Vision & Objectives

Babergh Peninsular strategic AONB Map - Dark green area (on uploaded AONB Map) should be considered for inclusion as AONB, this area already has numerous Public Footpaths, fantastic vistas, woodlands, wildlife, plants and insects

1. Your vision is certainly ambitious.
2. The only method by which your sustainable growth agenda can be achieved is to convert villages into dormitory communities with 43% of the working population working outside the area.
3. Those persons do not bring a benefit to the community but reduce its significance and importance: financial contribution is not spent in the community but in the outside areas.
4. If you intend to prioritise the infrastructure investment required to deliver the growth ambitions, then you have done nothing so far to improve infrastructures: public transport has been reduced, major traffic congestion is now critical, Park and Ride is withdrawn, reduced local services, and higher community charges have not improved the services you should provide.
5. What is the evidence based proof you have delivered employment and recreational growth and development.

735: VISION: Set against the NPPF requirements, this draft seems to perpetuate the historic situation in the district: where the economic and building issues are always set above the environmental and social issues, with the latter issues then dealt with in an ad hoc unplanned way, with 'lack of money' the most frequent excuse, and regardless of whether there is any cost.
FIRST: Quality of decision-making: The District sets the economic and building agenda, and the likelihood of individual parish councils having the knowledge or will to tackle this on a case by case basis, are slight (Sudbury Town Council proposed one minor amendment to the Chilton Woods Plan, but the District Councillor from Sudbury addressed the Planning Committee on 25/10/17 stating Sudbury Town Council were completely satisfied with the Plan and the consultation). In a meeting with the Babergh portfolio holder for Environment in May 2017, his advice was that public initiatives must be initiated via the parish / town council; the result was no discussion with a Babergh representative was possible, proposals became heavily filtered at parish level, where there is negligible awareness of national planning policy, and hence no direct accountability to the public; at the Planning Committee on 25/10/17 the chairman made denigrating comments on each submission by councillors or objectors, which questioned aspects of the application. (all objections referred to here were in keeping with the NPPF and not intended to impede the overall development). SECOND: Experience is of green elements interior to new developments, but with no benefit to the existing town, and this issue is not apparently accepted in consultations; so that 'growth is good' irrespective (Chilton Woods, at 3km broad from west to east, seals off the populated part of Sudbury from the countryside, and indeed from any open space; and all the 'green areas' are intended to be on the far perimeter; this was not considered by Babergh to be a concern.
HEALTHY COMMUNITIES & INFRASTRUCTURE: The items under this heading are welcome in outline, if broad to the point of wooliness. It seems unfortunate that only one of the items is precisely mentioned, that of a Relief Road / By-Pass; it cannot be right that the district has commissioned reports like a 'business case' but has never requested an overall presentation or appraisal of the variety of viewpoints on the topic (except the Mouchel Report 2002, which with recent traffic surveys, seems to have been 'buried') and it is notable that by adopting the proposal into its core strategy, the district has placed it beyond consultation, yet its mention in this section calls into question the 'community' sentiments of the rest of the section. The current by-pass business case concentrates on numerous development zones and regional strategies, in both Essex and Suffolk, which surely would increase traffic in the area; but no press statements have informed the public of issues other than relief of town centre traffic (the business case in referring to the latter admits the net change may be minimal, if less lorry congestion attracts more car visits). This section is where a 'vision For Sudbury' is mentioned, and yet that exercise is now called by Babergh "Vision for Prosperity" and its agenda has been stated by the key Babergh Officer as Growth and Expansion as the route to prosperity; we see nothing in this draft local plan to hint at how future consideration could be given to, for example, pedestrianisation of the town centre, provision for pedestrians and cyclists, circulating buses; this is worrying for the heart of the Stour AONB & Project Area; also we want to see growth in housing tied more to growth in local jobs than national needs of commuters; and there is no acknowledgement that the Western Relief Road project as a Regional Route (see current business case) would apparently require provision for the impact of new housing and the proposed township the size of Great Cornard around Middeleton and Bulmer. When will the councils share detailed WRRoad data and cost-benefit calculations; or strategic validation of the WRR against other options [e.g. revival the c1970 plan for a bridge south of Great Cornard]? We PROTEST at the relief road being closed to consultation, when the current business case indicates such major new unforeseen effects on Sudbury. WE URGE: the formulation of a green strategy for Sudbury area, with close consultation, exhibition and public concensus, perhaps as part of the 'Vision for Prosperity'. We make objections to sites that are the five most precious scenes round Sudbury and Cornard threatened by development: West of Tesco * (part of SS1028); plot north of Woodhall Moat (part of SS1028); Land around Health Centre (SS0933 and SS0590); South of Davidson Close Great Cornard * (SS0220); Tye Farm Great Cornard * (SS0242); the 3 sites marked * could presumably be saved by minor change without reducing amount of development. Brownfield and empty plots are available for the other 2.

