MM1.

The approach to take some time to ensure Part 2 is achievable and suitable for the current situation is supported. The made Thorndon Neighbourhood Plan will ensure that development in Thorndon is delivered where the local community feel is most appropriate.

Stradbroke Parish Council understand and supports the rationale for splitting the JLP into 2 parts. Made Neighbourhood Plans will lead development in the interim whilst Part 2 is being developed.

see submitted Representations document

see submitted Representations document

Various changes to emphasise the need for housing allocations as part of Section 2.

Whilst we are very keen for progress to be made on the Local Plan and splitting it into two sections does appear to be a sound approach, it is imperative that Section 1 "guides" Section 2 and its contents. We have not suggested that MM1 renders Section unsound, because we do not want to cause unnecessary delay, but there is a clear need for some further modifications.

Section 2 Local Plan must be prepared promptly by the Council and a strategy of delivery along transit routes and around the main settlements, should be progressed with more evidence. In particular, housing allocations, while consigned to Section 2 of the Local Plan, will be needed in order to meet projected housing need and that Policies should be drafted to allow this to still be identified in Section 2.

The drafting of the MM and AM means that Part 1 now reads as though Part 2 will not include any additional sites for development, whereas the Strategy and evidence highlights that additional housing and economic allocations will be required in order to meet the needs identified in Part 1 of the Plan. We consider that not all of the modifications currently fit comfortably with the expectations for Part 2.

The Inspector’s letter of December 2021 (G09) highlighted (amongst other matters) concerns on the soundness of policies SP03, SP04 and the LS01 and the LA housing allocation policies (para.2). The letter did not suggest that Part 2 would not need to allocate sites, it simply questioned the soundness of the rationale for the proposed strategy and recognised that the housing supply was currently very strong such that further allocations are not currently critical to the immediate delivery of homes and development.

With regards to the timescales, larger sites can take up to three years from outline permission to first dwellings (see: NLP February 2020 ‘Start to Finish’) and the previous strategy relied upon strategic scale allocations. While not predetermining allocations in Part 2, if there is any reliance on strategic allocations for housing and economic development, Part 2 should be adopted by 2025/6, in alignment with the current LDS. We are also concerned that Part 1 indicates in the trajectory that the annual housing requirement will not be met throughout the latter part of the Plan from 2031/32 onwards and are not certain that this complies with paragraphs 66 and 68 of the NPPF unless there is a trigger for establishing how the shortfall will be met.

It is presumed that there will be no intention to review and amend Part 1 upon the preparation and adoption of Part 2 and therefore the wording in Part 1 should be cognisant of being flexible on the likely contents of Part 2.

Review of Housing Need and Supply – MM1
The Inspector found that the majority of the housing requirements have already been addressed by
extant planning permissions. The Part 2 Plan will therefore review the identified housing supply against
the relevant housing requirement to ensure that the housing requirements of the whole Plan period
are met.
A review of the Districts’ housing requirements against the identified housing supply from extant
planning permissions is supported. It is considered that reviewing the settlement hierarchy, spatial
distribution for housing allocations, housing requirements for Neighbourhood Plan areas, and
settlement boundaries will allow Mid Suffolk to meet housing need as assessed according to the latest
government methodology at the time of preparation of the Part 2 Plan.
We would strongly recommend that the Councils agree to a timetable for production of the Part 2 Plan,
indicating when the Plan will be submitted for Examination, to ensure the Plan is effective and can be
monitored. The Part 2 Local Plan is a critical element of the Development Plan and needs to be
advanced in the short term.
Review of the Settlement Boundaries – MM9
The Main Modifications note that while the existing settlement boundaries have been in place for some
time, extant planning permissions for new housing developments lie outside of these boundaries. To
review the settlement boundaries comprehensively and consistently would significantly delay the
adoption of the draft Plan.
The settlement boundaries will therefore be reviewed as part of the Part 2 Plan. Until then, the existing
boundaries will be applied through Policy SP03 to meet the Districts’ development needs while
recognising the intrinsic character of the countryside. The principle of development is established
3
within settlement boundaries, and development outside these boundaries is only permitted under
specific circumstances.
A review of the settlement boundaries to meet the Districts’ outstanding housing needs is supported
and needs to be undertaken immediately to reflect consents approved to date, along with future
growth. This further highlights the need for the Part 2 Local Plan to be prepared immediately.

