01.01
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 20804
Received: 30/11/2020
Respondent: Professor Robert Turner
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The JLP is not justified.
1 The District Council have produced a Plan what will no doubt please the men and women in Whitehall as one that has complied with the dictates of Central Government and will wash their hands in respect of the consequences that this Plan will have for the present and future generations of the rural communities of which this District is composed.
2 It will please the Developers who will not have to live with the damage which they will cause once they withdraw with no doubt a handsome profit.
3 But it will do nothing to enhance the lives of present and future inhabitants of the towns and villages of this part of Suffolk
No changes recommended
See attached full submission
Support
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 20810
Received: 14/12/2020
Respondent: Mr T Richardson
Agent: Wilson Wraight
Both Councils acknowledge the requirement to deliver the right type of homes, of the right tenure, in the right place, to meet housing targets set by Government and need arising from anticipated population growth. The key objective of the Plan - to secure suitable and sustainable development and provide the necessary infrastructure to enable our communities to thrive, grow, be healthy, active, and self-sufficient - is supported.
Both Councils acknowledge the requirement to deliver the right type of homes, of the right tenure, in the right place, to meet housing targets set by Government and need arising from anticipated population growth. The key objective of the Plan - to secure suitable and sustainable development and provide the necessary infrastructure to enable our communities to thrive, grow, be healthy, active, and self-sufficient - is supported.
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 20853
Received: 17/12/2020
Respondent: Mx Miles Row
Legally compliant? No
Sound? No
Duty to co-operate? No
As the 6th Carbon Budget report and National Audit Office show a rigorous approach is needed. Given the unknowns at the moment a more dynamic strategy is needed to last until 2037.
01.01 The Babergh and Mid Suffolk Joint Local Plan (hereafter referred to as 'the Plan') is an important document which will provide the strategy for the growth of Babergh and Mid Suffolk. It will set out the current strategy for development up to 2037, including land allocations. This strategy will be updated if it becomes clear that we are not on track to meet climate change commitments. Once adopted, the Plan will replace the existing local planning policies for both Babergh and Mid Suffolk.
As the 6th Carbon Budget report and National Audit Office show a rigorous approach is needed. Given the unknowns at the moment a more dynamic strategy is needed to last until 2037.
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 21124
Received: 23/12/2020
Respondent: Sudbury Area Green Belt Group
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We believe this is unsound, as it’s incomplete and unsustainable - reasons given.
Indicate whether the former “saved policies” will continue - such as seeking construction of a Sudbury By-Pass;
State intention to choose and evaluate a candidate site for a garden city, to relieve if possible our congested sprawling towns;
Clarity on mapping “links and stepping-stones between protected sites”, acknowledge need to prepare for “Nature Recovery Networks”, map “protected areas”, recognise importance of the Stour Valley Project Area;
Address the illogicality, that listing SHELAA sites, which haven’t been selected for “Land Allocation”, may confer a virtual guarantee of success in a planning application; A proper assessment of Land Allocations to meet NPPF para 171, for more accurate identification of environmental harm; and impacts on key features in The Landscape Character Assessments;
Recognise that new developments should help towns meet the ANGS standards;
Acknowledge which “Strategies” are unfit and need more than "updating";
Address flood risk, from building in Critical Drainage Areas.
We believe this is unsound, as it’s incomplete and unsustainable:
1) It doesn’t indicate whether the former “saved policies” will continue - such as seeking construction of a Sudbury By-Pass;
2) There is no definite intention to choose and evaluate a candidate site for a garden city, to relieve if possible our congested sprawling towns, this exercise is long overdue.
3) There’s no clear or definite information on a number of issues referred to in the 25-Year Plan for the Environment and other government reports:
i) No clarity on “links and stepping-stones between protected sites” or preparing for “Nature Recovery Networks”, no recognition of the call in the “Developing for the Future” White Paper, for mapping of “protected areas”, a failure to recognise the Stour Valley Project Area;
ii) the potential illogicality, that listing SHELAA sites (on the basis of a minimal 1-page desk-top study) which haven’t been selected for “Land Allocation”, may confer a virtual guarantee of success in a planning application. A process for deciding Land Allocations from amongst SHELAA development sites, which doesn’t meet NPPF para 171, since the identification of which sites would be the least environmentally harmful, is inaccurate and also ignores biodiversity. A failure to protect from impacts on key features in The Landscape Character Assessments - as with inflicting urban traffic on narrow roads in characteristic sunken/ hollow lanes.
iii) a failure to recognise that where a part of town doesn’t fulfil the Accessible Natural Green Space standards, adjoining new developments should be separated by a green strip eg averaging 30m width. “Strategies” which are merely a convenient inventory of the obvious, eg Babergh’s 2012 Green Infrastructure Strategy which has nothing representing progress, and a “green arc” (Fig 14.b) that is merely a vague afterthought.
iv) lip-service only to avoiding flood risk, eg a failure to recognise that the Surface Water Management Plan for Sudbury and Cornard was not written in the context of any future building on the valley floor and sides.
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 21379
Received: 24/12/2020
Respondent: Threadneedle Portfolio Services Limited
Agent: Turley
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Alongside representations to specific policies and reasoned justification contained within the Regulation 19 Document, we would respectively request that details contained in the appended statement be considered also.
As above and contained within the appended Representations to the Joint Local Plan Pre Submission (Regulation 19) Document, prepared by Turley.
Alongside representations to specific policies and reasoned justification contained within the Regulation 19 Document, we would respectively request that details contained in the appended statement be considered also.
