Joint Local Plan Additional Modifications

Modification

(Strikethrough text = removal

Underlined text, italic and bold text = additional text

Plain italic = original wording)

Amend JLP front cover to remove reference to Reg 19. Removal of wording Pre-Submission (Reg 19) - November 2020 from footer of pages. Insert "Part 1" to document title and footers.

Modifications to page numbers and chapters in content page to reflect changes to the JLP.

Foreword to be removed

02.02 Babergh and Mid SuffolkThe Councils work collectively to deliver shared priorities, as set out in the Joint Corporate Plan (2019 - 2027). The main priority areas are the economy, environment, housing, wellbeing, communities and customers. The Plan provides the mechanism to enable the delivery of the spatial elements of the vision and priorities.to be able to shape the delivery of development in the context of the Joint Corporate Plan priorities.

Profile

02.03 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. Together the Ddistricts have six main population 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.

1. Delivering Housing

   Significant numbers of new homes need to be planned provided for over the Plan period along with employment and community facilities and services in Babergh and Mid Suffolk respectively.

2. Achieving an Uplift in Delivery

   Rates of annual housing delivery in Babergh and Mid Suffolk have been consistently below target. The number of homes to be delivered per annum has increased with the application of the Standard Methodology, which means that from 2018 onwards the annual rate of housing to be delivered has also increased by around 40% in each council. The revised uplift in housing numbers compounds the challenges of delivery.However, as at April 2021, the Councils have a high level of extant planning permissions.

03.01 The Plan sets the spatial vision of the place that Babergh and Mid Suffolk will become by 2037, based upon the following key priorities:

• Enabling sustainable economic growth;
• Enhancing and protecting the environment;
• Delivering appropriate housing through existing commitments and windfall development; and
• Supporting strong and healthy communities &and delivering Infrastructure.

03.02 To contribute to the delivery of the vision and priority areas, the Plan will set out an ambitious growth agenda. This 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.

By 2037, Babergh and Mid Suffolk Districts will have transitioned to a low carbon future, with the ambition to be carbon neutral by 2030. Significant gGrowth will have occurred, embedding the principles of sustainable development, balancing social, economic and environmental issues.

Major new housebuilding will have taken place, including the delivery of affordable housing for first time buyers and those on low incomes, whilst recognising the Districts have an ageing population.New homes will have been delivered, including affordable housing and housing for an ageing population. Strategic employment sites will be protected, and their proposed expansion supported in principle to ensure jobs are retained locally and created where opportunities exist, allowing businesses to expand and new businesses to invest in the area.

There will be enhanced biodiversity through the delivery of measurable net gains across the Districts, supported by an identified ecological network. The historic and landscape character of the Districts will be apparent with development being sensitive to this character and applying good design principles.

There will be a clear vision for the towns of Hadleigh and Sudbury in Babergh, and for Eye, Needham Market, and Stowmarket in Mid Suffolk. Many communities will have adopted nNeighbourhood pPlans, adding locally to the decision-making process.

A significant amount of growth will have taken place within the strategic transport corridors, recognising the opportunities that exist to move around the area and the relationship with the wider housing market area and functional economic area.

Infrastructure including education, health and transport will have been delivered, including school extensions, expanded health facilities and more opportunities for walking, cycling and use of public transport, as communities grow with active and healthy futures.

03.03 The objectives for the Plan are as follows:set out under four priority areas below:

i. Supporting the delivery of homes, including affordable housing provision. Delivery of the right types of homes, of the right tenure in the right place meeting need.

2. Encourage the development of employment sites and other business growth, of the right type, in the right place and encourage investment in infrastructure, skills and innovation in order to increase productivity.

3. To encourage inward investment to the Districts, by supporting Freeport East and the delivery of Gateway 14, as well as infrastructure improvements that will enable the continued growth of The Port of Felixstowe and strengthen the Districts' links to The Port of Felixstowe and the rest of the UK.

vii. To enable all communities to thrive, grow, be healthy, active and self-sufficient through supporting the provision of the necessary infrastructure, and encouraging more sustainable travel, including through the Ipswich Strategic Planning Area Transport Mitigation Strategy and the Councils' Local Cycling and Walking Infrastructure Plan (LCWIP).

viii. To support communities to deliver plans and projects at the district and neighbourhood levels, specifically providing opportunities for the District Councils to supporting communities on the development ofnnNeighbourhood pPlans.

ix. To work with the communities of Hadleigh and Sudbury in Babergh and Eye, Needham Market and Stowmarket in Mid Suffolk in the development of a vision and strategy for these towns.

05.02 Section 3 of the National Planning Policy Framework (NPPF) (February 20192021) sets out a Local Planning Authority's (LPA's) approach to plan-making. Paragraph 17 identifies that 'The development plan must include strategic policies to address each local planning authority's priorities for the development and use of land in its area'⁶. Paragraph 20 goes on to state that the 'Strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for:

1.  housing (including affordable housing), employment, retail, leisure and other commercial development;
2.  infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);
3.  community facilities (such as health, education and cultural infrastructure); and
4.  conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation.'⁷

05.05 The Councils LPAs in the Ipswich Housing Market Area (HMA), namely Babergh District Council, East Suffolk Council (formerly Suffolk Coastal District Council), Ipswich Borough Council, and Mid Suffolk District Council already have a long history of cooperation on strategic planning matters. The planning area of the Ipswich HMA is also known as the Ipswich Strategic Planning Area (ISPA).

Norfolk Council becomes Norfolk County Council in sections 3 and 6.

Anglia Water becomes Anglian Water in section 8.

Highways England becomes National Highways in section 8.

West Suffolk Clinical Commissioning Group, Ipswich and East Suffolk Clinical Commissioning Group becomes NHS Suffolk & North East Essex Integrated Care Board in section 8.

Change to box 9.

Rrecreational Ddisturbance Aavoidance and Mmitigation Sstrategy

05.08 The Councils are cooperating on manyall 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.

05.09 The Ipswich HMA planning authorities meet regularly through the Ipswich Strategic Planning Area Board, and have published a signed Statement of Common Ground, which identifies potential cross-boundary matters to be addressed within the Ipswich Housing Market Area. SCC and Natural England are also both signatories to the Statement of Common Ground. This Statement of Common Ground will be updated as each Local Plan within the HMA proceeds to adoption. A further Statement of Common Ground will be produced with those planning authorities outside of the Ipswich HMA as the plan proceeds to adoption.

05.10 Cooperation has taken place with infrastructure providers in preparing the Infrastructure Delivery Plan, in particular covering the key strategic infrastructure matters of water, education, health and transport. The Councils have also engaged with all partners through the preparation of the Plan. The published Duty to Cooperate statement sets out the Councils' cooperation on the strategic cross-boundary planning matters.

06.01 National planning policy requires that local planning authorities produce Local Plans to meet, as a minimum, the identified future housing needs in the Plan area, as well as cooperate with neighbouring local planning authorities to meet the overall needs of the identified Housing Market Area (HMA) as a whole. The relevant HMA for the Babergh and Mid Suffolk area is known as the Ipswich HMA which consists of the entire districtslocal authority areas of Babergh, Ipswich, Mid Suffolk and the area of the former Suffolk Coastal District Council (now part of East Suffolk District Council).

06.02 To determine the minimum number of homes needed, the National Planning Policy Framework (NPPF) requires that strategic policies should be informed by a local housing need assessment, conducted using the Government's standard methodology for calculating local housing need⁸. The methodology is made up of a calculation involving key, publicly available data from Office for National Statistics (ONS) on household growth projections and local housing affordability ratios.

06.03 Babergh and Mid Suffolk have undertaken to produce a jointThe Plan document with manyhas a set of common policies, although the identified development needs and monitoring of performance will be undertaken and recorded separately for each respective local authority district area. The baseline year of the Plan is April 2018, with the Plan end date of March 2037 (19 years). Using the standard methodology, the local housing need for Babergh and Mid Suffolk isareas are as follows:

Table on page 26 identifying the Standard Method Totals and Annual Local Housing Need Target for each authority to be labelled as 'Table 2'.

Table 2 - Local Housing Need in Babergh and Mid Suffolk

06.04 The local housing need represents a 'starting point' in identifying housing requirements for Babergh and Mid Suffolk. There are a number of other factors to consider when setting the housing requirement. The Strategic Housing and Economic Land Availability Assessment (SHELAA) indicates that there is a sufficient supply of land to meet the housing need set out in the standard methodology. National Planning Practice Guidance sets out that there may be circumstances where additional growth may be required. However, it is important to understand the likelihood of higher levels of growth being delivered. The local housing need figures produced by the Government's standard methodology is significantly higher (approx. 30%-40%) than the currenthistoric levels of housing delivery. This Plan aims to set out a proactive approach which can help to significantly boost the supply of housing land and delivery in the dDistricts, consistent with Government policy. In addition, the Councils are also addressing delivery through reviewing stalled planning permissions and investing in building new local houses.

06.05 Babergh and Mid Suffolk are planning to meetanticipate meeting their full identified local housing needs. Unmet housing need has not been identified to Babergh and Mid Suffolk by any neighbouring authorities, either within the Ipswich HMA or beyond. An Ipswich Strategic Planning Area (ISPA) statement of common ground is agreed between authorities in the Ipswich HMA detailing a process to follow should unmet needs become identified. Should it be determined through the plan making process that another authority within the ISPA is unable to meet its minimum housing need, the Councils will, under the duty to co-operate, work collaboratively to determine whether housing development needs that cannot be met wholly within a particular area, could be met elsewhere. An agreement to seek to accommodate unmet housing need would trigger an immediate review of the strategic policies of thisthe Plan.

06.06 As of April 2018, a A substantial number of dwellings required are already accounted for via commitments, as set out in the table below. These will contribute to meeting the overall requirement.

06.07 Delivery is a key challenge of the Plan. In recent years, the delivery of new housing has been below the adopted requirements and the new local housing need figure in both Districts. The Councils are taking proactive measures to improve delivery rates including, reviewing stalled planning permissions and investing in building new local houses. In order to help maintain a consistent and favourable supply and delivery of development throughout the Plan period, the policies aim to identify and create flexibility for sufficient housing development. To achieve this, the Plan has identified a buffer of approximately 20% in the supply of new land (see Spatial Distribution chapter). This will give greater confidence to meeting delivery targets and also to communities knowing that land for future needs is identified rather than unknown.

06.08 The NPPF recognises that small and medium sized sites can play an important role in meeting housing requirements and can improve delivery as they can be built out relatively quickly. Paragraph 6869 of the NPPF requires local planning authorities to identify land to accommodate at least 10% of the housing requirement on sites no larger than one hectare. This requirement is met by existing commitments. the Plan.

06.09 In addition to ensuring that enough new housing is being delivered, it is important to ensure that the right mix, type and size of new housing is delivered. This will provide a wide choice of homes and contribute towards sustaining mixed communities and demographics. The most up to date Strategic Housing Market Assessment (SHMA) will provide conclusions on the size of property needed in each tenure for the Districts as a whole. Currently, the SHMA (January 2019) provides the most up to date evidence on theeach District-wide needs for mix and type of housing across the Districts over the planPlan period. This demonstrates that the greatest need is for two, three- and four-bedroom accommodation. If appropriate new evidence for each District is produced on the mix and type of housing required during the pPlan period, this will be made available on the Councils' websites in due course. In addition to the District wide SHMA, local housing needs surveys may give a more localised view on the type and size of new housing required. The appropriate tenure mix of housing development is set out in the relevant affordable housing policies of the Plan.

