01.01

Showing comments and forms 1 to 14 of 14

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

Representation:

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

Change suggested by respondent:

No changes recommended

Full text:

See attached full submission

Attachments:

Support

BMSDC Joint Local Plan - Pre-Submission Reg19 (interactive) 2020

Representation ID: 20810

Received: 14/12/2020

Respondent: Mr T Richardson

Agent: Wilson Wraight

Representation:

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.

Full text:

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

Representation:

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.

Change suggested by respondent:

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.

Full text:

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

Representation:

We believe this is unsound, as it’s incomplete and unsustainable - reasons given.

Change suggested by respondent:

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.

Full text:

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

Representation:

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.

Change suggested by respondent:

As above and contained within the appended Representations to the Joint Local Plan Pre Submission (Regulation 19) Document, prepared by Turley.

Full text:

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.

Attachments:

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

Representation:

The JLP is not effective, consistent with national policy or in compliance with Duty to Cooperate.
See attached full submission

Change suggested by respondent:

See attached full submission

Full text:

See attached full submission

Attachments:

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

Representation:

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.

Change suggested by respondent:

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.

Full text:

See attached full submission

Attachments:

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

Representation:

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.

Change suggested by respondent:

To review all the proposed allocations in the light of evidence submitted with regard to deliverability and viability.

Full text:

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

Representation:

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.

Full text:

See attachment for full submission.

Attachments:

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

Representation:

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.

Full text:

See attachment for full submission.

Attachments:

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

Representation:

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.

Change suggested by respondent:

A 12 week consultation should have been carried out.

Full text:

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

Representation:

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.

Change suggested by respondent:

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.

Full text:

See attached full submission

Attachments:

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

Representation:

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.

Change suggested by respondent:

Build more houses on brownfield sites so greenfields is preserved for food production and environmental benefits.

Full text:

See attached full submission

Attachments:

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

Representation:

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.

Change suggested by respondent:

Review JLP against SA assessment and include Brexit and covid impact.

Full text:

See attached full submission

Attachments: