Duty to Cooperate

This system isn't fit for purpose, eg on Environmental Protection two partners are elitist because they do not consult locally, and also lack local knowledge: Historic England and Natural England. Both are well known to be too understaffed to fulfil their role, and I have seen the latter state it can respond only in limited cases; we are writing to the Parliamentary Environmental Audit Committee, proposing Natural England should be able to delegate this function to other local bodies, for instance, the wildlife trusts. I've asked NE for an example of their standards ie ANGST being adopted by a local authority, they admitted they could give no example. I received this reply: "On your question as to whether any LPAs have sought to formally or fully implement the ANGSt in their Local Plans, I'll look into this with colleagues and get back to you as soon as I can.
Jack Haynes
Lead Adviser
Norfolk & Suffolk Area Team
Natural England
Dragonfly House, 2 Gilders Way, Norwich, NR3 1UB Tel: 0208 02 64857 Mob: 07825 856174" - in a subsequent phone call, Jack Haynes admitted he could find no example.
Given the statement in Natural England's Green Infrastructure web pages, that 'Greenspace often forms corridors or narrow, afterthought type places - 'spaces left over after planning' - it is remarkable that despite consultation with Natural England, the Chilton Woods plan commits exactly that error.
Para 73 of the NPPF requires that "Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision. The assessments should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area. Information gained from the assessments should be used to determine what open space, sports and recreational provision is required". Yet locally, it is clear the populated part of Sudbury has no more open space than tiny fragments, yet Babergh District Council doesn't intend to remedy this: The Chilton Woods application was been approved on 25/10/17 without saving any of the space within reach of town; on 26/9/17 Peter Garrett of Babergh wrote about that locality that "Babergh does not have the resources to purchase land directly for open space provision" and implied that new work on the Open Space Assessment would not look at the land there which is owned by the County Council, whose officer Brian Prettyman wrote to me that "some development is likely" ie building.

Proportionate development.
Consideration of all developments on current and potential road congestion.

If the Council invests in upgrading the infrastructure along with new housing provision the plan should be successful.

It is not acceptable to expect Babergh to pick up all or the majority of the 4000 houses expected to be built by Ipswich due to its land short fall. All surrounding areas need to be considered and if all areas agreed to the national expectation of 10% growth in villages/towns then the spread would be much more even, acceptable and the impact would be much less than a huge development would cause in 1 area.

Whilst under the Localism Act 2011, BDC may feel compelled to be bullied by the concrete jungle living, unnatural whims of people who care NOTHING for long term stability (ie politicians ). The key word is SUSTAINABLE. Let the authorities build the infrastructure, and support existing population, rather than cutting back on services. ONLY at this point would 'sustainable' be relevant.
South Ipswich, with its unique environment, wildlife, flood plains etc. should be eternally preserved as is. Without trees, bees, EVERYTHING dies, including US. So much for 'progress'.

Building the right type of housing in the right place to meet the identified need is quite right. However what is happening is a travesty of this objective with increasing numbers of "executive" type homes with little attention to smaller units for youngsters starting out or the elderly downsizing. Currently "affordable" homes are "anything but affordable" for the majority of Babergh residents. The environmental objectives need to be matched by appropriate actions and should include greater detail. Why are we seeing a lag between development and infrastructure? Furthermore, housing developments need to be built only in appropriate sustainable locations.