New paragraph to be inserted after 06.09:

In addition to SHMA evidence for each District, communities may also produce their own up to date robust local housing needs surveys which may give a more localised view on the type and size of new housing required. The appropriate tenure mix of housing development is set out in the relevant affordable housing policies of the Plan. Adopted Neighbourhood Plans may also set out an approach to help influence housing type and mix specific to the local area. Equally, regard will also need to be had to the Plan and any supporting evidence to ensure the local housing needs of each District are adequately met.

07.01 This planning policy reflects the size, type and tenure of housing needed for different people in the community. Affordable housing is an identified need within Babergh and Mid Suffolk Districts as required by Paragraph 61 of the NPPF (2019) The Strategic Housing Market Assessment (SHMA) - Part 1 and Part 2 (May 2017) and subsequent SHMA (2014-based Local Housing Need) evidence update (January 2019) were jointly commissioned by Babergh and Mid Suffolk District Councils, Suffolk Coastal and Waveney District Councils (now East Suffolk Council) and Ipswich Borough Council. The SHMA documents provides the evidence to justify the need and requirement for affordable housing. This planning policy reflects the size, type and tenure of housing needed for different people in the community and affordable housing is an identified need within Babergh and Mid Suffolk Districts as required by Paragraph 62 of the NPPF.

07.02 Affordable housing is housing for sale or rent, for those whose needs are not met by the market, which includes housing that provides a subsidised route to home ownership and/or is for essential local workers. Annex 2 of the NPPF (20192021) sets out the definition of affordable housing and is split into the following four main categories: affordable housing for rent, starter homes, discounted market sales housing and other affordable routes to home ownership. An additional form of affordable housing introduced in 2021 are First Homes⁹, which, post the transitional arrangements, should equate to 25% of the affordable housing provision. However, under the transitional arrangements, this Plan does not address First Homes.

Where viability assessments are submitted, the Councils will expect applicants to clearly set out all of the assumptions and evidence behind the assumption that go into the appraisal. The supply of information must be presented on an open book basis using the Homes and Communities Agency Development Appraisal Tool (DAT model) ¹²produced by Homes England, including the calculation of residual land value and any cash-flow analysis. There must be no hidden calculations or assumptions in any model or appraisal. Viability assessments will be made publicly available. For the implementation of exceptional circumstancesreference must be made to thedevelopment management policy on Affordable Housing.

08 - Settlement Hierarchy08 - The sustainable location of new development

New paragraphs inserted before para 08.01

As detailed in the Introduction chapter, this Plan is focused upon setting out the strategic and non-strategic policies for the Plan area. However, a Part 2 Plan is anticipated to address further issues including, a settlement hierarchy, the spatial housing strategy, the approach to Gypsy, Travellers and Travelling Showpeople, houseboat dwellers and any potential new allocations needed. In the meantime, this policy identifies how growth is expected to come forward in the Plan area.

The Joint Local Plan (Part 1 and Part 2) needs to plan for development in the right locations to meet the identified local housing and economic needs across the Plan area. Growth has many key benefits, including the securing of greater local investment, adapting and enhancing the local environment to modern living contexts, creating local job opportunities and ensuring local people have suitable and affordable homes to live in.

08.01 In considering the broad locations for new development, national planning policy requires that sustainable development be applied through balancing social, economic and environmental objectives. Development needs to be accommodated in settlements where the need to travel can be reduced, through good access to facilities and services and where significant adverse impacts can be avoided or mitigated. In combination with the spatial distribution, the settlement hierarchy acts as a useful tool to enable these objectives to be met. National policy also emphasises the importance of recognising the intrinsic character of the countryside. To this end the plan seeks to restrict most development outside defined settlement boundaries.

Policy SP05 moved into Chapter 10.

Paras 09.25-09.28 moved to Chapter 10.

Policy SP06 moved into Chapter 10.

10 The Economy - Tourism

Text modified from original paras 09.25 to 09.28 (supporting SP06) and inserted into updated Chapter 10.

Town cCentres, Retail & Leisure

09.25 As Babergh and Mid Suffolk are largely rural Districts, the towns and core villages within them serve an important function in the provision of shopping, employment and leisure opportunities.The towns in Babergh and Mid Suffolk have an important function serving district-wide catchments in the provision of shopping, employment and leisure opportunities.However, tThere is also a substantial influence offrom the neighbouring major retail centres of Ipswich, Bury St Edmunds and Colchester.which are located just outside the Plan area. The Councils' Retail and Town Centres Study (2015) has been used to identify the strengths, opportunities of key retail centres and the capacity for further retail and commercial leisure development in the Plan area..

09.26 In order to maintain the vitality and viability of existing town and retail centres, new retail,main town centre uses (as defined by the NPPF) leisure and community facilities will continue to be directed sequentially to the town centres ofthe towns in Babergh and Mid Suffolk and to the core and hinterland villages as defined in the settlement hierarchy.Sudbury, Hadleigh, Stowmarket and those defined centres in made Neighbourhood Plans.

09.27 The sequential approach ensuresestablishes a town centre first approach for retail development will be in sustainable locations with good means of accessibility supported by regular public transportation. Where proposals developments are proposed to be are in located on edge of centre and out of town centre sites locations, developers will be required to provide evidence to justify the location by demonstrating there are no suitable alternative sites within or adjacent to a the town centres. When considering edge of centre and out of centre proposals, preference will be given to accessible sites which are well connected to the town centres. The potential implications of the permitted changes through the Use Class E for retail and leisure proposals outside town centres should be fully assessed taking account of the need to protect the vitality and viability of the town centres.

09.28 Due to the historic richness of the Districts  A a number of town centres fall within Conservation Areas,where a number of Listed Buildings are present therefore within which development proposals will need to take into consideration the effect itthey may have on the historic townscape.

These paragraphs will now follow on from new inserted supporting text and Policy SP05 and SP06 as above.

10.01 -NPPF paragraph 83 - To support sustainable rural tourism and leisure developments which respect the character of the countryside.

10.02The Tourism Sector is an important part of the Suffolk economy. Babergh and Mid Suffolk Districts are located strategically across southern and central Suffolk They include Constable Country bordering into Essex, contain the Shotley Peninsula and part of the Suffolk Coast and Heaths AONB, Dedham Vale AONB, the 'wool towns' (including Lavenham, Kersey, Polstead and Hadleigh), as well as the Heart of Suffolk which contains historic market towns of Eye, Hadleigh, Needham Market, Stowmarket, Debenham and Sudbury. Constable Country runs along the Essex and Suffolk border in Babergh.

10.03Sustaining Supporting the tourism sector is essential for the Suffolk economy. Tourism in Babergh has an estimated worth of £188133 million and provides 3,0672,601 full-time equivalent (FTE) jobs (119.4% of all employment in the dDistrict). In Mid Suffolk, ittourism is worth around £167118 million and provides providing 2,7672,304 FTE jobs (97.5% of employment in the dDistrict) [Destination Research, the Economic Impact of Tourism, 20162021].

10.04Individual tourism and leisure facilities of strategic significance include:

• Needham Lake;
• Gainsborough's House; and,
• The Museum of East Anglian Life.

10.05Based on the heritage and agricultural origins of the area there are specialist clusters based on heritage, food and drinks with clusters of businesses located such as Muntons, Aspall, Copella and Jimmy's Farm. Specialist related events are also held around the stately halls of Helmingham, Melford and Kentwell Halls. Both Districts are rich with heritage assets and rural landscapes. Heritage/landscape-led tourism which seeks to bring back disused or under-used heritage assets into appropriate productive use or that enables the enhancement and protection of the landscape character is encouraged

10.06 In order to support the unique tourism offerings of the facilities, each are designated for tourism related purposes where the development and expansion of uses which enhance their tourism and leisure offer is supported in principle, where appropriate in the scale, character and nature of their locality.

10.07 Babergh District recognises the Dedham Vale AONB and Suffolk Coast and Heaths AONB as important to the tourism sector. The Dedham Vale AONB Management Plan 2016 and The Suffolk Coast and Heaths AONB Management Plan 2018 both acknowledge a key quality of the AONB is its ability to link economic well-being and the landscape, with a flourishing tourism industry, which draws on the natural beauty, tranquillity and historic assets within the AONB.

10.08 The National Planning Policy Framework (2021, Para 84), encourages sustainable rural tourism and leisure developments which respect the character of the countryside. Within the AONBS,development of tourism initiatives in rural locations, provided the character of the countryside is respected, and pollution and other adverse effects on the local and natural environments are minimised. Ssustainable tourism, as advocated in the adopted AONB Management Plans, is strongly supported. in the implementation of tourism development throughout Babergh, but with particular regard to the AONBs.

10.09 In order to ensure tourism can be sustainable, facility proposals that are adapted to meet existing and potential climate change issues and can demonstrate a contribution toclimate change mitigation (such as access by other modes of transport other than the car) will be supported.

10.10 In terms of commercial leisure capacity, the 2015 study identifies capacity for 4 new cinema screens in both districts. In 2018, The Regal Theatre in Stowmarket received a grant form Mid Suffolk District Council to fund two additional cinema screens. There is also an increasing demand for gyms, and it is recommended that additional capacity could be supported in town centres, along with small scale ten pin bowling provision in the longer term.

10.11 To encourage visitors to support the economy of the Districts, the 2015 study identified the need to explore potential family attractions and provide greater sustainable connectivity from the train stations to desirable destinations and attractions, through bespoke walking and cycle ways.

11.01 The provision of infrastructure is fundamental to maintaining the quality of life, the prosperity and environmental credentials of the area. It is essential that any future growth and development is supported by infrastructure to meet the needs of the population, businesses and the wider community. There are a wide range of infrastructure types necessary at both a local and strategic level. It is critical that the strategic and cumulative infrastructure needs are considered and addressed at a strategic district wide level. This approach will then inform how individual developments can contribute and support the delivery of such strategic infrastructure, as well as understanding the more localised and scheme specific infrastructure capacity issues and needs.

11.02 The key strategic infrastructure projects relevant to the Plan area include key transport improvements, an schools education expansion programme, environmental protection of internationally important environmental designations in and around the Plan area, improvements to digital infrastructure and the water supply and treatment network. A comprehensive list of all strategic and local infrastructure is set out in the Babergh and Mid Suffolk Infrastructure Delivery Plan. In the Hartismere Water Resource Zone (WRZ) in Mid Suffolk District, water supply infrastructure network upgrades will be required. The network upgrades will not be available before 2032 at the earliest.

11.03 Across Suffolk and beyond, tThere are strong aspirations towards the delivery of key infrastructure projects, some of which will cross over administrative local authority boundaries, including into Ipswich. As such, development in the Ipswich Strategic Planning Area (ISPA) is predicted to add significant strain on the transport network. Therefore, a Transport Mitigation Strategy, which provides a package of transport measures, has been identified to reduce vehicle movements arising from new development and existing communities, and address air quality impacts in and around Ipswich.

11.04 The overall strategy for the pattern, scale and quality of development as set out in Joint Local Plan has been informed by the provision of existing capacity and the deliverability of new infrastructure provision. Further information on the assessment of infrastructure is set out in the Babergh and Mid Suffolk Infrastructure Delivery Plan (IDP).

