BMSDC Joint Local Plan - Pre-Submission - Sustainability Appraisal and Appropriate Assessment 2020
Representation ID: 21427
Respondent: Sudbury Area Green Belt Group
Legally compliant? No
Duty to co-operate? No
Environmentally not sustainable:
- Policy Review & Baseline too insubstantial and tokenistic;
- Allows expedient developer-led processes, not proactive; not accountable for operation of SA recommendations; negligible promise;
- Babergh's chronic failure could persist on numerous standards as in our full text;
- Need for appraisal visits to SHELAA and LA sites, to correct some E19 ratings;
- Appendix F negates the preceding painstaking work, with identikit “mitigations” providing a “get-out clause” for development;
- Positives are claimed by keeping fragments of sites;
- Appendix G is so abbreviated and partial as to be irrational and misleading.
a) Include a clear system for:
- assessing achievement against the ratings in Appendix C;
- referring to Appendix E Appraisals in published planning decisions;
b) Review Table E to avoid such follies as: giving a double plus for recreation etc, to the destruction of an exceptionally beautiful site of natural grassland and small fields, much used by the public, that would doubtless be accorded “net gain” for substituting a lesser fragment of tidied land and planted trees.
App A Consultation comments received on the SA Scoping Report
We believe many of the comments, have too readily been dismissed wholesale.
Appendix B Policy Review and Baseline Information - Biodiversity
This section does not give us the claimed confidence of a sustainable Plan, it relies on a Policy Review & Baseline that are too insubstantial:
B.230 Suffolk's Nature Strategy (2015) is so soggy, weak and inconsequential, it serves as no more than a suggestion for a tick-list;
B.232 In September 2019 Babergh District Council pledged to protect wildlife, biodiversity and natural habitats which included: - wildflower verges - these will be very few in number - free trees for families - this is a trivial, token, misplaced effort - producing a map showing Babergh's wildlife networks - the document on this plan so far fails to indicate how extensive this will be, whether it will be published, whether Babergh will implement findings unilaterally as implied, or whether Babergh will be accountable for its translation of any recommendations into practice.
B.233 The Climate Change Task Force - these efforts are not so far above the routine of local authorities as to be worth the mention; the councillors who originated this have now dismissed it as too limited.
B.234 Babergh and Mid Suffolk also provide details of national ecological guidance on their website - we have never seen these guidance items referred to in any planning decision.
B.235 A Green Infrastructure Framework for Babergh District (August 2012): This Framework identifies key opportunities for the enhancement of Green Infrastructure and future provision/connections in a number of areas, including Ipswich, Hadleigh and Sudbury/Great Cornard/Chilton. - we regard this document was a mere inventory of the status quo, offering negligible promise for the future. As examples of its unimportance, we give: - a lack of any improvements for Great Cornard (we don’t count a “cycle track” on existing narrow congested streets) - and the only changes for Chilton being far distant from the existing heavily populated town area.
Appendix C Assumptions Applied for the Sustainability Appraisal of Site Options
We question the sustainability of:
1b Open space, sport and recreation - we can’t see how this can be scored as “minor positive”: 301-800m from open space, sport, recreation facility, open country and registered common land since the ANGSt standard is for everyone to live within 300 metres of 2 hectares - this would just rubber-stamp Babergh’s acknowledged failure to meet the standard in town areas.
5c WwTW Flow Capacity - we welcome this but there is no track record of it being applied, and the draft Local Plan continues for example, to support Site SS0220 in Great Cornard where there is an acknowledged severe problem.
11b Locally designated biodiversity assets, priority habitats and ancient woodland - we welcome the detailed negative rating for building nearby, but point out that Babergh has not ruled out development, on land assessed by Natural England as Priority 1 Grassland Habitat (SS0590 Churchfield Road, Sudbury).
13. To conserve and enhance the quality and local distinctiveness of landscapes and townscapes. - we welcome the inclusion of this rating, but unless there is a clear system for assessing it, we don’t believe it will be applied to deciding planning applications.