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 21731
Received: 22/12/2020
Respondent: Cllr John Hinton
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The JLP is not effective, consistent with national policy or in compliance with Duty to Cooperate.
See attached full submission
See attached full submission
See attached full submission
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 21944
Received: 23/12/2020
Respondent: Brantham Parish Council
Legally compliant? No
Sound? No
Duty to co-operate? No
The JLP is not legally and procedurally compliant, positively prepared, justified, effective , consistent with national policy or in compliance with the Duty to Cooperate.
See full submission
We note that Policy CS10 has not been retained in full despite it being a core part of the Brantham growth to date.
Employment led regeneration at the Brantham Regeneration Area will be supported in principle.” this is not sufficiently strong in our opinion and we would like to see CS10 as a saved policy, in order to ensure that this Brownfield site is protected against being allocated exclusively to housing.
We would like to see CS10 as a saved policy, in order to ensure that this Brownfield site is protected against being allocated exclusively to housing.
See attached full submission
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 22033
Received: 23/12/2020
Respondent: Landbridge
Agent: Richard Brown Planning
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The JLP is not legally and procedurally compliant or sound.
See full submission.
The Plan is not considered sound because
a) The Housing Need considerations set out in section 4 clearly confirms that the identified housing requirement, that they are minimum figures
b) That delivery is not yet established by a robust evidence base whether with regard to existing commitments or proposed allocations
c) That windfalls should not be relied upon to meet the housing requirement
d) That sites should be allocated if they comprise sustainable development and
e) Attached as Appendix 4 is the Councils “note” circulated on the 7th December. Our response is attached as Appendix 5.
the Plan is not considered sound for the reasons stated.
To review all the proposed allocations in the light of evidence submitted with regard to deliverability and viability.
See attached full submission
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 22222
Received: 24/12/2020
Respondent: Ipswich Borough Council
Legally compliant? No
Sound? No
Duty to co-operate? No
Issues with how the impact from the extension 2037 for the plan period have been assessed.
The ISPA authorities have agreed through their statement of common ground (Iteration 6) to use a common base period (2018 - 2036) for their local plans. The JLP covers the period to 2037, however the joint ISPA evidence base which supports the plan only covers the period to 2036. Babergh and Mid Suffolk are out of step with the joint ISPA Statement of Common Ground and other ISPA authorities. Unclear how the JLP has reflected the common evidence base to project the growth estimates necessary to extend the plan period up to 2037.
See attachment for full submission.
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 22245
Received: 24/12/2020
Respondent: Ipswich Borough Council
Legally compliant? No
Sound? No
Duty to co-operate? No
Object - Non-compliance with the Regulations covering notification period.
Due to the specific timings of notification to Ipswich Borough Council, the BMSDC Regulation 19 consultation does not represent the full six-week notification period, as required by the regulations for statutory consultees, and as such the plan has not been prepared in accordance with the relevant legislation.
Timescale coincided with IBC Local Plan Hearings, an expected period of consultation would have been expected. IBC has allowed an 8-week period for SPDs. Appears no formal exhibitions or public engagement have been undertaken, no alternative online provisions were made.
See attachment for full submission.
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 22321
Received: 22/12/2020
Respondent: Save Our Country Spaces/SOCS
Legally compliant? No
Sound? No
Duty to co-operate? No
BMSDC are in breach of Government Guidance on consultations and as Such Fail their Duty to Cooperate and Statement of Community Invovement.
This failure could lead to a legal challenge as the process as organised is not fit for purpose.
A 12 week consultation should have been carried out.
Please see attachments for full representations.
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 22357
Received: 24/12/2020
Respondent: NJ Fiske
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Consultation on this whole Draft Plan during the Covid problems, the uncertainties of Brexit and over the year end and Christmas Season is so insensitive.. No Public Meetings are able to be convened at the moment. Therefore there is a strong case for an extension of the consultation period, which I and many others request.
Consultation on this whole Draft Plan during the Covid problems, the uncertainties of Brexit and over the year end and Christmas Season is so insensitive.. No Public Meetings are able to be convened at the moment. Therefore there is a strong case for an extension of the consultation period, which I and many others request.
See attached full submission
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 22358
Received: 23/12/2020
Respondent: Mrs LP Wheatley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Building houses in vast number on greenland is a pollutant.
The natural environment and humans cannot cope with increase in pollution.
Too many houses identified for Sproughton - all of these builds are on greenfield. The land will be destroyed.
A farmer miles away from anywhere who wants to build are faced with more restrictions than 2500 houses being built near Sproughton.
Job loses and no local employment opportunities results in all these new residents will have to commute to work.
Prediction is for increase in population there is also a prediction for a decrease.
Government states new build should be on brownfield sites.
Build more houses on brownfield sites so greenfields is preserved for food production and environmental benefits.
See attached full submission
Object
BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020
Representation ID: 22365
Received: 16/12/2020
Respondent: East Bergholt Parish Council
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We are concerned that the results of the extensive Sustainability Appraisal (SA) conducted over summer 2020 by LUC are also not reflected in this Plan, resulting in the adoption of a strategy which is not justified by the evidence base.
The SA also highlighted that the strategy will lead to increased car journeys and carbon emissions, which conflicts directly with the LA’s Climate Change objectives and policy stance. The SA also showed clearly that many of the site allocations in the Plan do not score well on sustainability criteria but have nevertheless been retained.
Without powers to allocate strategic transport funding there is an inability to deliver infrastructure required.
Review JLP against SA assessment and include Brexit and covid impact.
See attached full submission