11.05 To support the delivery of growth across Babergh and Mid Suffolk Districts, the Councils will continue to work with service providers, statutory bodies and neighbouring authorities to ensure support for the timely delivery of the required infrastructure throughout the Plan period.

11.06 Monitoring of infrastructure delivery and re-assessment of infrastructure requirements will be undertaken regularly.

11.07 All allocation sites must have a project level HRA if they are within the zone of influence of protected habitats sites. Where relevant, project level Habitat Regulation Assessments (HRA), Construction Environment Management Plans (CEMP) and lighting design schemes for planning applications will be required.

11.09 Many communities within the Babergh and Mid Suffolk area need improvements to community infrastructure, to support the overall and proposed distribution of growth. The Infrastructure Delivery Plan (IDP) has identified which improvements to community infrastructure are required throughout the Plan period. lifetime of the Plan. Development must have regard to this, to ensure that appropriate and sustainable development can be supported. The allocations made in the Plan are accompanied by a clear list of infrastructure requirements, which are considered necessary to bring them forward for development and have been subject to suitable viability testing.

12.01 The aims of the Plan are to ensure sustainable development can be achieved, whilst supporting the objective to contribute to conservingprotecting and enhancing our natural, built and historic environment. This includes making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including a low carbon economy NPPF (2019 2021 pPara 8).

12.02 To protect conserve and manage the environment, the Councils will employ a hierarchical approach of avoidance, mitigation and compensation.

12.03 The NPPF (2021 Para. 174) advocates that local plans should contribute to and enhance the natural and local environment(NPPF para.170). A framework of policies supports this strategic approach:

1. Environmental Protection and Conservation
2. Biodiversity
3. Landscape
4. Historic Environment
5. Change of use of Land

ENVIRONMENTAL PROTECTION AND CONSERVATION

12.04 Babergh and Mid Suffolk have a rich and varied natural environment, including rivers,and estuaries, open spaces and countryside, but some local resources are under pressure.

12.05 The  Eenvironmental protection and conservation measures provides a managed policy framework which is adaptable and can respond to pressures through measuresapproaches such as prevention, management, mitigation or adaptation from flood risk, water resources, land resources, pollution and climate change.

12.06 All components of the green infrastructure network must be managed at a strategic level to ensure cross cutting boundary and cumulative issues and impacts are effectively managed at a strategic level. This includes natural components, such as biodiversity, geodiversity and landscape, as well as assets within settlements, including historic assets, green spaces and recreational areas.

12.07 Local sites of biodiversity and geodiversity value are identified in this the Plan to ensure consideration can be given to the level of protection provided to these local sites - including County Wildlife Sites, County Geodiversity Sites, Local Nature Reserves and pPriority species and habitats.

12.08 In districts, such as Babergh and Mid Suffolk, future development must be managed to respect the key features and local distinctiveness.

12.09 Along with Areas of Outstanding Natural Beauty (AONBs), Sites of Scientific Interest (SSSIs) and Conservation Areas, there are also less well-known features that makes all landscape character areas significant and worthy of protection. It is important to recognise these elements, in order to balance interests and consider potential impacts in the future, as well as, to identify any further management or guidance which may be required that goes beyond the boundaries of defined designations covered by legislation. Furthermore, in cases where mitigation measures are necessary, it may help inform the type of measures which could be appropriate.

12.10 There are approximately 16 identified Landscape Characters within Babergh and Mid Suffolk. Babergh makes a valuable and varied contribution to this, with the Suffolk Coasts and Heaths AONB and Dedham Vale AONB, including the Stour Valley, covering a considerable part of the dDistrict. Legislation provides protection and guidance within these areas and both have Management Groups Plans providing a robust framework for management of challenges facing these areas in the future.

12.11 The importance of heritage assets to the historic character and distinctive appearance of both dDistricts should not be underestimated. The historic environment is a precious resource valued by residents, visitors and local businesses, and the attractive historic character of many of the villages and wealth of traditional buildings is the focus of a healthy and growing tourism sector.

12.12 The Plan seeks Tto continue to conserve and enhance the heritage assets throughout the dDistricts, for the benefit of all to enjoy as well as to. To enrich the quality of life through learning from local historic knowledge and thereby ensure assets are safeguarded for future generations.

12.13 Protection for internationally and nationally protected sites is established in legislation. In producing the Plan, consideration can be has been given to the level of protection to afford to local sites of biodiversity and geodiversity value including County Wildlife Sites, County Geodiversity Sites and priority habitats and species.

12.14 Through previous Habitats Regulations Assessments, there has been recognition of the sensitivity of the internationally pProtected Habitats Sites and the potential for significant effects arising from increased recreational disturbance related to new housing development. The sites are protected under the provisions of Wildlife and Countryside Act 1981 and Natural Environment and Rural Communities Act 2006.National policy identifies that development should initially consider whether avoidance of these sensitive areas is practical. In circumstances where this is not possible, appropriate mitigation should be provided, including being able to demonstrate well-designed open space/green infrastructure, proportionate to its scale, and prevents a significant adverse effect on site integrity to a Habitats Site. Such provisions can help minimise any predicted increase in recreational pressure to the Habitats Sites by containing the recreation within and around the development site boundary away from Habitats Sites, in accordance with Natural England best practice advice¹⁶. Suitable Accessible Natural Green Space (SANGS) guidance¹⁷ can be helpful in achieving this, including provision of high-quality, informal, semi-natural areas; circular dog walking routes of at least 2.7 km within the site and/or with links to the surrounding public rights of way; dedicated 'dogs-off-lead' areas; signage/information leaflets to householders to promote these areas for recreation; dog waste bins; and a commitment to the long-term maintenance and management of these provisions. Babergh, Ipswich, Mid Suffolk, Suffolk Coastal and Waveney Councils (now East Suffolk Council) are taking a joined-up approach to mitigating these impacts. For Babergh and Mid Suffolk, these relate to the Stour and Orwell and Deben estuaries. The Councils have produced a Suffolk Coast Recreational disturbance Avoidance and Mitigation Strategy (RAMS), which identifies and costs the measures necessary to mitigate recreational and leisure impacts and confirms how they will be funded. The intention of the strategy is to avoid adverse effects on the integrity of the Habitats Sites, in combination with other plans and projects, over the lifetime of the Plan.

New paragraph to be inserted after paragraph 12.14:

Babergh, Ipswich, Mid Suffolk, Suffolk Coastal and Waveney Councils (now East Suffolk Council) are taking a joined-up approach to mitigating these impacts. For Babergh and Mid Suffolk, these relate to the Stour and Orwell, and Deben estuaries. The Councils have produced a Suffolk Coast Recreational Disturbance Avoidance and Mitigation Strategy (RAMS), which identifies and costs the measures necessary to mitigate recreational and leisure impacts and confirms how they will be funded from residential development. The intention of the strategy is to avoid adverse effects on the integrity of the Habitats Sites, in combination with other plans and projects, over the lifetime of the Plan period.

12.15 Strategic projects may require joint working by public bodies, to ensure the requirements of the Habitats Regulations are met.

Updated map for Protected Habitats Mitigation Zones map

12.21 The Plan aims to future proof all development from the impact of climate change, by supporting the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change is a national core planning principle taking account of the long-term implications for flood risk, coastal change, water supply, biodiversity, landscape and visual impacts, the risk of extreme winter and summer temperatures, and overheating from rising temperatures. This should underpin both plan-making and decision-taking (NPPF, 2021, Para. 20). The Plan seeks to meet these aims through a combination of Cclimate Cchange policies, including issues on sustainable construction, design, energy, flood risk and water management.

New paragraph to be inserted after paragraph 12.21:

Approaches to mitigate and adapt to climate change include sustainable construction techniques that regulate building temperatures, tree planting and shelter in public realms including public transport nodes and stops, and biodiversity net gain.

12.22 Mitigation means to reduce or delay the impact of climate change, by reducing the flow of greenhouse gases into the atmosphere, either by reducing the burning of fossil fuels or enhancing stores that accumulate and store gases such as oceans, forests and soil. Adaption means to adapt adjust to life in a changing climate with the goal to reduce our vulnerability to harmful effects of climate change.

PART 2 SECTION B

NON-STRATEGIC LOCAL POLICIES

13.01 Sustainable development is at the heart of planning. The location of development is a critical determinant on its sustainability and has a significant effect on the extent to which it contributes socially, economically and environmentally.

13.02 Paragraph 78 of the NPPF states that "To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby."

13.03 Within the rural areas of Babergh and Mid Suffolk there are many small, dispersed communities and clusters of houses. Whilst they do not have the level of services and facilities to support larger scale new housing, some small-scale development may be appropriate in order to achieve the ambitions of NPPF paragraph 78 (above). This will also help meet the Councils' objective to support strong and healthy communities, by enabling people to stay within their communities.

13.04 It is known the Districts have an ageing population with physical disabilities. Therefore, there is an identified need to meet future housing demands regarding accessible and adaptable dwellings. This windfall policy will support the delivery of M4(2) standards, along with other measures set out in the Plan.

LP01 - Hamlets and Clusters of development in the countryside Windfall infill development outside settlement boundaries

New paragraphs for supporting text to LP01:

13.01 There are opportunities for sustainable windfall infill development across Babergh and Mid Suffolk. In the past, such opportunities have often been constrained through restrictive planning policies, particularly outside settlement boundaries.

13.02 Across the Plan area there are many small-dispersed communities. Whilst these communities do not contain the level of services and facilities which would be necessary to support larger scale new housing developments, small scale windfall infill development may be appropriate to enable sustainable development where it will enhance or maintain the vitality of the rural communities.

13.03 Windfall infill development is not considered necessary to meet each Districts housing need. Consequently, the level of development in these communities should be limited based on the consideration of the local context and circumstances and the cumulative impact of development proposals should be managed to ensure development is appropriate and sustainable. For example, there may be cases where two detached dwellings or a terrace of three small dwellings would be much more in keeping with the surrounding property than a semi-detached pair of dwellings.

13.05 The creation of an annexesto an existing dwelling, whether the main host dwelling is located inside, or outside settlement boundaries can often create a useful facility for the support and care of family members. additional accommodation for a dwelling and can help to create more flexible use of the accommodation to respond to changing family circumstances over time.

13.06 A rResidential annexes should therefore be designed to ensure the planning unit/ dwelling curtilage, as a whole, so that they are ancillary in use and scale to the main dwelling unit and provides genuinely flexible subordinate ancillary accommodation that can be adapted and re-adapted to meet the changing needs of an extended family circumstances over time. This should include the option of absorbing the annexe back into the main dwelling accommodation, if necessary, by the same or future occupiers.

13.07 To meet these requirements,rather than create a separate dwelling unit, it is essential that the main dwelling and annexe accommodation are either directly physically and/or functionally connected, by an internal link or and have a close spatial relationship with shared facilities and space.

13.08 The Councils will apply restrictive conditions or obligations to ensure annexes do not Unduly large or detached annexes can prove an economic and practical liability when vacated or when the property changes ownership. This leads to pressure for the annexe to be severed and let separately from the main dwelling. This can create sub-standard accommodation dwellings with inadequate standards of access, amenity and space, which is unacceptable in planning terms. and potentially result in additional dwellings in unsustainable locations.