Appendix E Detailed Appraisal of Site Options
We challenge whether these Appraisals will be respected to achieve sustainability, and without some requirement for the Appraisals to be referred to in published planning decisions, we challenge whether they will be overlooked in the event of planning applications on these sites.
Table E.12: Chilton Parish
We are amused by the double negative for SS0590, GP surgeries - since the site is on NHS land which also has a major surgery.
We note that site SS0590 rightly has a large number of negatives, and with construction due to start on adjacent land at Chilton Woods, we challenge what pluses could be achieved by building here, that won’t be better achieved on Chilton Woods in 2021.
Table E.19: Great Cornard Parish
1b, 1c and E.165: With site SS0220, we see exemplified the folly of giving a double plus for recreation etc, to the destruction of an exceptionally beautiful site of natural grassland and small fields, much used by the public, that would doubtless be accorded “net gain” for substituting a lesser fragment of tidied land and planted trees. This land is crucial to the beauty of the Gainsborough Walking Trail, and the double plus is perverse since the development will ruin that.
5c WwTW Flow Capacity: - for SS0242 this is rated at zero, contrary to the locally well-known and worsening problems with sites SS0220 and SS0242, and the adjacent Woodland Rise development, which is finally being acknowledged by the water authorities. This rating would undermine the Executive Summary recommendation of the independent report “Surface water and drainage: review of responsibilities” published by DEFRA in August 2020, ie Page 8: “Planning system - That the Ministry of Housing, Communities and Local Government, in their forthcoming review of the National Planning Policy Framework, ensure that advice on the vital importance of achieving sustainable drainage in all new development is prominent, clear and unequivocal. That local planning authorities ensure that appropriate professional expertise is brought to bear in decision making on all planning applications where there are surface water drainage implications. That local planning authorities ensure the submission of drainage plans at an early stage in the planning approval process, and that the whole development is carried out in accordance with the approved plans.” The danger is of Babergh not applying it to SS0242 Tye Farm, because it’s (wrongly) rated “0” in the SA appendix E Table E19 - which gives "--" SS0220 but "0" to SS0242 - so we ask for this to be corrected to “possible negative” (local evidence from adjacent sloping sites is of considerable overland flows on the springline, which a recent development has disastrously altered the direction of. We challenge Babergh to seek a re-assessment of these three adjacent sites, in the spirit of this quote from the government website for the Review: “While the review will now be considered in full by ministers, the government is immediately accepting 12 of the recommendations.”
13. To conserve and enhance the quality and local distinctiveness of landscapes and townscapes: - the single negative for SS0220 shows the inability to tell from a desk top study, that this is the most beautiful and natural of the SHELAA sites in the whole Sudbury area. The single negative for SS0433 shows a failure to recognise the loss of important river valley scenery.
E.169 Sites SS0220 (Land south of Davidson Close, Sudbury) and SS1082 (Land east of Kings Hill, Great Cornard) as both sites contain land with a 1 in 30 year risk of surface water flooding. - we are relieved to see this, albeit tucked away in the small print. However we point out the risk at SS0220 appears higher and is worsening, and the SA fails to make any suggestion that such sites could be reconsidered with a view to excluding from the SHELAA list. We point out the continuing failure to identify a risk for SS0242, despite it being in Critical Drainage Areas 3&5 of the Sudbury and Cornard Surface Water Management Plan.
E.170 Site SS0220 (Land south of Davidson Close, Sudbury) We welcome the fact that this site has not been “Allocated”, and we hear Babergh will hold it “in reserve”, apparently the lowest form of “suitability in principle”. But we challenge what this amounts to in terms of sustainability, since it allows for an option of “Allocation” in the future, and in the event of a planning application it would amount to just “suitability subject to mitigation”, and an effective ruling out of “avoidance”; which is an illogical and perverse position. The decision is based on desk-top studies,and has overlooked real information (such as the Report of the Cornards’ Residents Association, which showed that development here could never be suitable).
Appendix F Detailed Appraisal of Place and Allocations Policies
Those of the public who have struggled as far as Appendix F may well be shocked to see the painstaking work of the preceding Site Appraisals, so largely negated by the “mitigations” that now provide a “get-out clause” for development - and that App F approves “identikit” mitigations that are simplistic, inappropriate and ineffectual. The conversion of countryside into suburbia or worse, can now proceed in a blunt way, giving no distinction or differential treatment to the most sensitive or precious sites.