Review of Housing Need and Supply – MM1
The Inspector found that majority of the housing requirements have already been addressed by extant
planning permissions. The Part 2 Plan will therefore review the identified housing supply against the
relevant housing requirement to ensure that the housing requirements of the whole Plan period are
met.
A review of the Districts’ housing requirements against the identified housing supply from extant
planning permissions is supported. It is considered that reviewing the settlement hierarchy, spatial
3
distribution for housing allocations, housing requirements for Neighbourhood Plan areas, and
settlement boundaries will allow remaining housing requirements over the Plan period to be achieved.
We would recommend that the Councils agree to a timetable for production of the Part 2 Plan,
indicating when the Plan will be submitted for Examination, to ensure the Plan is effective and can be
monitored.
Moreover, the evidence base for the Part 2 plan should be consistent with the evidence accompanying
the Part 1 Plan which evidently established the suitability of the Subject Site as a key location for
growth, given its spatial position relative to Washbrook, Ipswich, the A14 and A12 corridors, and
sustainable transport opportunities.
The Subject Site underwent a full design and planning process closely aligned to the Neighbourhood
Plan, which included commitment to highways improvements, provision of new open and play spaces,
biodiversity net gain, enhanced local walking and cycling provision, sustainable construction proposals
ahead of current building regulations, and protection of landscape character and heritage assets.
Previous concerns about piecemeal development of the Subject Site have been addressed, with all
three landowners being agreed to work together on a single masterplan.
The LA008 allocation in the Part 2 Plan would allow local housing needs to be met through a
sustainable scheme that includes committed delivery of local infrastructure and protection from
unplanned development.
Review of the Settlement Boundaries – MM9
The Main Modifications note that while the existing settlement boundaries have been in place for some
time, extant planning permissions for new housing developments lie outside of these boundaries. To
review the settlement boundaries comprehensively and consistently would significantly delay the
adoption of the draft Plan.
The settlement boundaries will therefore be reviewed as part of the Part 2 Plan. Until then, the existing
boundaries will be applied through Policy SP03 to meet the Districts’ development needs while
recognizing the intrinsic character of the countryside. The principle of development is established
within settlement boundaries, and development outside these boundaries is only permitted under
specific circumstances.
A review of the settlement boundaries to meet the Districts’ outstanding housing needs is supported.
As Babergh has a demonstrated need for an additional 1,191 dwellings over the Plan period, it will be
necessary for settlement boundaries to be revised to accommodate needed housing growth.
The LA008 site is adjacent to the Copdock & Washbrook settlement boundary and fits within the spatial
pattern of development in the parish. Given its proximity to the village of Washbrook, it is within walking
and cycling distance of a range services and facilities in Washbrook, including bus service to Ipswich
Railway Station. The principle of development on the Subject Site was established through the JLP
and Neighbourhood Plan processes.
Including the LA008 site within the settlement boundary would reflect its suitability as a key sustainable
growth area within the Ipswich Fringe and enable future Neighbourhood Plan-led development.

Anglian Water recognises that a number of matters will be addressed in the Part 2 Local Plan for Babergh and Mid Suffolk. We will seek to positively engage with Babergh and Mid Suffolk Councils in preparation of their Local Plan Part 2 with respect to the Settlement Hierarchy and spatial distribution, particularly where carbon efficiencies can be made in relation to available infrastructure and future infrastructure provision - both in terms of capital/embodied and operational carbon.

