up considerations when determining applications.

Local Plans must be produced in accordance with national planning policy. Government policy, set out in the National Planning Policy Framework (NPPF)[1], sets out a requirement for local planning authorities to objectively assess the need for housing in their Housing Market Area and ‘to ensure their Local Plan meets the full, objectively assessed needs for market and affordable housing…including identifying key sites which are critical to the delivery of the housing strategy over the plan period’ (paragraph 47). The Council has worked with authorities in the Housing Market Area[2] (Babergh, Mid Suffolk, Ipswich and Suffolk Coastal) on the production of a Strategic Housing Market Assessment[3]. The assessment covers the period up to 2036, which aligns with the period all of the respective plans will be covering.

Babergh and Mid Suffolk’s Current Development Plan

The current Development Plan[4] for Babergh consists of the saved policies of the Babergh Local Plan, Alteration No. 2 (2006), the Babergh Local Plan (2011 – 2031) Core Strategy and Policies (2014) and the ‘made’ neighbourhood plans – East Bergholt Neighbourhood Plan (2016) and Lavenham Neighbourhood Plan (2016).  For Mid Suffolk, the Development Plan comprises the saved policies of the Mid Suffolk District Local Plan (1998), the First Alteration to the Mid Suffolk Local Plan (2006), the Mid Suffolk District Core Strategy Development Plan Document (2008), and the Mid Suffolk District Core Strategy Focused Review (2012), the Stowmarket Area Action Plan Mid Suffolk’s New Style Local Plan (2013) and the ‘made’ Neighbourhood Plans which currently only comprises the Mendlesham Neighbourhood Plan (2016). 

The Minerals Core Strategy (incorporating Development control Policies) (2008) and the Waste Core Strategy Development Plan Document (2011) produced by Suffolk County Council also form part of the Development Plan.

The new Joint Local Plan will replace the Local Plans and alterations (saved policies), the Core Strategies, and the Stowmarket Area Action Plan.

When made, any new Neighbourhood Plans[5] shall also become part of the development plan and shall be considered alongside the Joint Local Plan when determining applications.  As at July 2017, neighbourhood plans have been made in Babergh for the parishes of East Bergholt, Lavenham and in Mid Suffolk for Mendlesham. A further 14 parishes have been subject of area designation and plans for these areas are at various stages of preparation.  There is a timely opportunity for neighbourhood planning groups to be developed in parallel with the local plan and share evidence and information to bring forward sites for allocation to emerging the levels of growth as stipulated in the draft Joint Local Plan.

The new Joint Local Plan

The new Joint Local Plan will set out the amount of growth that needs to be planned for, where the growth should go and how it should be delivered. Planning policies will set the context for protecting the District's valuable natural and built environment and ensure that new development is delivered in a sustainable way. These planning policies will be used by the Council when making decisions on planning applications. 

The Plan will be primarily based upon and in conformity with current and emerging national planning policy and legislation, whilst having full regard to strategic matters identified in relation to the emerging countywide Suffolk Strategic Planning and Infrastructure Framework[6], the New Anglia Local Enterprise Partnership[7] and the Housing Market Area.

Why do we need a Plan to deliver growth?

The Council has identified its Objectively Assessed Need (OAN) for housing[8].  The new Joint Local Plan will set out a strategy that will accommodate this in full in accordance with national policy requirements. Preventing growth across the two Districts is not an option. Levels of housing need in the area are high and new homes will have to be provided to meet this need. Rates of annual housing delivery in Babergh and Mid Suffolk have been below the levels of current need since need 2014/15 and this has further compounded the levels of unmet housing need impacting upon the requirement for future development.

Delivery of housing and economic growth is challenging. A ‘plan led’ approach to shaping the levels, locations and scope of future delivery provides a mechanism to pro-actively manage and influence the future of the area.

Housing and economic growth is a key factor in securing investment into existing and new infrastructure projects.  Development should be planned to secure the delivery of key infrastructure projects across the County, such as the Ipswich Northern Route and the Sudbury Western Relief Road, as well as localised infrastructure schemes within communities. 

The proposed locations and details of development will be subject to consultation through the plan preparation process.