Table F.15: LA042 – Allocation: Land at Tye Farm, Great Cornard (Site SS0242) – Residential (new allocation):
1. To improve the health and wellbeing of the population overall and reduce health inequalities:
1b Open space, sport and recreation: As set out in the policy wording, accessible natural green space will be retained. However, if this is not possible, alternative provision of equal or greater quality natural green space that is accessible will be provided. Therefore, the major negative effect against criterion 1a (Open space, sport and recreation) has been upgraded to a minor negative effect to reflect this. - we are shocked by such glib “mitigations” which are characteristic in the planning world, and challenge whether the end result would be a positive for sustainability, because:
Once again, a positive is claimed by a fragmentation of the feature, ie the present de facto access over almost all the site; however the present major benefit would be lost which we believe to be exceptional locally: a wide open grassland space adjacent to town, with “big sky” and a superb panorama of Sudbury
We must point out that we cannot judge the question clearly since we cannot obtain from Babergh any information on which parts of this very large site are expected to be built on, or where the vehicle access might be; whether the single piece of such info ie the 70m contour, could ever be suitable or not, depends entirely on which parts of the site would be built. We are shocked by this lack of info and protest, given how many years it is since the site was allocated.
1c Public Rights of Way (PRoW): the policy states that nearby Public Rights of Way will be protected. Therefore, uncertainty has been removed from the major positive effect recorded against criterion 1c (Public Rights of Way) to reflect this. Once again we see the trick of claiming a positive by merely maintaining the status quo.
11 LA042 – Allocation: Land at Tye Farm, Great Cornard (Site SS0242): An ecological survey and any necessary mitigation measures will be provided. Therefore, the major negative but uncertain effect against criterion 11b (Locally designated biodiversity assets, priority habitats and ancient woodland) has been upgraded to a minor negative but uncertain effect to reflect this. - we challenge this wording and ask for it to be reconsidered, since:
a) it reads illogically;
b) there’s no indication of whether or how the doubtful “necessary mitigation measures” could be possible or achievable, so it not only sets the bar too low, but completely demolishes it.
c) We challenge what has happened here to the NPPF para 175’s hierarchy of avoid - mitigate - compensate, since the “avoid” option is “avoided”. We challenge how a Land Allocation could ever have been made on this site, and quote the NPPF para 171 “allocate land with the least amenity or environmental value….maintain and enhance networks of habitats and green infrastructure”. At this rate, the whole SA exercise would be betrayed and become hollow window-dressing.
13 To conserve and enhance the quality and local distinctiveness of landscapes and townscapes: Development will also be screened with planting, which will retain and extend the wooded character of the existing eastern settlement edge of Great Cornard. Consideration will also be given to prominent and open slopes or elevated areas where development is likely to have localised visual prominence. - These remarks are hardly acceptable, particularly in the absence of any indication of which parts of this very large site might be developed. The fact there are woods in the area is all but irrelevant. In the planning appeal APP/D3505/W/19/3230839 for the comparable nearby site at Prospect Hill, the Inspector dismissed the appeal on grounds of landscape, stating that “In any event, planting cannot be relied upon to provide a solid and permanent buffer to views. This is because it is ever evolving, is reliant on regular maintenance to retain a consistent form and may be reduced in scale or extent in the future.”
Appendix G Reasons for Selecting or Rejecting Site Options
We fail to see what is gained by including Appendix G, unless it’s corrected, since it’s comments are so abbreviated and partial as to be irrational and misleading. For instance, in the case of:
Babergh, Urban Areas and Market Towns, Chilton, SS0590:
a) it’s surely irrational that the site hasn’t been “Allocated” yet has been accorded a “Dwelling Yield” (of 25 houses);
b) we must assume it’s an error not to have listed “biodiversity” after Potential for significant impact on heritage assets (the site was assessed by Natural England as Priority l Grassland Habitat) - this should be corrected.