13.09Householder permitted development rights may allow the siting of caravans and mobile homes within the curtilage of an existing dwelling, under certain conditions and subject to any restrictions²³. The installation of caravans and mobile homes may be approved for use as annexe accommodation, where considered appropriate and acceptable when assessed and adequately justified. Such approvals will be subject to a condition or legal agreement, which restricts occupation to meet the specific need identified. It may also be necessary to impose a time limit and or any other necessary restrictive conditions. Additional accommodation within existing dwelling curtilages is generally contrary to policy of the Local Planning Authority. However, genuine, evidenced and justified exemptions can be recognised for special family and or personal circumstances identified.

13.10 Dwellings can be adaptable to meet the changing requirements of occupiers. It is often popular to extend or convert residential properties, rather than move residence. Equally, extensions and conversions to residential dwellings can create diversity and flexibility in housing stock in sustainable locations, in addition to meeting occupier needs. The Local Planning Authority will need to assess such proposals to buildings and the adjoining curtilage, to ensure the proposal does not create unacceptable layout, design, amenity, access, parking or any other environmental or social impacts.

13.11 All proposals are advised to have regard to any existing Supplementary Planning documents or guidance endorsed by the Local Planning Authority on good quality design principles and standards.

13.12 The LPA may impose conditions and / or remove permitted development rights to make the development acceptable in planning terms. For example, removing permitted development rights to insert new windows and erect additional outbuildings to protect the amenities of neighbouring occupiers.

13.13 New residential development can be achieved through the sub-division of large dwellings or the conversion of ancillary buildings within settlement boundaries (see Policy: Replacement dwellings and additional dwellings on sub-divided plots within settlement boundaries). It should also be noted, for planning applications for the conversion, extension or other development that involves alterations to the roof-space, there may be a need to carry out bat surveys and possibly surveys for other protected species depending on the specific nature of the proposal.

New paragraphs for supporting text to Policy LP03:

This policy addresses proposals for residential extensions, and conversion of buildings of ancillary uses (such as garages) to become part of the living accommodation. Residential extensions can add greatly to the diversity and flexibility of the housing stock and help to meet a range of occupier needs. All development should achieve good design and maintain and create good levels of amenity for future and neighbouring occupiers, whilst enhancing the character of the area.

The Councils may impose appropriate conditions or in exceptional circumstances remove permitted development rights in order to protect the amenities of adjoining occupiers.

When considering proposals for extensions and conversions to ancillary residential uses, the Councils will have regard to parking standards and other design guidance and standards for new dwellings.

LP04 - Replacement Dwellings and Conversions In The Countryside (Outside of Settlement Boundaries)

13.14 This policy sets the criteria for replacement dwellings outside settlement boundaries within the countryside. This policy has a direct interlinking relationship with policy on residential extensions and conversions, which is referred to in this replacement dwelling policy.

13.15 Replacement dwellings and extensions within the countryside (outside of settlement boundaries) can gradually change and have an individually and cumulative adverse impact on the rural character of the countryside over a period of time. This is contrary to strategic aims and policies to balance and maintain the social and environmental aspects within sustainable development and environmental policies. The sub-division of plots in the countryside could create new dwellings in the countryside contrary to the aims of the Plan and national planning policy, unless there is an exceptional circumstance (for example, residential annexe accommodation and rural exception site).

13.16 Proposals to extend residential curtilage of an existing dwelling onto agricultural land or other uses of land in the countryside for an enlarged garden, amenity land or other use is considered under policy on change in use of land.

13.17 All proposals are advised to have regard to any existing Supplementary Planning documents or guidance by the Local Planning Authority on good quality design principles and standards.

13.18 The LPA may impose appropriate conditions or in necessary circumstances remove permitted development rights to make the development acceptable in planning terms. For example, removing permitted development rights to insert new windows and erect additional outbuildings to protect the amenities of neighbouring occupiers.

New paragraphs for supporting text to LP04:

When considering proposals for replacement dwellings on existing residential plots and/or the conversion of a plot to a dwelling, the Councils will have regard to maintaining and creating good levels of amenity for future occupiers and neighbouring occupiers, and the character of the area through the use of good design.

The Councils may impose appropriate conditions or, in exceptional circumstances, remove permitted development rights to protect the amenities of the occupiers of adjoining properties. For example, removing permitted development rights to insert new or alter existing windows and balconies in order to protect the amenities of adjoining occupiers.

13.19 This policy sets the criteria for replacement dwellings inside settlement boundaries. This policy has a direct interlinking relationship with Policy on Residential Extensions and Conversions, which is referred to in this policy.

13.20 Proposals to extend residential curtilage of an existing dwelling onto agricultural land or other uses of land in the countryside for an enlarged garden, amenity land or other use is considered under policy on change in use of land.

13.21 In general terms, replacement of existing dwellings and sub-division of existing residential plots within settlement boundaries does provide a regular source of housing supply in sustainable locations and contributes to the effective and efficient use of land. When considering proposals for replacement and additional dwellings on existing residential plots within settlement boundaries the LPA will need to assess layout, design, scale, amenity and how this relates to spatial context and surroundings.

13.22 All proposals are advised to have regard to any existing Supplementary Planning documents or guidance by the LPA on good quality design principles and standards.

13.23 The LPA may impose appropriate conditions or in necessary circumstances remove permitted development rights to make the development acceptable in planning terms. For example, removing permitted development rights to insert new windows to protect the amenities of neighbouring occupiers.

LP06 - SchemeMix and type of composition and LP07 - of Housing and Supported and Special Needs Housing

13.24 The National Planning Policy Framework encourages planning policy for different housing groups in the community to reflect different size, type and tenure of housing needs for a range of people including but not limited to families with children, older people, people with disabilities, travellers, people who rent their home and people wishing to commission or build their own home.

13.25 All housing proposals must help contribute to a range of dwelling types and bedroom spaces to meet the requirements of different households as identified through evidence within the Strategic Housing Market Assessment (SHMA) (May 2017 and January 2019 update). The SHMA data for the Ipswich Housing Market Area is a key piece of data to identify the housing needs across the districts. 

13.26 Other evidence of local housing needs may include the housing register or needs survey carried out by communities, such as parish/town councils, neighbourhood planning groups or other organisations. This would be considered alongside the SHMA evidence base document that sets the needs at the District level. Any alternative assessment of local need would need to be viewed in the context that new housing development is contributing to the district wide need and not just to the needs of the parish/town where the development is proposed.

13.27 13.14 This policy is to ensure development meets a set of identified local needs within the Districts. It is also to ensure that supported and special needs housing is provided in an appropriate manner, so that it contributes to the quality of life for its residents and meets wider sustainable development requirements. Supported and special needs housing includes accommodating care for older, disabled or vulnerable people and care leavers, people with learning difficulties, mental illness and physical disabilities.

13.28 13.15 The SHMA¹⁹ indicates identifies the population of older persons is currently 26.2% in Babergh and 24.8% in Mid Suffolk., and cites that t The OAN projections indicate the population aged 65 or over is going to increase dramatically, by 57.8%,within the Ipswich Housing Market Area over the Plan period. by 57.8%.The Councils have recognised this need through the adopted²⁵ in the Ipswich Housing Market Area over the plan period. Joint Homes Strategy, in that the specific population forecasts for both districts show the increase in over 65s is 20% over 20 years. In addition to the predicted rise in the older population predicted to rise, it is also expected that a growing number of households will include one or more persons with a disability, and more households with will contain people living with long-term health conditions.

13.29 There is a Building Regulation standard in force relating to accessible dwellings, which sets standards in relation to accessible and adaptable dwellings (Part M4(2)) and wheelchair accessibility dwellings (Part M4(3)), which are over and above the minimum requirements²⁷. LPAs can apply these standards, by incorporating a requirement within their planning policies. The SHMA identifies that there will be an increase of people across the Districts during the Plan period.

13.30 13.16 The SHMA²⁰recognises that there is an increasing need for the provision of older people accommodation; 1,369 additional specialist units will be needed in Babergh by 2036 comprising of 1,125 sheltered housing, 106 enhanced sheltered housing, and 138 extra care housing units. There is also an additional requirement for registered care (nursing and residential care homes). The SHMA identifies (up to 2036) there will be a requirement forfrom 1,591 people in Babergh, which means an additional 572 registered care accommodation spaces will be required.over the plan period.

13.31 13.17 There is also a recognised trend within the SHMA²¹identifies thatincreasing need for the provision of older people accommodation; 1,005 additional specialist units will be needed in Mid Suffolk by 2036 comprising of 755 sheltered housing, 73 enhanced sheltered housing,and 176 extra care housing units. There is also an additional requirement for registered care (nursing and residential care homes). The SHMA identifies (up to 2036) there will be a requirement forfrom 1,670 people in Mid Suffolk, which means an additional 1,004 registered care accommodation spaces will be required.over the plan period.

13.32 13.18 It is also recognised that the numbers and type of specialised accommodation needed may depend on changes in patterns of demand and expectations it includes the following types of accommodation: residential institutions with care, including residential and nursing care homes; housing with care and support, including sheltered, enhanced sheltered or extra care housing; and, other housing identified for those with specific housing-related care or support needs, such as physical or sensory disabled people, people with learning difficulties, care leavers or people with mental health support needs. SCC are developing further accommodation typologies to respond to future care needs. It is considered suitable to plan towards this target currently with the knowledge that accommodation to be delivered should not be too prescriptive.

13.33 13.19 The requirements for sSupported and special needs housing will need to must comply with Building Regulations (M4 (2)) requirements.the technical housing standards, which is a national document that sets out the government's nationally described space standard²⁹ . This material consideration is also interlinked with design and amenity. Further local requirements regarding the link between spacing standards, design and amenity can be found in Policy - Design & Residential Amenity.

13.34 13.20 Opportunities should be taken to integrate older persons housing into the community, in order to address potential issues of isolation and to promote inclusivity. For example, older persons housing on sites that are well related to schools, community centres or other focal points can help to create integrated communities. The Suffolk Healthy Ageing Needs Assessment (2018) identifies tackling social isolation and loneliness as one if of its recommendations. There is a particular need for older and vulnerable people to have opportunities to access sustainable transport and modes of travel other than the car.

13.35 To achieve a greater mix of housing types, all developments of ten units or more or sites of 0.5ha or more residential units, will be expected to provide a mix of house types and sizes. The Council will expect applicants to relate needs to the SHMA and/or to an assessment of local need, where the methodology and scope for this is either adopted via a neighbourhood plan or agreed with the Council.

13.36 Neighbourhood Plans may wish to identify specific localised needs for certain types of dwellings where supported by evidence, gathered through a local housing needs assessment, which is supported by the Council. There are also other or complementary mechanisms in which communities can deliver the homes needed in the local community, for example, through the establishment of a Community Land Trust.

13.37 This policy applies to all sites and proposals which individually or as part of a wider or contiguous site, that could accommodate a level of development that would meet the needs of different housing groups.

13.38 The Strategic Housing Market Assessment (SHMA) - Part 1 and 2 (May 2017) and subsequent SHMA (2014-based Local Housing Need) evidence base updated data January 2019 is a joint evidence base document between Babergh DC, Mid Suffolk DC, Suffolk Coastal DC, Waveney DC (now East Suffolk) and Ipswich BC that (amongst other matters) provides the evidence to justify the need and requirement for affordable housing. Planning policy reflects the size, type and tenure of housing needed for different people in the community and affordable housing is an identified need within Babergh and Mid Suffolk Districts as required by Paragraph 61 of the NPPF.