The environmental importance of the AONBs is acknowledged but not emphasised. Perhaps you are relying on other authorities to look after the issues involved. I believe that environmental considerations should be high priorities in Babergh.

See attachment

Environment should include wildlife corridor protection.
Within the economy, for rural areas particularly, emphasis on encouraging employment and retail would help to offset the dormitory nature of some hinterland villages.

The vision should highlight, more prominently, a more sustainable future for the area through a strategy that minimises the need to travel by car and promotes movement by walking, cycling and public transport. Connectivity and accessibility for all should be a key feature.

We agree with this.

We agree.

We need to attract employers to ensure employment for all the housing estates which are being built. Also ensure the correct housing in is in the right place but I don't see large housing estates necessarily fulfil that objective

The Commission does not have the resources to respond to all consultations, but will respond to consultations where it considers they raise issues of strategic importance.
Local, parish and town councils and other public authorities, as well as organisations exercising public functions, have obligations under the Public Sector Equality Duty (PSED) in the Equality Act 2010 to consider the effect of their policies and decisions on people sharing particular protected characteristics. The PSED is an on-going legal requirement and must be complied with as part of the planning process. The Commission is the regulator for the PSED and the Planning Inspectorate is also subject to it. In essence, you must consider the potential for planning proposals to have an impact on equality for different groups of people. To assist, you will find our technical guidance here :
https://www.equalityhumanrights.com/en/publication-download/technical-guidance-public-sector-equality-duty-england

This vision statement is notable for its lack of ambition. The timescale for the "vision" propounded in this document is 20 years. Apart from the objective of building more houses, there is little in the vision statement that demonstrates any innovative thinking on key issues in proposed policy addressing the economy, environment and infrastructure. It could be summed up as saying, "carry on as before, but just with more houses".
A policy which aims and claims to influence the lives of our people for the next 20 years needs to be more than a reaction to central government pressure to build.

Housing

There is little in the policy to ensure that a wider range of housing is provided. With the continuing reliance on windfall sites, it is likely that developers will build what generates the maximum profit for them, rather than what the community needs or can afford.

Economy

Where is the strategy for generating quality employment opportunities? Mid Suffolk acknowledges its poor record of new business creation. One can only hope that under the duty to cooperate, partner organisations will come forward with the strategic vision that this document lacks. Given the technological changes that are predicted over the next 20 years, to focus solely on identifying land for relatively low grade business activity is a missed opportunity to create employment of a quality and salary level which might enable people to afford the houses being built. MSDC should learn from Cambridge as an example of good practice in economic transformation.

Environment

The document fails to properly address the key environmental issues facing the two districts. The options for comment provide limited environmental protection policies or "do nothing." There is little or no attempt to use the development process to tackle environmental issues or enhance environmental assets. The document needs to adopt more innovative approaches to using the development process to address environmental degradation and enhance the quality of the environment. For example the Suffolk Nature Strategy is referred to as Key Evidence but there are no proposals for taking forward the recommendations of SNS.

Mid Suffolk really does need to produce a green infrastructure strategy as a matter of urgency. Green infrastructure is not dealt with adequately in the consultation, in particular it needs to be addressed in the Biodiversity section, at the moment it is all sport/play based and does not consider a wildlife enhancement role. The contribution new development must make to new green infrastructure including its contribution to conserving and enhancing biodiversity needs to be included in the Biodiversity Section and policies. The emerging Habitats Regulation Assessment Disturbance and Avoidance and Mitigation Strategy being produced by Babergh and others needs to cover Mid Suffolk too.