The JLP duty to cooperate is seen solely in the context of section 110 of the Localism Act and part 2 of the Town & Country Planning Regulations 2012. The framework of the JLP seems to cherry pick the NPPF and to ignore the letter of that document but also the spirit of a bottom up process based on local involvement at the community level.
It is not clear where authority is derived to ignore the NPPF as a whole document. Many important sections within the JLP commence with a reference to paragraph 156 of the NPPF and this leapfrogs over the need to; 'reflect the vision and aspirations of local communities' (para 150), 'be consistent with the principles and policies set out in this Framework' (para 151), 'Early and meaningful engagement and collaborations with neighbourhoods' (para 155). By starting at 156 the need to engage and involve local communities is not fully addressed. The present process of consultation is not a substitute for proper engagement

The framework of the JLP is to cherry pick the NPPF and to ignore not only the letter of that document but also its spirit of a bottom up process based on local involvement at the community level.
See our submission for a fuller critique

This is going to be a national requirement along with transparency and publication of progress so it needs to be addressed and the council appears to have a grip on that issue. However although not part of the specific requirement there are also requirements to cooperate and communicate at Parish/Town council and community levels but consultation rarely takes place until statutory consultee stages are reached.

As a layman, I found this section of the Joint Local Plan impossible to understand or comment upon.

* Ipswich say they have insufficient land to meet their projected housing numbers which means under the 'Duty to Cooperate' surrounding district councils must assist in finding land to accommodate Ipswich housing overspill. In this case around 4000 dwellings - how are Babergh proposing to help meet this requirement? Babergh should NOT be picking up all 4000.

Dear Sir,

I am writing to lodge my response to the BMSDC JLP Consultation document. Could you please confirm receipt of my submission and include me in the mailing list for updates on the progress of the JLP, thanks.

Section 1 -Strategic

Objectives:

- The JLP should aim to ensure that the local road networks in and around Sproughton village are capable of supporting any proposed developments.
- The JLP should ensure that all necessary infrastructure and services are delivered to support any proposed developments.

Priorities:

- The proposed developments should not cause local communities, such as Sproughton, to lose their identities, as a result of 'creeping coalescence ' ie, merging Ipswich with surrounding villages.

Duty to Cooperate:

- Ipswich should not be imposing 4000 new houses under this Duty to cooperate rule. How is Ipswich's total overspill requirement being spread across other surrounding councils?

Section 2 - Delivery

Housing requirement, Settlement Hierarchy and Housing Distribution

The Housing requirement 2014 to 2036 appears overstated @7820, particularly as this is based on 1.03 persons per house, as opposed to past average of 2.3. This begs the question of whether this forecast is current and has taken full account of our leaving the EU, and related domestic and overseas migration estimates.

Spatial Distribution

A planning approach which is more New Settlement Focused would enable existing communities such as Sproughton to retain their village identity. I favour an approach which goes down the bold, innovative and creative route, rather than encouraging Ipswich to pursue 'creeping coalescence' which will ultimately destroy the local communities in its immediate vicinity.

Other Distribution Options

The JLP proposes a high proportion of the housing growth to be in Sproughton, because of its close proximity to ipswich. I would prefer a more proportional approach, which would support the development of communities across Babergh, enabling necessary infrastructure and services to develop organically alongside sustainable housing growth, whilst also avoiding the destruction of villages such as Sproughton!

New Settlement

Following on from comments above, I support the creation of a new / garden town separate from current settlements, in order to protect the nature of existing communities. This seems to me to be the only reasonable way of meeting the objectives of the Babergh JLP as well as the Duty to Cooperate rule being imposed by the Ipswich plan.

Section 3 - Place

Consultation question 78
SS1024 - site not appropriate for development due to:
- The environment (Chantry Vale)
- creeping coalescence with Ipswich
- lack of supporting infrastructure (schools and health)

SS0721 - site appropriate for development but:
- not clear why some of the site has not been allocated to housing.
- given that the site has been available for development for approaching 16 years, why has development not taken place earlier, if the requirement for additional commercial and housing development around Ipswich is so pressing?

SS1023 - Site not appropriate for development due to:
- The environment (Chantry Vale)
- creeping coalescence with Ipswich
- lack of supporting infrastructure and services (schools and health)

SS0711 - site not appropriate for development due to:
Creeping coalescence between Bramford and Sproughton.



Regards

Thank you for consulting Transport for London (TfL). I can confirm that TfL has no comments to make on the consultation documents

See attached

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