13.39 The evidence and information within the strategic Housing Needs &Requirements Policy provides the local affordable housing need calculations setting out the mix and composition within the Babergh and Mid Suffolk Districts. The data identifies a total potential demand of 495 discount home ownership/starter homes dwellings in Babergh, and 430 discount home ownership/starter homes dwellings in Mid Suffolk. The provisions for discount home ownership and starter homes must not be made at the expense of shared ownership and social /affordable rent provision.

13.40 In exceptional circumstances³⁰, where proposals are not able to meet the requirements for affordable housing for viability reasons, and to ensure that development can still come forward and overall housing delivery is not compromised, the Council may agree to alter the requirements subject to this being demonstrated through a comprehensive viability assessment, to the Council's satisfaction. Before reducing the overall provision of affordable housing, the tenure and type of affordable housing should be first adjusted to secure viability and best meet the housing needs.

13.41 Local need for affordable housing may be identified through a local housing needs survey (LHNS)²²¹Developers are encouraged to work closely with the Council's Strategic Housing team at pre-application stage to ensure appropriate evidence is provided with any planning application.

13.42 Babergh and Mid SuffolkThe Councils will encourage new homes to be delivered through community-led housing vehicles such as Community Land Trusts (CLT's), co-operatives or co-housing groups, which address a local housing need. The Plan recognises that community-led development can be beneficial for local communities and may be an appropriate 'exception' to development outside settlement boundaries. on the edge of settlements or in the countryside. Proposals of any scale will need to demonstrate an appropriate mix which linkslinked to identified local needs, with such needs perhaps which can be identified via a local survey. A legitimate local community group can include a Parish Council or an appropriately constituted CLT.

New paragraph to be inserted after 13.42:

A Rural Exception Site which is proportionate in size to the adjacent settlement would normally be considered to be no greater than either 5% of the total number of built dwellings, or no greater than 1ha.

LP10 - Moorings, Marinas & Houseboats

Policy background and explanation

13.52 The Councils will work with partner agencies to identify suitable moorings to meet the needs identified in an up to date needs assessment. An area of the mooring is shown on the Policies Map at Pin Mill Chelmondiston, Woolverstone, Shotley and Fox's at Wherstead.

13.53 There is a need to protect the special landscape and ecological characteristics of these internationally important areas and as a result, Babergh District Council will need to prepare a project-level HRA, Construction Environment Management Plan (CEMP) and lighting design schemes to assess the likely impacts from development.

13.54 Water-based and associated land-based facilities of an appropriate scale will only be permitted on the Stour and Orwell estuaries where these are compatible with; landscape characteristics, biodiversity, agriculture, access and river safety constraints. A sustainable development approach will be of the utmost importance on both estuaries.

13.55 Many activities that take place in or over the marine plan area require a marine licence. Early consultation with the Marine Management Organisation is recommended for appropriate proposals.

13.56 The Self Bbuild and Custom Housebuilding Act 2015 requires LPAs to keep a register of people who are interested in building their own homes. NPPF (2021,pPara. 621) states that LPAs should plan for the needs of those wishing to build their own homes. The Councils haves set up a self-build register, to understand the level of interest and demand in plots for self-build / custom build across the Districts. As of April 2018, there were 164 people on the self-build register, all with a variety of land and locational requirements.

14.01 In the 2019 NPPF, chapter 6 'Building a strong, competitive economy' is clear when it sets out "Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development."

14.02 The purpose of this section is to provide a planning framework which;

1. Encourages the development of employment sites and other business growth, uses of the right type, in the right place. and encourage investment in skills and innovation in order to increase productivity.
2. Encourages inward investment to the Districts by supporting the delivery of infrastructure improvements that will support enable the continued growth of the Port of Felixstowe and strengthen the Districts' links to the Port of Felixstowe and the rest of the UK.
3. Supports the tourism sector as one of the key drivers of economic growth.
4. Provides sufficient flexibility to be responsive to changing behaviours, innovation and sectoral advancements to enable business to be competitive and improve productivity.

14.03 Alongside the major strategic employment sites located in the towns, Ipswich Fringe and along the transport corridors, the rural economy also plays a fundamentally important role in the prosperity of the Districts as a whole, and the vitality of local communities. Many of the rural employment sites have grown organically over time responding to changes in demand and will inevitably continue to change. The aim of the Plan is to provide a framework to effectively manage development requirements for employment land.

Replace paragraph 14.03 with the following paragraph:

The economic base of the Districts comprise a wide range of employment sites and units ranging from the large strategic employment sites to small sites, often occupied with small and medium sized enterprises (SMEs), located across the Districts and sometimes outside settlement boundaries. Many sites have grown organically over time responding to changes in demand and new opportunities. The aim of the Plan is to maintain a suitable diversity of employment sites to meet current and future economic needs in a sustainable way.

14.04 The policy on small scale employment and flexible working practices recognises the importance of micro and Small and Medium-sized Enterprises (SME) scale of businesses in the two districts, where their predominantly rural nature means it offers benefits such as where these can thrive in the home. It seeks to accommodate Micro and SME operators positively by making provision for small scale employment and flexible working practices in appropriate locations. The provision to enable remote working, in particular through telecommunications connectivity, will be addressed in the contributions, infrastructure and services policy.

Replace paragraph 14.04 with the following paragraph:

The Plan also provides flexibility to support small scale employment use and flexible working practices. The predominantly rural nature of the Districts means that there are many small scale businesses, often within agricultural complexes and also within residential curtilages in both the towns and the wider countryside. This is an important component of the Districts' economic sustainability and diversity. The purpose of the policy is to provide a consistent framework to enable such uses to be regularised where it is considered necessary and appropriate to do so.

14.05 The policy for ensuring an adequate supply of land and premises for economic growth aims to ensure that a continuous range and diversity of appropriate employment sites and premises are available throughout the plan period. The Councils consider that availability of employment opportunities - particularly in rural areas - is essential to maintain sustainable communities. The loss of individual premises or land in employment use in itself may not appear to be significant, but the cumulative loss of several such units can be damaging to the local economic resilience. The policy seeks to retain viable employment use on existing employment premises, but also enable other commercial uses, such as small scale retail, services and other facilities.

14.06 Overall, the Council expects that employment land and premises will remain in employment use throughout the plan period. Where a business is unable to make premises work viably, this does not mean that the premises is inherently unsuitable for employment use as an alternative operator or another business use may be able to operate successfully from the premises.

New paragraph to replace 14.06:

The Councils consider that maintaining economic opportunities, particularly in the countryside, is fundamental to ensuring the sustainability of communities. The loss of individual premises or land in employment use in itself may not be considered significant, however cumulatively ongoing loss can damage local economic resilience. Accordingly, the policy seeks to retain viable employment sites and premises. In circumstances when a business is unable to make a premises work viably, this does not mean that the premises is inherently unsuitable for employment use or other commercial or community activities. This policy is not applicable to sites in employment use allocated for other purposes within the development plan.

14.07 The policy aims to achieve a balance between ensuring there is sufficient choice in the employment land and premises market over the long term and being proportionate in the type and level of evidence required to support a change of use of small premises. Applications for alternative windfall uses on existing employment land therefore needs to be considered in accordance with this policy to ensure that a supply of suitable sites is retained.

14.08 On some sites it may be appropriate to undertake a "land swap" whereby employment land/premises can be redeveloped with another use and the employment uses can be developed elsewhere on a new site. This could be beneficial for businesses to provide modern premises, and it could be beneficial for local amenity if employment uses were relocated away from residential areas. Where a land swap is agreed, the Council will require demonstrable economic benefit to the locality in terms of retention and enhancement of economic opportunities.

Add new paragraph added before paragraph 14.09:

The Plan is aimed at supporting the viability and vitality of the town centres in Babergh and Mid Suffolk Districts with a sequential approach to supporting uses in the town centres.

14.09 The aim of the policy is to promote competitive town centre environments that provide customer choice and a town centre offer. It is also aimed at supporting the viability and vitality of town centres in the Babergh and Mid Suffolk districts. A threshold of 400m² has been set, to require an impact assessment for applications for retail and leisure development which is outside of town centres, or not in accordance with an up-to-date plan. The assessment should be proportionate to the scale and type of the proposal, and in accordance with the relevant national policies and guidance. To maintain and improve the vitality and viability of town centres a mix of uses will be supported.

14.10 In accordance with the NPPF a threshold of 2,500m2 has been set for requiring retail and leisure development outside of town centres, which are not in accordance with an up to date plan, to provide an impact assessment. The level of detail to be included in the impact assessment should be proportionate to the scale and type of proposal and should be agreed between the Council and applicant on a case-by-case basis. Furthermore, in dealing with such applications (regardless of its size) paragraph 86 and 87 of the NPPF states that Local Planning Authorities should apply a sequential test to focus main town centre uses in town centres, then in edge of centre locations and only if suitable sites are not available (or expected to become available within a reasonable period) should out of centre sites be considered. The primary frontages and town centre boundaries for Hadleigh, Stowmarket and Sudbury are set out in the relevant Policies Maps.

14.11 To maintain and improve the vitality and viability of the town centres a mix of uses will be supported whilst safeguarding retail uses. These types of uses could include but are not limited to: "above the shop" homes; leisure and cultural activity including support for evening economy and improvements to the public realm, such as tree planting and green infrastructure. Proposals that implement adaption measures to combat climate change will be encouraged.

14.12 The NPPF para 83. States the Local Plan should enable sustainable rural tourism and leisure developments which respect the character of the countryside.

14.13 The Plan seeks to provide a diverse range of facilities and accommodation across the District to support the leisure and tourism sectorscater for the tourist demand. Tourist accommodation, particularly that which is in permanent buildings, can sometimes come under pressure to be occupied for full time residential use. New touristm accommodation should will therefore be restricted by planning conditions and/or legal agreements so that it is retained for the benefit of the tourism economy and not lost to residential use. Planning conditions will also limit the occupation of new self-catering tourist accommodation units.to a continuous period of 28 days by one person or persons within one calendar year. The owners/operators of the accommodation will be required to maintain an up to-date Register of all lettings, which shall include the names and addresses of all those persons occupying the units during each letting. The Register will be required to be made available at all reasonable times to the Local Planning Authority.

14.14 Proposals to remove holiday occupancy must include appropriate evidence where it can be fully and satisfactorily to demonstrated that there is no demand for the tourist accommodation. The mMarketing evidence must be provided with details on of the following:

1. Wwhy the property is being marketed;
2. Tthe location, and links to transport networks and general setting;
3. Aadvertising methods - used to market the accommodation particulars should be set out in a bespoke, well-designed brochure with professional photos. Evidence of advertisements in both local and national publications/ online advertisement and/ or targeted mailing will be demonstrated;
4. Gguide price/rent; and
5. guide Tterms and conditions.

14.15 Proposals for leisure tourism and tourist accommodation development needs to consider all demonstrate consideration of the environmentally sensitive characteristics of the area both districts. This includes, but is not limited to: future proofing all development from the impact of climate change; protecting conserving and enhancing heritage assets, and their setting and protecting and enhancing biodiversity and geodiversity, as a result of development. Reference also needs to be made to the Councils' most recent Landscape Guidance and/or other relevant landscape guidance supporting Neighbourhood Plans.

15.01 The aim of this policy is to ensure that all developments are environmentally sustainable and will seek to prevent and mitigate against adverse environmental impacts and climate change, irrespective of the size of the development. Development proposals must take into account a broad range of environmental issues such as land and resources; land contamination and instability; pollution and environmental amenity; and water quality.

15.02 Land and air pollution are subject to regulatory controls under Environmental Health Legislation including the Environmental Protection Act 1990, Pollution Prevention Act 1999 and the Environment Acts of 1995 and 2021. Applications within an Air Quality Management Area (AQMA) and all major planning applications, may be required to submit an air quality impact assessment to assess and quantify the impact on local air quality and to identify appropriate mitigation measures to ensure that development is acceptable on the grounds of air quality. Contributions may also be required towards the cost of air quality mitigation measures.

15.03 Lighting needs to be appropriate for the design and scale of development and location. It is important that lighting is designed to illuminate the target only and not detract from the night sky's natural state and thereby avoid light pollution and its associated impact on wildlife.

15.07In accordance with Government guidance for land contamination and land stability, all planning decisions should give appropriate weight to any recommendations of regulators within the Councils and the Environment Agency. All measures must also be compatible with the relevant National and International Standards or any subsequent more recent legislation. Where appropriate potentially contaminated land should be investigated and remediated prior to development and/or during construction to a level appropriate to its proposed use. Where mitigation/remediation cannot be satisfactorily achieved, development will be refused.

All paragraphs 15.08 to 15.21 to be deleted and replaced with re-written and re-ordered new paragraphs below.

The NPPF advocates that local plans should contribute to, and enhance, the natural and local environment by protecting and enhancing sites of biodiversity or geological value and minimising impacts on and providing measurable net gains for biodiversity. Development should adhere to the Biodiversity Mitigation Hierarchy; Avoid, Mitigate or Compensate, as set out in paragraph 180(a) of the NPPF and Planning Practice Guidance (PPG) for the Natural Environment (para 19).

Protection for internationally and nationally protected sites is established in legislation. At an international and national level, this includes Special Protections Areas (SPAs), Special Areas of Conservation (SACs), Ramsar sites and Sites of Special Scientific Interest (SSSIs). Proposals that would result in significant effects on these sites, either alone or in combination with other plans and projects, should be refused, unless mitigation measures can be applied to avoid adverse effects on site integrity. Only in exceptional circumstances where a suitable compensation strategy exists and where there are 'imperative reasons of overriding public interest' would development that causes harm to a SPA, SAC or Ramsar sites be permitted.

Sites of Special Scientific Interest (SSSIs) are protected through the Wildlife and Countryside Act 1981 (as amended). The NPPF states that development on land within or outside of an SSSI likely to have an adverse effect on an SSSI should not normally be permitted. An exception should only be made where the public benefits of development clearly outweigh the impacts.

Priority species and habitats are identified by the UK post-2010 Biodiversity Framework. The NERC Act 2006 requires the Secretary of State to publish a list of habitats and species which are of principal importance for the conservation of biodiversity in England. Known as the Section 41 list, this should be used to guide decision makers in implementing their duty under Section 40 of the NERC Act to have regard to the conservation of biodiversity in England when carrying out their normal functions: England Biodiversity Strategy 2020, Biodiversity Net Gain initiative and the latest published version of the Natural England Biodiversity Metric are designed to assess changes to biodiversity value as a result of development or land changes and can be an essential method to ensure net gains are achieved.

In order to meet the biodiversity net gain initiative, development proposals will be required to meet a minimum of 10% increase or in line with Government requirements if greater.

At the local level, designations in Babergh and Mid Suffolk comprise of County Wildlife Sites, County Geodiversity Sites/Regionally Important Geological and Geomorphological Sites, Local Nature Reserves and Priority habitats and species. For the purposes of this policy, all of these are also designated sites.

Green infrastructure refers to a network of spaces and linkages that are generally valued for their wildlife, geological, landscape or historic importance and may also have recreational value and help reduce flood risk. Although often important in their own right, when considered as a holistic network they provide much greater benefits. Emphasising the importance of green infrastructure creation, protection conservation and enhancement, ensures an improved and healthy environment that is available for present and future communities. These improvements can include reducing vulnerability and increasing resilience to extreme weather events and flooding through measures such as SuDs and green roofs for example.

To create, protect and enhance ecological networks, the NPPF advises that biodiversity should be conserved and enhanced at a landscape-scale across local authority boundaries. The documents titled A Green Infrastructure Framework for Babergh District (2012) and the Haven Gateway Green Infrastructure Strategy for Ipswich Policy Area (2015), identify potential wildlife corridors (river and green corridors) that would benefit from enhancement. The Suffolk Nature Strategy identifies a large area of Babergh and the south of Mid Suffolk as 'South Suffolk ancient woodland clusters' which is one of the areas of principal importance for landscape-scale conservation in Suffolk, along with the two AONBs.

The Plan seeks to ensure that all new development secures high standards of design and green infrastructure which creates attractive and sustainable places where people want to live and spend time. Networks of green infrastructure should be provided across new developments linking with existing ecological networks.

Enhancement for biodiversity could include: watercourse improvements (such as along river corridors and undisturbed river banks) to benefit biodiversity and improve water quality, habitat creation, wildlife links (including as part of green or blue infrastructure) and building design which creates wildlife habitat (e.g. green roofs, hedgehog friendly fencing, bird, insect and/or bat boxes) relevant to local conservation priorities.

The Councils are also working on an emerging Green Infrastructure Strategy to support the Councils' adopted Biodiversity Action Plan. Furthermore, a Biodiversity Supplementary Planning Document will be produced.

15.23 Parts of Babergh lie within the designated landscapes of The Dedham Vale Area of Outstanding Natural Beauty (AONB) and the Suffolk Coast and Heaths AONB, however, all All landscape whether designated or not, has its own character, sense of place and local values. These include areas with uninterrupted or panoramic views of surrounding landscapes, landmarks and distinctive field patterns with associated hedges, woodlands and corpse of trees, as well as areas of tranquillity, dark skies and strong rural character.

15.24 Landscape character assessments of the area have been carried out and provide information on the different landscape character types of the area²⁷⁶. These assessments recognise particular characteristics, qualities and features of landscapes to provide an understanding of distinct sense of place and sensitivities to development and change. They will be used as a basis to guide decisions about whether development is appropriate in the landscape and provide a framework for the provision of appropriate landscape mitigation and enhancement.

New paragraph to be inserted after 15.24:
The Plan seeks developments to be sensitive to their landscape and visual amenity impacts; subject to siting, design, lighting, use of materials and colour, along with the associated mitigation measures.

15.25 Where development may beis visually prominent or is likely to adversely significantly affect landscape character, production of a Landscape and Visual Appraisal (LVA) or Landscape and Visual Impact Assessment (LVIA) (as appropriate), will be required.aThis should inform strategic landscape masterplans and/or a landscape management plans detailing mitigation proposals if required. may be required.

15.26 The Plan seeks to protect conserve and enhance the landscape, taking account of its natural beauty, characteristics and features of natural, archaeological or historic interest. All new development proposals need to ensure it they responds to and reinforces the local distinctiveness of the area in scale, form, design, materials and location. For example, by use of materials which complement the local individual landscape character, archaeological and historic patterns of settlement and land use and designations; being demonstrably informed by local guidance, in particular the Councils' Joint Landscape Guidance, the Suffolk Landscape Character Assessment and Settlement Sensitivity Assessment.

15.27 Babergh and Mid Suffolk have a diverse landscape character, with parts of Babergh lying within Dedham Vale AONB and the Suffolk Coast and Heaths AONB. Adjoining the Dedham Vale AONBA rea of Outstanding Natural Beautyis an area defined as the Stour Valley Project extending beyond Sudbury and into West Suffolk. The Suffolk Coast and Heaths AONB also has a project area which encompasses the Shotley Peninsula. These project areas, however, do not currently benefit from the same protection as an AONB. Whilst these project areas do not benefit from the same protection as the AONBs, development proposals in these areas should conserve their special qualities as identified in the Valued Landscape Assessments, and where relevant seek to deliver enhancements where the special qualities have been impacted by changes in farming practices or previous development.

15.28 The protection conservation of AONB's is not just the land within the designation, but also to includes its setting. In line with Tthe National Planning Policy Framework, great weight is given to conserving and enhancing the landscape and scenic beauty in the AONBs and the conservation and enhancement of wildlife and cultural heritage are important considerations.

New paragraph to be inserted after 15.28:

The Plan requires development to be sensitive to landscape character and visual amenity impacts. This could be achieved through the use of good built and landscape design, includingmaterials and colour, siting, design and lighting, along with the associated mitigation measures which complement the local individual landscape character, archaeological and historic patterns of the settlement.

15.29 Babergh and Mid Suffolk have a considerable wealth of historic settlements and buildings which contribute to the area's distinctiveness and make it an attractive place to live and work. The Planning (Listed Buildings and Conservation Areas) Act, 1990 contains statutory provisions relating to the management of the historic environment, however local authorities may develop policies through their local plans. The NPPF advocates that local plans should set out a positive approach to the conservation and enjoyment of the historic environment, including heritage assets most at risk.

15.30 Heritage Assets are defined by the NPPF as 'A building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest'. It includes nationally designated heritage assets, other non-designated heritage assets, Scheduled Monuments and sites of potential archaeological interest.

15.31 The designated heritage assets in Babergh and Mid Suffolk comprise of some 7,000 lListed bBuildings, 60 Conservation Areas, 72 Scheduled Ancient Monuments and 7 Registered Parks and Gardens. In addition, there are other buildings and features which make an important contribution to the character and appearance of the area. These may not be of sufficient quality to be designated as a heritage asset but are important in reinforcing a sense of local identify. An Historic Environment Record is maintained by SCC, which includes details of local archaeological sites and finds, historic buildings and historic landscapes.

New paragraph to be inserted after paragraph 15.31:
Where heritage assets of archaeological interests are likely to be affected, a conservation strategy, including details of recording, mitigation, repair preservation, protection and management, as appropriate, will be required.

15.32 Some designated heritage assets are known to be at risk through neglect and decay, or are vulnerable to becoming so. The authorities will continue to monitor Heritage at Risk and will work with Historic England and other bodies to secure appropriate solutions.

15.33 In exceptional circumstances, permission may be granted for development which would not normally be acceptable in order to secure the long-term future of the designated asset. This is known as 'enabling development' and should only be carried out as a last resort in line with the guidance produced by Historic England. In such circumstances, the Councils will assess whether the benefits of a proposal, which would otherwise conflict with planning policies, but would secure the future conservation of a heritage asset, outweighs the disbenefits of departing from plan policies.

15.34 Proposals which physically affect Scheduled Monuments require Scheduled Monument Consents in addition to any planning permission and/or lListed bBuilding cConsent required. Applications for Scheduled Monument Consents must be made to the Secretary of State for Digital, Culture, Media and Sport before any work may be carried out which might affect a monument either above or below ground level. Further information on the application process for Scheduled Monument Consent is available on Historic England's website²⁹⁹³⁰

15.35 Proposals to increase or extend residential garden land by the change in use of land can have a significant impact on the environment, especially when there is an impact on best and most versatile agricultural land or there are adverse effects on the landscape character and setting of the locality. The impact of such a change is likely to be unacceptable. Designated constraints, local guidance and supplementary planning documents will provide detailed information and guidance for assessing landscape impacts of such proposal.

15.36 The National Planning Policy Framework is clear economic diversification and a high-quality environment have to be pursued together. Both of which are mutually dependant and supportive and are the essence in achieving sustainable development. This also means diversification of the rural economy should not be at the expense of the environment or productive agricultural land or the best and most versatile land. Any proposals in relation to legislation associated or connected with the Department for Environment Food & Rural Affairs will be considered proportionately along with the consideration of positive approaches to manage land for agriculture, conservation or recreational purposes. Long-term sustainability of any proposal will need to be considered especially if the proposal is to develop agricultural land. It is often the case once land is developed the restoration of natural habitats or landscape enhancement features is expensive to create

15.37 The Local Planning Authority will not encourage new industrial development to intrude into the rural environment away from settlements. The operation of industrial development often requires necessary access to materials, support services, markets, clients and labour, which are often not available in rural locations without creating sustainability issues, intensification and cumulative impacts to the rural road/lane networks/highway. Proposals to change the use of agricultural land from existing redundant buildings to recreation, leisure or tourism-based activity may be suitable subject to proportionately balanced assessment of environmental harm and any other appropriate policies that may relevant to such proposal.

15.38 Proposed changes in use arising from the diversification of farm enterprises/businesses may be acceptable providing the proposal does not adversely impact on the social, environmental or economic aspects of the existing farm. In particular, the proposed diversification must not place unreasonable restrictions on the farm that could jeopardize its viability as a result of the development permitted after the farm was established. Equally any proposal must not detrimentally affect neighbouring amenity, proposals must be compatible with the protection of the countryside with regard to landscape, ecology, biodiversity, natural resources and intrinsic recreational value. The proposal must not unreasonably or unnecessary result in the loss of best and most versatile agricultural land or productive agricultural land, the proposal must not create excessive traffic intensification resulting in cumulative impacts or traffic safety issues.

15.39 The Local Planning Authority will expect the use of existing buildings to be considered in the first instance where proposals require the provision of new or more floor space. Any acceptable new buildings must be ancillary to and used solely in connection with the existing farm enterprises/business to meet the operational needs. Condition(s) may be necessary for the Local Planning Authority to apply.

New paragraphs to replace paragraphs 15.35 & paragraph 15.36:

Proposals for the use of land for equestrian uses or other similar animal land-based (non-agricultural hobby farming) uses should minimise the impact on the landscape and amenity through consideration of the re-use of existing buildings, the size, scale, design, materials and siting of any proposed building or equipment, the emissions to be generated, and integration with the landscape/area.

New paragraph to be inserted prior to Policy LP23 (now LP21 - Agricultural Land to Residential Garden Land):

Proposals to increase or extend residential garden land by the change of use of land are required to give consideration to their impact on landscape characteristics, biodiversity, amenity and appropriate mitigation of those impacts.

LP2422 - New New Agricultural/Rural Buildings in the Countryside:

15.40 The NPPF encourages and supports a prosperous rural economy and to ensure the natural environment is protected and enhanced.

15.41 The National Planning Policy Framework requires that new development can be integrated effectively with existing businesses. Proposals for new agricultural/commercial/business activity and facilities should not place unreasonable restrictions on existing agricultural/commercial/business as a result of the new proposal. Therefore, often to prevent conflicts of uses and impacts to existing agricultural business operation any agricultural diversification proposal must be ancillary/subsidiary component of the main farm enterprise/existing business operation and is to contribute to the continuing viability of the agricultural/rural business as a whole.

15.42 Suitably and sustainable located new buildings for where appropriate ancillary/subsidiary use in connection with existing agricultural/rural business may be favoured where it can be demonstrated that such uses would not create or cause significant levels of traffic, particularly lorries/HGV's on rural roads. The proposal must not adversely impact on character and landscape of the area, ecology and biodiversity; and must not have any significant impacts on any listed buildings, listed building settings, including any existing buildings that may be curtilage listed. All agricultural applications must include environmental protection measures, a Construction Environment Management Plan (CEMP) and demonstrate that relevant guidance for pollution prevention (GPPs - Netregs.org.uk) will be adhered to throughout the development.

15.43 Proposals must ensure the location, design and scale of the proposal does not have a significant adverse effect on the character and appearance of the locality; must not cause any significant amenity impacts; must avoid adverse effects to site integrity to Habitats Sites via reductions in air or water quality; and must not cause any conflict of uses through any impacts on existing rural commercial activity/business. All allocation sites must have a project level HRA if they are within the zone of influence of protected habitats sites. Where relevant, project level Habitat Regulation Assessments (HRA), CEMP (as stipulated above) and lighting design schemes for planning applications will be required.

15.44 It is recognised there has been an increase in intensified farming activity within rural areas, which has seen the increase of large commercial buildings within the countryside. Equally, it is also recognised there is a need to manage effectively agricultural related development within the countryside. To ensure the fine balance between ensuring a prosperous rural economy and ensuring the rural countryside character and environment is maintained, protected and enhanced. Not all locations in the countryside will be considered suitable or sustainable for new buildings and uses due to sustainability objectives of the Plan.

15.45 Proposals for new isolated, remote and detached buildings away from settlements and clustered development will be resisted. Unless it can be justified and evidenced in terms of sustainable development objectives of the Plan.

New paragraph to replace paragraphs 15.40 - 15.45:

The NPPF encourages and supports a prosperous rural economy, however it is necessary that proposals for agricultural buildings outside settlement boundaries can be integrated effectively with the landscape and surrounding context. This means considering the highway network capacity and suitability as well as a safe and suitable access.

15.46 The NPPF (2021, Para.148 152) states that the Plan should help shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience.

15.47 The NPPF advocates good design whilst optimising the potential of the site for the use of alternative heat and energy initiatives.

15.48 The Plan supports proposals for sustainable construction and design providing that development proposals are sympathetic to local character and history, including the visual impact upon the surrounding built environment and landscape setting.

15.50 Whilst the planning system has a role to play in delivering sustainability in buildings, construction methods and the energy performance of buildings are primarily addressed via Building Regulations. Nevertheless, the March 2015 Ministerial Statement enables local planning authorities to require energy efficiency standards that exceed Building Regulations provided these do not exceed the requirements of the Level 4 of the former Code for Sustainable Homes. This equates to around a 20% improvement in CO2 emissions performance above the Target Emission Rate of the 2013 Edition of the 2010 Building Regulations These have been updated to increase the reduction in CO₂ emissions to 30% for new dwellings and 27% for other new buildings, with further reviews of Building Regulations expected in coming years. Whilst noting the role that Building Regulations play in driving forward these reductions in carbon dioxide emissions, the policy seeks further reductions where possible.

15.51 The Plan expects and actively supports developers to explore innovative ways to cut CO2 emissions. This can include improving energy efficiency measures such as insulation, air tightness and efficient building layout, orientation and services.

15.52 Other technical standards to improve sustainability were introduced by the Government in October 2015 through the introduction of optional water efficiency Building Regulation standards. Both the Essex & Suffolk Water and Anglian Water areas are classified as experiencing 'serious' water stress (www.gov.uk/government/publications/water-stressed-areas-2013-classification ) therefore, the Plan responds to these changes by requiring improvements to water efficiency on new dwellings to achieve the higher water efficiency standard of 110 litres/person/day (compared to 125 litres/person/day under Building Regulations). To ensure this lower water usage can be delivered through Building Regulations, a planning condition will be applied to any planning permission for new dwellings.

15.53 The Anglian Water and Essex and Suffolk Water regions are particularly vulnerable to impacts of climate change including the potential reduction in summer rainfall,and lower available water resources,.tThese factors are all compounded with Eastern England identified as the driest region in the UK. Therefore, all new commercial development is expected to give due consideration to water efficiency along with new residential development for the reasons set out in NPPF. In order to future-proof against climate change the Plan will encourage all residential development to achieve 100ltrs per person per day and take advantage of the removal of the fixed element of the zonal charge levied by Anglian Water (at the time of writing - potential saving of up to £740 per plot).

Table 7 - Maximum Fittings Consumption Optional Requirement Level

15.56 Good design is a key aspect of sustainable development and has the potential to maintain and enhance existing environments. It can also have benefits in terms of the health of residents and community safety. The Plan provides a framework to promote high-quality, well-designed developments, and good quality housing. In order to achieve this aim, applicants should work collaboratively with the Councils at an early stage. In determining applications regard will be given to the 'Suffolk Design Guide for Residential Areas', and any other relevant local design codes and documents endorsed by the Councils, where appropriate. This also includes the principles of Suffolk Design and any supplementary planning documents.

15.57 In addition, dwellings built to adapt to and accommodate the needs of the occupier over their lifetime can facilitate choice, help meet the needs of an ageing population and improve quality of life. There is a Building Regulation standard in force relating to accessible dwellings, which sets standards in relation to accessible and adaptable dwellings (Part M4(2)) and wheelchair user dwellings (Part M4(3)), which are over and above the minimum requirements. LPAs can apply these standards, by incorporating a requirement within their planning policies. The SHMA identifies that there will be an increase of people with accessibility needs across the Districts during the Plan period.

15.58 The Plan seeks new dwellings to be designed to meet these needs using the Building for a Healthy Life Standard design assessment framework or other similar design standards or equivalent replacement standards considerations, as appropriate. The Councils consider that good practice in design principles would include active frontages/edges, permeability, strong street composition and connectivity. While specifically for the public realm, good visual design signatures would include signage, hard landscaping and public art. Appropriate long-term design principles and measures in terms of privacy and adequate facilities would include suitable bin storage (including recycling and re-use bins), secure cycle storage and garden space.

In order to address the needs of the ageing demographic in Babergh and Mid Suffolk, suchdesign standards should also take account of the need for buildings to address specific requirements, including dementia friendly accommodation, where considered appropriate. Dementia-Friendly Design Principles are set out in the RTPI guidance (2020). Key factors which would determine whether locations are appropriate include: good public transport links, close accessible services and facilities such as attractive nearby areas e.g. garden, park, courtyard, paved area and shopping centres.

15.59 The National Policy Framework (NPPF) proposes that "'the planning system should support the transition to a low carbon future in a changing climate'. Paragraph 1526 of the NPPF states that Local Planning Authorities should support community-led initiatives for renewable and low carbon energy

15.60 The policy on Energy Sources, Storage and Distribution is aimed at encouraging and facilitating the development of renewable and low carbon energy in the Babergh and Mid Suffolk Districts. This is in line with national policy stating that planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, as well as supporting the delivery of renewable and low carbon energy and associated infrastructure. This is central to the economic, social and environmental dimensions of sustainable development. The NPPF urges that Local Planning Authorities should recognise the responsibility of all communities to contribute to energy generation from renewable or low carbon sources.

15.61 The Plan supports proposals for renewable and low carbon energy development providing that any identified potential harm on Special Protection Areas, Special Areas of Conservation, Sites of Special Scientific Interest, AONB designations or Local Wildlife Designations can be effectively mitigated.

15.62 The Plan seeks to support proposals for low carbon energy systems especially where networks can be expanded to accommodate new and existing developments over time. Networks could include, for example, specifically designed Combined Heat and Power systems (CHP) linked to district heating networks or utilising existing waste heat from industrial uses/ existing power stations through a district heating network. These types of systems represent a particularly efficient use of energy and should be considered by developers in new proposals.

15.63 The potential for new standalone technologies has not been investigated within the twoDdistricts however, there may be interest in developing suitable schemes in the area. The Plan seeks to support proposals which are appropriate in scale, design and location.

15.65 As part of the Government's Water Abstraction Plan (2017), in May 2018, Suffolk was designated as a pilot catchment area for testing innovative approaches to reforming water abstraction. Suffolk's Holistic Management Approach links all aspects of water management to develop new ways of delivering flood alleviation, to provide more reliable water resources for all users and to improve water-based ecosystems and water quality.

15.70 Whilst neither of the Ddistricts have major flood risk areas there is a small section of estuary which is threatened by coastal erosion on the Shotley Peninsular and there are areas across both Ddistricts which suffer from localised flooding. Localised flooding is mainly a result of surface water flooding which has potential to be addressed through measures to improve drainage channels.

16.17 Infrastructure is defined on the in each Council's Infrastructure Funding Statement Community Infrastructure Levy (CIL) CIL Position Statements and the supporting Infrastructure Delivery Plan (IPD IDP). The provision of infrastructure is fundamental to maintaining quality of life, economic prosperity and the environmental assets of the dDistricts. The aim of this policy is to secure an appropriate level of infrastructure, including through developer contributions and planning obligations. Applicants will be expected to demonstrate that existing, planned and / or committed infrastructure is sufficient to accommodate development.

16.20 New development must provide for the educational needs of new residents. Educational needs include provision for early years, primary, secondary and post 16 education as well as Special Educational Needs. The NPPF (2021, pParagraph 94 95) sets out, that importance should be placed on the need to provide new school places. It also states that local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement, giving weight to the need to create, expand or alter schools. This involves both the expansion of existing schools where feasible, and identification of opportunities to create new schools. Further to the above, paragraph 104106 of the NPPF states that, in relation to education facilities, planning policies should minimise the number and length of journeys. Therefore, early years settings and schools will aim to be placed in the best possible location to promote sustainable modes of travel and enable good access.

16.21 The Councils have worked closely with SCC through the IDP to identify the educational requirements needed to accommodate growth in the Plan. The IDP highlights that in order to accommodate planned growth, a combination of school expansions and new schools will be required. The Councils will support the creation of well-designed new schools. The delivery of new schools and school expansions is important for the delivery of the Plan growth, and as such they are to be protected for that use. Similarly, with high demand for school places within the Districts it is important that existing educational facilities are offered a level of protection.

16.22 Similarly, the Councils haves worked closely with the relevant healthcare providers to establish the required health provision for the lifetime of the Plan. This includes meeting the needs of the identified ageing population in the Plan area., Wwhilst taking account of changing models of current and future healthcare provision,.iIt is assumed that the ongoing healthcare needs of the population will need to be met at a level deemed acceptable by the relevant healthcare providers, on a continuous basis.

New paragraph to be inserted after original 16.22

The policy also seeks to futureproof provision of healthcare and education facilities by ensuring that speculative windfall development proposals do not undermine the ability of existing facilities to expand in the future if required. The Councils will also engage in pre-application discussions with promoters to develop a collaborative approach to suitable applications and ensure that new facilities are placed in the best possible location to promote sustainable transport modes.

16.25 The Councils have Community Infrastructure Levy (CIL) in place. This means that some types of new development must make a payment which will be used to fund infrastructure required to support development in the each District. The amount of levy payable depends upon the size, type and location of the new development. A portion of CIL is also paid to the relevant Town and Parish Councils in which development takes places. However, CIL cannot be the single source of funding for infrastructure. This is because certain types of infrastructure (such as new primary schools) need to be delivered through section 106 planning obligations.

Affordable housing is defined in the National Planning Policy Framework (2019 2021) as: ...

...

An additional form of affordable housing introduced in 2021 was 'First Homes' (see further detail in this glossary).

Building for a Healthy Life

Building for a Healthy Life is the latest edition of - and new name for - Building for Life 12, a Government-endorsed toolfor assessing the design quality of neighbourhoods and homes, and the latest version is Building for Life 12. To achieve Built for Life accreditation, Design Code to help people improve the design of new and growing neighbourhoods. Uusing a traffic light approach,a development would be expected to achieve as many green lights as viable whilst reducing amber lights and avoiding red lights. must score 9 'greens' from a set of 12 questions The 12 considerations are split equally between three headings; which revolvearound 'integratedion into the neighbourhoods', 'creating adistinctive places' and 'streets for all and home '.

The Community Infrastructure Levy (CIL) was introduced in legislation in 2010 and enables planning authorities to set a 'levy' on new development in order to secure the infrastructure needed. Babergh and Mid Suffolk District Councils adopted CIL in 2016. The Charging Schedules set out the rate of CIL that will be charged for different types of development, dependeant upon location. The broad categories of infrastructure that CIL will be spent on are set out by the Councils in their Regulation 123 List Infrastructure Funding Statements.

Constable Country

An area straddling the Essex and Suffolk border, lying in the Dedham Vale AONB, that has strong connections with the artist John Constable. It includes the villages of Dedham, East Bergholt and Flatford.

The Development Plan comprises any Development Plan Documents that have been adopted in relation to the area.

The Development plan also includes adopted Minerals and Waste plans, which are produced by SCC. Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that decisions 'must be taken in accordance with the Development Plan unless material considerations indicate otherwise'. Once adopted, tThe Joint Local Plan Part 1, will form part of be the Development Plan for Babergh and Mid Suffolk, alongside 'made' Neighbourhood Plans and Saved Policies in adopted Development Plan Documents.

A Joint Local Plan Part 2 will be produced, which upon adoption will also form part of the Development Plan, and is likely to include the following matters:

•  Settlement hierarchy;
•  A spatial distribution for any housing allocations insofar as necessary to provide flexibility to ensure plan period housing requirements can be met;
•  Housing requirement figures for Neighbourhood Plan areas;
•  Settlement boundaries;
•  Open space designations;
• An assessment of Gypsy, Travellers and Travelling Showpeople needs, and if necessary, allocations to provide for these needs;
•  An assessment of Houseboat Dwellers' needs, and a relevant development management policy for houseboat dwellers, moorings and marinas; and
• Other matters which are considered necessary by the Councils, dependent upon the monitoring of the Plan and the circumstances at the time.

The Employment Land Needs Assessment (ELNA) was commissioned by Babergh and Mid Suffolk District Councils along with Ipswich Borough Council, Suffolk Coastal District Council and Waveney District Council (the latter two now known as East Suffolk Council) to define the Functional Economic Area and identify the qualitative and quantitative need for employment land across the Districts. The ELNA was based upon the 2015 East of England Forecasting Model jobs forecasts and was published in 2016.

Employment use is classified within the Use Classes Order, formally as class B2 and B8, as well as class E in the main, however employment is also generated from proposals within classes C1, F and Sui Generis. The temporary changes to the Use Classes Order are also included where relevant.

The Functional Economic Area is established in the Employment Land Needs Assessment. It is based upon analysis of travel to work areas, housing market areas and commercial property market areas. Babergh and Mid Suffolk sit within the Ipswich Functional Economic Area along with Ipswich and Suffolk Coastal (now part of East Suffolk).

Hazardous Sources

These include hazardous installations and pipelines, and when considering the proximity of development proposals to these, it is necessary to establish the consultation distance as set by the Health and Safety Executive (HSE).

A houseboat is defined for the purposes of VAT as being a floating decked structure which:

a) is designed or adapted for use solely as a place of permanent habitation;

b) does not have the means of, and which is not capable of being readily adapted for, self-propulsion.

Joint Corporate Strategic Plan

The Councils' Joint Strategic Plan was produced in 2013/14 and refreshed in 2016. The Joint Strategic Plan sets out a framework for delivering the Councils' services over the period 2016 - 2020. This document is now replaced by the Babergh and Mid Suffolk Corporate Plan 2019 - 2027.The Babergh and Mid Suffolk Corporate Plan 2019 - 2027 sets out the Councils' main priority areas, which are the economy, environment, housing, wellbeing, communities and customers.

Local Planning Authority (LPA)

As defined in the NPPF (2021): The public authority whose duty it is to carry out specific planning functions for a particular area.

As defined in the NPPF (20219): For housing, development where 10 or more homes will be

provided, or the site has an area of 0.5 hectares or more. For non-residential development

it means additional floorspace of 1,000m2 or more, or a site of 1 hectare or more, or as

otherwise provided in the Town and Country Planning (Development Management

Procedure) (England) Order 2015. Other than for the specific purposes of paragraphs 172176 and 173177 in this Framework.

The revised National Planning Policy Framework (NPPF) was published revised by the Department of Communities and Local Government ion February 2019 20 July 2021, replacing the previous NPPF published in March 2012, and revised in July 2018 and updated in February 2019. It is the key piece of national planning policy and is supported by guidance in the form of the Planning Practice Guidance. In considering whether a Local Plan is 'sound', through the Examination process, the Councils will need to be able to demonstrate that the plan accords with the policies within the NPPF.

Babergh, Ipswich, Mid Suffolk, Suffolk Coastal and Waveney Councils (the latter two are now East Suffolk Council) are taking a joined-up approach to facilitate development whilst at the same time adequately protect Habitats/European wildlife sites (European Sites) along the Suffolk Coast, from harm, mitigating the potential for significant effects arising from increased recreational disturbance related to new housing development. For Babergh and Mid Suffolk these relate to the Stour and Orwell river Estuary and Deben Estuary estuaries. The Councils have produced a Suffolk Coast Recreational dDisturbance Avoidance and Mitigation Strategy (RAMS) which identifies and cost the measures necessary to mitigate recreational and leisure impacts and confirm how they will be funded. The intention of the strategy is to avoid adverse effects on the integrity of the Habitats Sites in combination with other plans and projects, over the lifetime of the Plan.

Self-Build

The Self-Bbuild and Custom Housebuilding Act 2015 requires the authorities to keep a register of individuals and associations of individuals who are seeking to acquire serviced plots of land in the authority's area in order to build houses for those individuals to occupy as homes. Self-build is defined for the purposes of the Community Infrastructure Levy as as all homes built or commissioned by individuals or groups of individuals for their own use, either by building the home on their own or working with builders.

The settlement hierarchy categorises settlements based upon their role in terms of levels of service provision.

Starter Home -

Under The Housing and Planning aAct 2016 a Starter Home:

1. is a new dwelling,
2. is available for purchase by qualifying first-time buyers only,
3. is to be sold at a discount of at least 20% of the market value,
4. is to be sold for less than the price cap, and
5. is subject to any restrictions on sale or letting specified in regulations made by the Secretary of State.

The price cap outside of London is set at £250,000, and a qualifying first-time buyer must be at least 23 years old but under the age of 40.

The Housing White Paper (February 2017) includes a number of proposals in relation to Starter Homes including requiring households to have an income of less that £80,000, requiring some or all of the discount to be repaid if the home is sold within 15 years and including Starter Homes within the definition of affordable housing.

Wheelchair user accessible dwellings

Wheelchair user accessible dwellings were introduced by the Government through revisions to the Building Regulations in 2015, as one of a suite of 'optional' standards that can be required through planning policy. Part M4(3) of the Building Regulations sets out the specifications for wheelchair accessible dwellings.

A new Monitoring Framework is set out at the end of this Modifications Schedule document (page 83)

Town Centre Maps for Hadleigh, Sudbury and Stowmarket to be removed. Town Centre boundaries remain the same but now shown on the Policies Map and relevant Place insert maps.

New Appendix 04 - Schedule of JLP Policies is set out at the start of this Modifications Schedule document (page 1)