Infrastructure

Firm objectives and outcomes are only proposed for Sudbury and Stowmarket - in the form of a vision and a relief road. Mid Suffolk faces a number of entrenched infrastructure issues - an inadequate secondary road network; poor broadband and mobile phone coverage; the absence of mains gas and sewage in many villages. Many villages are still reliant on oil for heating, with the environmental damage associated with the delivery and burning of oil.
The approach seems to be to build houses everywhere, with a heavy reliance on windfall sites, and let the infrastructure catch up as and when. The policy needs to include an explicit statement on taking into account the cumulative effect on existing infrastructure of small piecemeal developments.

See attached

We agree with the vision.We would urge the usage of Brown Field Sites and Redundant Buildings in order to save productive land and green spaces. Housing required is low cost , small and affordable houses.

It is essential that new housing is not only in the right place, but has the right infrastructure and facilities in place when development is occupied - infrastructure (doctors, public transport, schools, etc) in many core villages is already stretched or inadequate.

I would like the plan to be aimed at improving the quality of life for all; including not just those joining the planned developments, but also those currently living and working in the district. I would not like to see development permitted when it disadvantage those already established in locations where impacts from the proposed development would be negative. For example, those in Sproughton find that their village is being considered less as a residential area and more as a transport corridor. Whilst new developments surrounding Sproughton can be designed to avoid any internal through traffic, each has added to the traffic volumes through Sproughton. The cumulative effect of each development permitted is significantly diminishing the amenity of the village. For the plan to avoid realising such a worsening outlook, the transport infrastructure needs extending so that existing and future traffic movements can be accommodated, and routes which avoid existing residential centres are made available. The Local Plan is not complete whilst the transport infrastructure needed for its fulfilment, and the means of its provision, remains unassessed and unspecified.

The plan needs to have a vision statement and this is currently lacking. The objectives could be used to inform the vision statement.

I agree with the objectives set out, but they are rather vague and need to be more specific and measurable so that progress against them can be quantified.I would like to see a commitment to support and improve rural public transport, to minimise the effects of pollution (noise, light and air) caused y new development, and to provide support for local groups to enhance communities.
I feel the council should have crime prevention as an objective part of the strategy to address this pro actively to prevent an increase associated with higher population.

Whilst Babergh District Council Planning continue to openly refuse to take on board objections made to a development application by local residents, and Parish Councils, instead choose to 'know it all' and plough on regardless, rather than address real issues, the only conclusion can be that visions of a nineteen thirties Germany will still persist.
Even the high Court have commented upon BDC Planning not adhering to Publically Stated Policy. Hip Hip Horay for East Bergholt.

I wonder if BDC will actually bother to follow this public consultation plan, especially with regards to planning permissions, and not waste our public money on court cases defending the indefensible?
That would be a refreshing change in itself. The planning department should realise THEY, are paid PUBLIC money, to serve US.
I wonder how many of us have been suffered service cut backs, whilst lawyers, Large Landowners etc. are made richer, against the actual NEEDS of a local area.?

1. Traffic we are already almost at total gridlock in Sudbury at certain times of the day
2. Why despoil the beautiful natural area round Sudbury and Gt Cornard; Wildlife in this area is varied and special we do not want it destroyed; Children need outdoor open space to grow, learn and play
3. The local infrastructure can't deal with the population as it is let alone all the extra people the plan would bring in.

Housing. It should be a stated aim to provide most of the new housing as council housing in the towns. This is the best way to ensure affordability and to allocate it to local people.
The cycle of new housing, leading to more people, leading to a demand for more employment, leading to the influx of more people, is not sustainable.
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Sudbury Western Relief Road. This proposal conflicts with the environmental and healthy communities aims and with the duty to cooperate on conserving and enhancing the natural and historic environment including landscape. The proposal should be deleted. Previous studies have shown that it would have a minimal effect on reducing congestion and pollution in central Sudbury, that the environmental damage to the historic Stour Valley would be unacceptable, and that alternative measures are available.

Healthy communities and infrastructure. We should encourage walking and cycling by providing far more dedicated routes. Our villages must be protected from disruption by large and unwelcome new housing estates. We should provide more accessible green spaces at the heart of our communities.

At this point the Local Plan seems lacking a statement of vision . The council needs to think about what that vision might be. From a Beyton point of view the vision should be to secure the best quality of life possible for everybody residing within the village, and to encourage the village to prosper by maintaining and enhancing the local environment, providing high quality housing for all, supporting the local economy and village culture, and enabling the whole village community to be involved in supporting this success.