The Plan

The Plan will be set out in 3 parts:

  1. Strategic
  2. Delivery
  3. Places.

The Plan will articulate policies to influence delivery across four priority areas that your district councillors have identified will have the most positive impact on that future: 

  • Housing
  • Economy
  • Environment
  • Healthy Communities & Infrastructure

The Councils of Babergh and Mid Suffolk, as the Local Planning Authorities, need to work with a large number of organisations and individuals to produce a local plan and determine planning applications. Alongside working with infrastructure providers and the New Anglia Local Enterprise Partnership, Babergh and Mid Suffolk District Councils work closely with the other local authorities across Suffolk, including with the County Council.

Viability is a factor which has a significant influence over planning policies and development proposals. The new Joint Local Plan has to be deliverable. The NPPF (paragraph 173) states that in order to ensure the deliverability of the Plan and the viability of development, it is necessary to ensure that, with all costs taken into account, development will provide a competitive return to a willing landowner and developer. This means that the cost of meeting the requirements of the policies in the new Joint Local plan combined with the costs of meeting national requirements, such as building regulations, need to be assessed and factored into the emergence of policy.

Delivery & Places

The Plan will have a focus upon managing the delivery of sustainable development which supports the areas economic growth ambitions; the important rich historical and natural environment; the extensive network of existing communities; and enables development through facilitating the delivery of infrastructure. 

The new Joint Local Plan will take into account emerging Neighbourhood Plans being prepared in the Districts and will provide a basis for new Neighbourhood Plans to be prepared against. The new Joint Local Plan will need to clearly identify the 'Strategic Policies' that new Neighbourhood Plans will need to be in accordance with.

Local Plan Timetable

The new Joint Local Plan will take approximately 2 years to prepare. There will be extensive public consultation leading up to the final draft plan which will be submitted to the Government for independent examination.

The Councils consulted on three topic based initial options documents in January 2015 addressing (i) Rural Growth, (ii) Development Management Policies and (iii) Strategic Site Allocations. 

However, since consulting on the documents the strategic context which informs the emerging Plan has changed significantly. A collaborative approach has been taken with the adjoining Suffolk authorities. All are producing Plans to cover the period to 2036.  A revised Strategic Housing Market Assessment and Employment Land Needs Assessment[9] (including Employment Land Supply Assessment[10] and Sector Needs Analysis[11]) has been undertaken across the Housing Market Area as well as other relevant local studies.  Consequently the District has decided to undertake a comprehensive review for the new Joint Local Plan.  

The Council updated the Local Development Scheme[12] in March 2017. Milestone dates are as follows:

  • Publication of Regulation 18 Draft Local Plan Summer  2017
  • Publication of Regulation 19 Draft Local Plan Winter 2017/18
  • Submission of Regulation 22 Draft Local Plan Summer  2018
  • Examination in Public Winter  2018
  • Adoption of Plan  Spring 2019


(16) Babergh & Mid Suffolk Profile & Context


Babergh and Mid Suffolk are predominantly rural districts covering the geographical centre of Suffolk, running from the boundary with Essex in the south to the boundary with Norfolk in the north. This covers a total area of approximately 565 square miles.

Babergh and Mid Suffolk Councils have been developing an agreed process of integrating services over several years. Whilst remaining two distinct sovereign councils, they now have a single staff structure to serve the two organizations and members work together collectively to deliver local authority services across the two districts. Both Councils’ overall visions and strategic priorities proved to be very similar and have been recently further aligned[13]. Over the next three years the new Joint Strategic Plan[14] identifies a shared focus on the planning and delivery of sustainable growth. The Local Plan is one of the key tools available to the Council to help deliver the shared vision locally.



The population of Babergh District is 87,740; Mid Suffolk population is 96,731 (Census, 2011).

Across Babergh and Mid Suffolk more than half the population live in villages and rural areas. In combination both districts have six main centres; which include Eye, Needham Market and Stowmarket in Mid Suffolk; Pinewood, Hadleigh and Sudbury in Babergh. The historic market towns are surrounded by a rural hinterland comprising 198 rural parishes.

Babergh and Mid Suffolk are heavily influenced by large centres of population just across its borders; Bury St Edmunds in the west, Ipswich in the east, Diss and Harleston in the north. This is reinforced by the area’s strategic transport connectivity with main road and rail links including the A12/A14/A140 main roads from London to Felixstowe and Cambridge, together with main line rail links from London, to Cambridge and Norwich and a strategic link for freight traffic from Felixstowe to Nuneaton in the Midlands. A large portion of Mid Suffolk has direct access to the A14 and the main line railway between London/Ipswich/Norwich and Cambridge. Babergh has lesser access with a small proportion of its area served directly by the east A12 and north by the A14 and no main line railway stations.

(20) Key Social Issues


  • A Growing Population

The population is expected to continue to grow over the period 2014 to 2036. The official 2014 Sub-National Population Projections identify an increase of around 8,000 people in Babergh and around 13,000 people in Mid Suffolk.


  • An aging demographic

The Districts have similar demography with fewer younger people and an increasing proportionate aging population. Both Districts have an aging population with 45 - 59 year olds representing the single largest age group at present. In addition, a significant percentage of the population are aged 65 years or older (21% in Babergh and 20.13%[15] in Mid Suffolk). Babergh and Mid Suffolk also have a relatively long life expectancy at about 81 years for males and about 84 years for females[16]. As the population ages, there will be different demands on services and facilities, in particular housing and medical care.


  • Open Space

Whilst there is extensive countryside previous assessments for Babergh and Mid Suffolk have identified an identified deficiency in accessible open space provision, this includes - Neighbourhood Equipped Areas for Play (NEAP) and Local Equipped Areas for Play (LEAP), outdoor sports provision and allotments


  • Education

Educational attainment at GCSE level is in line with Suffolk and national averages. However many pupils access 6th Form education outside of the Districts including at Ipswich or Bury St Edmunds.


  • Housing Need and Affordability

House prices on average are around 9 times above the average earnings of residents and rural parts of the Districts are unaffordable for many.


  • Income Deprivation

In Babergh 69% of the population and in Mid Suffolk 75% of the population live in a rural location. Although deprivation levels are low compared with national levels,  across Suffolk 28% of those identified as income deprived live in rural areas[17].


  • Low Crime Levels

Babergh and Mid Suffolk benefit from low levels of crime and levels of unemployment have been decreasing recently.



(20) Key Economic Issues


  • Economic base

The economic sectors that achieve growth in Babergh and Mid Suffolk are tourism; creative industries; food production, construction and related services; hospitality/ leisure. Babergh is near the level of the county with regard to the level of business formation rates, however Mid Suffolk currently holds the lowest rates in Suffolk[18].


  • Employment levels

The employment rate relating to the population between 16 and 64 years (working age) fluctuates but is generally around the England average for Babergh and higher than the England average for Mid Suffolk. In 2015, the employment rates in the Districts were 73.7% and 79.7% respectively, compared to an England average of 73.9%[19].


  • Projected growth

Research in 2016 suggests that Babergh is due to see a 14% increase in jobs and Mid Suffolk to see a 13% increase from 2011 – 2031, which represents a slow down when compared with past trends. The overall growth in jobs in expected to be driven by growth in the Professional and Business Services[20].


  • Need for land

The largest employment land needs requirement in both Babergh and Mid Suffolk will be general office (B1a), Science Park and Small Business Units (B1b), and Distribution (B8)[21].


  • Town centre occupation

The vacancy rates in town centres in Babergh & Mid Suffolk are below the national average. However, it is acknowledged that there is a need to enhance the town centres.

(21) Key Environmental Issues


  • Environmental assets

The Districts have a rich historic environment, with a number of protected areas such as Sites of Special Scientific Interest (SSSI) sites, Special Protection Areas (SPAs) and Area of Outstanding Natural Beauty (AoNBs). Water is a key environmental issue to be addressed in terms of provision/quality and flooding.  Air is also a key issue that needs to be considered. With such a rich but sensitive natural and built environment the pressure of new development will need to be carefully managed.


  • Air Quality

One area in Sudbury is identified as an Air Quality Management Area.


  • Biodiversity

Significant areas of priority habitat / species have been recorded. Some priority habitat / species identified is in adverse condition.


  • Geology

There are areas within both districts that are identified as having geological importance (Regionally Important Geological and Geomorphological Sites and County Geodiversity Sites[22]).


  • Climate Change

Along river courses there are areas at risk of flooding. Areas with risk of coastal erosion have been identified in the south of the Babergh District.