The documents indicate that the villages of Claydon and Barham will double in size if all the suggested residential developments progress. The infrastructure of the villages is insufficient to support this. Roads are already congested and the schools are full. Building around the existing villages will adversely effect recreational activities such as walking and cycling. The buffer zone between Ipswich and Claydon needs to be retained to stop the villages being swallowed up by Ipswich.

I do not see a vision being articulated here, rather a statement about 4 areas which need to be managed. A vision should be both inspiring and attainable and yet build on the lessons of the past. My vision is to 'engage and empower local communities to preserve and improve their environment and by so doing enrich their quality of life.' Please ban the word 'sustainable', the most abused word in planning circles, usually found next to a noun like 'development' to make the latter sound virtuous.

Many years ago I walked down a rough tarmacked track on the side of a high hill with far reaching views. I was in South Africa looking for something. Eventually I found the engraved stone neglected in the high grass of an overgrown island in the middle of the track. Cetshwayo, the King of the Zulu's who arguably gave the British army the biggest bloody nose it ever had fighting a tribal nation.
I was surrounded by a housing estate.
Vision is not just facilitating the building of houses, its building them in the right places and it is saving and respecting the best of our nature, landscape and history in the way our great grandchildren will have wanted us to.
There is a lot of space to build houses, but the jewels of our county only exist where they stand, their surroundings are just as important, and our decedents will not forgive us for ignoring that.
Regulations will ensure quality houses are built, market conditions will regulate the rate commercial enterprises built houses are built. But although government cannot force a developer to build one single house councils can start building again, which is the real problem because council building has declined.
True vision should be about 100 years not 5 years.

We agree with the following objectives:

- To contribute to the delivery of the vision and priority areas the New Joint Local Plan will set out an ambitious yet sustainable growth agenda which will prioritise the infrastructure investment required ...

- To encourage inward investment ...

- To enable provision of the necessary infrastructure to support residents, businesses, communities, the environment and individuals"

- To prioritise investment in strategic services and infrastructure, improving connectivity and service provision

- To work with the communities of Sudbury in the development of a vision and strategy for both towns"

BUT we disagree that the development of proposals for a Sudbury Western Relief Road project can support the objectives set out in the plan..

We propose the development of a Sudbury Area Roads Plan including a bridge near Great Cornard to take away all HGVs and other traffic passing through the town to Ballingdon Bridge.


Consultation Questions:

Q 1. What do you think the vision should be?
The historic town of Sudbury revitalised at the heart of prosperous community to the east and the Stour Valley area of natural beauty to the south and west.

Q 2. Do you agree with the identified objectives? Please explain reasoning.
Yes and no. A Sudbury Road project to realise this Q 1 vision must replace the Sudbury Western Relief Road project. Its aims are to take all HGVa and as many other vehicles as possible away from the town centre. The main elements of this proposal, subject to the recommendations of highway engineers charged with planning roads for the Sudbury area, are :

- a "designer" bridge over the railway and Stour south of Great Cornard.
- a road from the A134 Sudbury to the bridge (e.g. an extension of Shawlands Avenue)
- and/or a road linking the bridge to Valley Road to Great Waldingfield at its junction with the A134 and a new road to future developments beyond Chilton Woods
- a road from the bridge to the A131 near Bulmer Tye.
- a road from the bridge to the A1071 at its junction with the A134 to connect Ipswich and Hadleigh in South Suffolk to Halstead and Braintree in North Essex.

Q 3. Are there other objectives which should be added?
- Sudbury town centre to be a pedestrian area, as proposed by Mouchel in 2002.
- Extension of the Stour Valley AONB to Foxearth and beyond.

Q 4. What should be a priority across the Sudbury area?
- To attract business and investment.

Q 5. What is most important for Sudbury?
- A clear infrasture plan and a bold objective as the basis for a revival of the town.

Note
The attachment sets out the need for an alternative to the Sudbury Western Relief Road. To support the case it proposes an update to the 1970s plan for a bridge at Great Cornard and adoption of Mouchel 2002 proposal to make the centre of Sudbury a pedestrian area. It recommends that planners and highway engineers outline a Sudbury Area Roads Plan as a matter of urgency.

This just seems to be geared to policy decisions that have already been made, citing values that support those decisions.
I would imagine that all the Villages will be concerned over the social effects on their communities, with an influx of commuters, the effects of both atmospheric and noise pollution and the adverse impacts on local wildlife.
Healthy Communities and Infrastructure needs to come first. We need a policy which limits the housing development in an area to that supported by its infrastructure (or clearly defined enhancements) and which does not materially change its character.