  • Heritage Assets 

Babergh and Mid Suffolk are rich in heritage assets[23]. In Babergh there are 29 designated conservation areas (36% of all 79 villages and towns) and 2985 listed buildings, 34 scheduled monuments and 5 registered parks and gardens which represent about 20% of the estimated 13,700 designated Heritage Assets in Suffolk. In Mid Suffolk there are 3419 listed buildings, 36 scheduled monuments and 2 registered parks and gardens;  which represents more than a quarter of all Heritage Assets in Suffolk (Historic England May 2016, Heritage Counts, April 2014).


  • Landscape

There is a significant extent of quality landscape including European and nationally designated areas within both districts. Babergh in particular is part of the Suffolk Coast and Heaths Area of Outstanding Natural Beauty[24] and Dedham Vale and Stour Valley Area of Outstanding Natural Beauty.


  • Material Assets

Both districts have a high volume of Grade 3 Agricultural Land[25] and limited available previously developed land. Recycling performance is currently lower than the County average in both districts.


  • Water Quality

The Districts need to improve water quality in a number of identified areas and provision of water infrastructure is essential to ensure infrastructure capacity is available for any new development.



(44) Vision and objectives


The new Joint Local Plan needs to set a spatial vision of the type of place that Babergh and Mid Suffolk will become by 2036. The vision will be based upon the following key priority areas for Babergh and Mid Suffolk Council namely:

  • Housing
  • The Economy
  • The Environment
  • Healthy Communities & Infrastructure.

The achievement of these objectives should to be set within the context of the National Planning Policy Framework (NPPF) and the presumption in favour of sustainable development. To contribute to the delivery of the vision and priority areas the New Joint Local Plan will set out an ambitious yet sustainable growth agenda which will prioritise the infrastructure investment required to deliver the growth ambitions and will identify the locations for delivering the necessary housing, employment and recreational growth and development. In accordance with paragraph 156 of the NPPF, the Plan will signpost throughout how it meets the strategic objectives requirements.


The proposed objectives for the Plan are as follows:


  • Delivery of the right type of homes, of the right tenure in the right place meeting need.
  • To seek to maintain a sustainable balance between housing and employment opportunities.


  • Encourage development of employment sites and other business growth, of the right type, in the right place and encourage investment in skills and innovation in order to increase productivity.
  • To encourage inward investment to the Districts by supporting infrastructure improvements that will enable the continued growth of Felixstowe and strengthen the Districts’ links to Felixstowe and the rest of the UK.
  • To support the ‘Ipswich Northern Route’ project and the strengthening of Ipswich and the surrounding area as the key economic driver of the County.


  • To protect and enhance environmental assets (including landscapes, biodiversity, green spaces, air and water quality, and river corridors)   for current and future generations.
  • Ensure new development avoids areas of flood risk and reduce future flood risk where possible.


Healthy communities & Infrastructure

  • To enable provision of the necessary infrastructure to support residents, businesses, communities, the environment and individuals.
  • To prioritise investment in strategic services and infrastructure, improving connectivity and service provision.
  • To support communities to deliver plans and projects at the district and neighbourhood levels, specifically providing opportunities to for the District Councils supporting communities on the development on neighbourhood plans.
  • To work with the communities of Sudbury and Stowmarket in the development of a vision and strategy for both towns.
  • To support the development of proposals for a Sudbury Western Relief Road project.


Consultation Questions:

(174) Q 1.        What do you think the vision should be?

(153) Q 2.        Do you agree with the identified objectives? Please explain reasoning.

(114) Q 3.        Are there other objectives which should be added?

(133) Q 4.        What should be a priority across the district area? (please state which district)

(160) Q 5.        What is most important for your town or village?


(15) Duty to Cooperate

What is the Duty to Cooperate

The Duty-to-Cooperate is applied to local planning authorities by Section 110 of the Localism Act 2011 and requires the Councils to apply the Duty to Cooperate in relation to planning of sustainable development. It is a prerequisite test for the Examination of Local Plan production.

Paragraph 156 of the National Planning Policy Framework sets out that Local planning authorities should set out the strategic priorities for the area in the Local Plan which should include strategic policies for:

1)      the homes and jobs needed in the area

2)      the provision of retail, leisure and other commercial development

3)      the provision of infrastructure for transport, telecommunications, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat)

4)      the provision of health, security, community and cultural infrastructure and other local facilities

5)      climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment, including landscape

Further information regarding the Duty-to-Cooperate can be found on the Government national planning guidance website at -

What are we cooperating on

The full list of bodies in the Duty-to-Cooperate is set out in Part 2 of The Town and Country Planning (Local Planning) (England) Regulations 2012.