This is a significant over development of Sproughton which currently has around 581 dwellings - this would be an increase of 397% in parish size. It is completely disproportionate and would result in Bramford joining with Sproughton and Sproughton being absorbed by Ipswich. Not so much 'creeping coalescence' as 'complete digestion'. A much fairer basis for development would be a pro-rated approach with some tweaking for those settlements that are very small in size.

9th November 2017



Draft Joint Local Plan Response


I have already made some responses on the on-line consultation. This set of comments is an attempt to say what I think is important rather than be 'tramlined' down a set of prepared questions.

In the past people, in the main, people lived in a settlement and worked there or near by; sustainable modes of transport (before the internal combustion engine) were used. In the present day planners and politicians invoke the sustainability of such arrangements and extol the virtues of people living in urban centres, where most jobs are, along with appropriate services and infrastructure. This should be the starting point for Babergh's strategy on housing.

Babergh's planning documents talk about the importance of:- addressing climate change, having access to services, using sustainable forms of transport. It is quite clear that if you want to achieve these things then people have to live in or close to jobs and service centres. It therefore makes sense for most of any new housing development to be located in and around the towns and largest villages.

There seems to be an urban bias in much of what goes on in planning i.e what is good for urban areas can be applied to the rural areas. I disagree with this. The main points I want to make are as follows:-

1. Most new housing should be in the towns and large villages (up to 80%). All new development should be accompanied by adequate resources to enhance services, facilities and infrastructure. The people affected are likely to be less hostile if they get something back. People are also warmer to the establishment of an entirely new settlement (as long as it's not near them) because infrastructure and services will be planned in and , as it is new, everything should be fit for purpose.
2. Small villages and hamlets should be seen as entities which are happy in their own skin. They do not need to be turned into commuter or dormitory villages. Their size goes with their character and their lack of facilities is their appeal. They are there to live alongside the countryside not to challenge or dominate it. Having no paved footpaths or street lighting is part of why we live here! More houses will create a demand for these comforting signs of 'civilisation' and destroy what we have. Planners and politicians do not appreciate the delicate ecosystem which our smallest settlements present and which residents value. Shouldn't the views of existing residents have some weighting here? please
3. In the village in which I live, Shimpling, I take issue with the desktop exercise which redrew the village boundary. This failed to recognise that the meadow (casually now included inside the BUAB) was the subject of some discussion last year when planning was allowed next to it. There is now a TPO on a splendid oak tree in this meadow which is a precious green asset. Would you now put the BUAB line back where it was please?
4. I support the downgrading of Shimpling from hinterland village to hamlets and countryside. This, at least, is a better recognition of the fact that it is, a non-sustainable village. This surely should offer it some protections against the development applications which are currently in danger of swamping us? If we go back to 'sustainability' being the key criterion for all things planning related, then the non sustainable villages should be exempt from development.
Economic need should be the only exceptional criterion on deciding on development in unsustainable settlements like Shimpling. If there is a need for a person to live in the village as part of his/her job, then that should be a consideration in the planning process.
5. The Authority should offer support to non sustainable villages like Shimpling so that they can counter the large number of planning applications which simply swamp our resources. Producing a neighbourhood plan is not the way to go for these small settlements but we need some mechanism to enable us to be more proactive. We feel abandoned by the local authority.
6. By suggesting that neighbourhood plans are the only partial defence against inappropriate development, the Authority is neglecting those villages like Shimpling which need another route. As part of its new plan Babergh must recognise the different needs and identity of the small rural settlements.
7. Current planning rules give even more power to speculators, developers and landowners. Villages like Shimpling simply do not have the resources to compete when it comes to challenging inappropriate development. The local authority seems to have no interest in our plight where the few can dictate to the many. If there is any local democracy out there we don't see it in action. Villages like this surrounded by farmland are 'easy pickings' for those who want to 'release land' for building purposes.
8. We need the local authority to take a firmer line in speaking up for the rural areas, their distinctiveness in terms of landscape and heritage qualities and the importance of small being beautiful. The draft local plan is (necessarily, I concede) statistical and functional, but where is there an inflection to beauty, quality of life and the health related benefits of walking along lanes and ditches and having sweeping views? When you have crunched every bit of data and tarmaced as much open space as you can what are you left with?


H Colin Johnston