The Councils in the Ipswich Housing Market Area (HMA), namely; Babergh DC, Ipswich BC, Mid Suffolk DC, Suffolk CC and Suffolk Coastal DC already have a long history of cooperation on strategic planning matters. However, due to the geographical context of Babergh and Mid Suffolk districts the potential matters for strategic cooperation are complex extending mainly across Suffolk, Norfolk and Essex.

A summary of the current key issues and identified partners which the Council is cooperating with is identified below. As the Local Plan (and other neighbouring Local Plans) develops, there may be additional key issues which also need to be considered.


Key planning issue


Key DtC partners




1)      Defining housing market area and objectively assessed need

Ipswich HMA authorities, Waveney DC, St Edmundsbury BC, Braintree DC, Tendring DC, Colchester BC, South Norfolk DC, Breckland DC, New Anglia LEP, Greater London Authority

2)      Resolving if unmet housing need is identified and the approach to delivery of the housing requirement

Ipswich HMA authorities Waveney DC, St Edmundsbury BC, Braintree DC, Tendring DC, Colchester BC, South Norfolk DC, Breckland DC, New Anglia LEP, Homes & Communities Agency

3)      Impact of bordering strategic housing developments

Ipswich HMA authorities, Waveney DC, St Edmundsbury BC, Braintree DC, Tendring DC, Colchester BC, South Norfolk DC, Breckland DC




4)      Defining functional economic market area and objectively assessed need

Ipswich HMA authorities, St Edmundsbury BC, Braintree DC, Tendring DC, Colchester BC, South Norfolk DC, Breckland DC, New Anglia LEP

5)      Enterprise Zones and Local Development Orders

Ipswich HMA authorities, Suffolk CC, New Anglia LEP

6)      Impact of bordering strategic employment land developments

Ipswich HMA authorities, St Edmundsbury BC, Braintree DC, Tendring DC, South Norfolk DC, New Anglia LEP

Retail, leisure & other commercial



7)      Enhancement and regeneration of retail centres

Ipswich HMA authorities, New Anglia LEP

Infrastructure provision



8)      Provision and enhancement of strategic infrastructure improvements


Ipswich HMA authorities, Suffolk CC, Essex CC, Norfolk CC, Highways England, West Suffolk CCG, East Suffolk CCG

Environmental protection


9)      Conservation and enhancement of the natural and historic environment

Ipswich HMA authorities, Suffolk CC, Natural England, Environment Agency, Historic England


How are we going to cooperate

The Council is already cooperating on many of the key relevant issues such as jointly commissioning strategic evidence and sharing consistent assessment methodologies with the other planning authorities in the Ipswich Housing Market Area.

Detailed discussions will be held with other Duty to Co-operate bodies when the relevant sections of the Joint Local Plan are being drafted.

Consultation Questions:


(109) Q 5A. Do you agree or disagree with the identified key issues for compliance with the Duty-              to-Cooperate for the Babergh and Mid Suffolk Joint Local Plan? Please explain why.

(73) Q 6.        Are there any other key planning issues which need to be considered in accordance               with the Duty-to-Cooperate? Please explain why.

[1]  See Glossary

[2]  See Glossary

[3]  See Glossary

[4]  See Glossary

[5]  See Glossary

[6]  See Glossary

[7]  See Glossary

[8]  See Glossary

[9]  See Glossary

[10]  See Glossary

[11]  See glossary

[12]  See Glossary

[14]  See Glossary

[15]  Census 2011, KS102EW, Age Structure

[16]  Suffolk Observatory 2013

[17]  Hidden Needs Report – Hidden Needs in Suffolk Five Years On (Report to Suffolk Community Foundation, 2016)

[18]  Suffolk Observatory 2013

[19]  Suffolk Observatory 2015

[20]  Ipswich and Waveney Economic Areas Employment Land Needs Assessment (2016)

[21]  Ipswich and Waveney Economic Areas Employment Land Needs Assessment (2016)

[22]  See Glossary

[23]  See Glossary

[24]  See Glossary

[25]  See Glossary

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