See full representation

Pigeon note that the modified Policies Map has saved a certain number of policies concerning strategic site allocations which are still delivering housing and employment around the Ipswich Fringe, Sudbury, Stowmarket, Hadleigh. The modifications to the JLP makes reference to these ‘saved’ policies within paragraph 1.06 in that ‘live’ list will be retained on the Councils website. Pigeon suggest that it would be helpful to have a list within the JLP Part 1, caveated that a ‘live’ list is available on the Councils websites for the sake of transparency, given these ‘saved’ policies are not obvious on the Policies Plan.

A review of the Districts’ housing requirements against the identified housing supply from existing planning permissions is supported. It is considered that reviewing the settlement hierarchy, spatial distribution for housing allocations, housing requirements for Neighbourhood Plan areas, and settlement boundaries will allow remaining housing requirements over the Plan period to be achieved. It is important, therefore, to ensure the JLP Part 2 comes forward as soon as possible.

We therefore consider that the only way forward is for the plan to be found unsound and for the Council to take the time required to prepare a new Local Plan/s supported by an updated evidence base and with an extended plan period.

In summary, we consider that the modified JLP fails to accord with national policy and is not justified by proportionate evidence such that it cannot be considered sound. Given the scale of the issues identified with both the submission version of the JLP and the current modified version, we do not consider that the JLP is capable of being modified in such a way that it could be found sound.

We therefore consider that the only way forward is for the plan to be found unsound and for the Council to take the time required to prepare a new Local Plan/s supported by an updated evidence base and with an extended plan period.

See attached Representations for further detail.

Please see attached document.

It is considered that the Plan could be made sound by Part 1 setting out strategic policies, the settlement hierarchy and the broad locations of development, and in that regard that Part 2 should be allocating sites (including confirming the housing requirement for Neighbourhood Plans).

Policy SP01 Indicates that in part 1 and part 2, the district will seek to deliver a minimum of 7904 dwellings; delivery of 10165 in mid Suffolk
The housing requirement under Policy SP01 the Council consider is already (about 90%) provided for by existing completions, sites under construction, sites with full or outline planning permission, sites with a resolution to grant planning permission (subject to s106), allocations in made NPs and the allowance of 1000 windfall dwellings.
The housing requirement which includes a 20% buffer, is still a minimum requirement.
With regard to existing planning permissions, it is reasonable to expect that a proportion will not come forward over the lifetime of the plan.
It is submitted that windfalls should not be relied upon to meet the housing requirement. The Council should be planning positively by allocating sufficient sites to meet the total housing requirement (including 20% buffer).
In this regard (again) the plan is not positively prepared and effective. Windfalls should be seen as a ‘bonus’
There is a suggestion that sites which have planning permission should be included in the plan in case the existing permission is not implemented. It is unclear about how that then contributes towards the requirement being met
The Inspectors Letter (G09) confirms that Part 2 will contain
•An up to date robust settlement hierarchy
•A spatial distribution for any housing allocations included insofar as necessary to provide flexibility and ensure that the plan period housing requirement can be met
•Consequent housing requirement figures for neighbourhood plan areas.
•Up to date and justified settlement boundaries reflecting commitments and allocations.
But there is no confirmation as how that this can be achieved outside of the examination process and with the benefit of an up to date plan in place setting out a housing requirement figure and development management policies (§11).
Usually a part 1 and part 2 plan is broken down as follows: to set out the strategic policies, settlement hierarchy, what the requirement is, and broad locations for where development would be acceptable (in Part 1) and then specific allocations to meet the identified need would come forward in Part 2. That is not the approach being taken here – there must be severe doubts about how this can all come forward in Part 2.
With regards to the proposed Part 2 Plan we support the provision of Housing requirement for Neighbourhood Plan areas (01.08)
It is considered that the Plan could be made sound by Part 1 setting out strategic policies, the settlement hierarchy and the broad locations of development, and in that regard that Part 2 should be allocating sites (including confirming the housing requirement for Neighbourhood Plans).

Policy SP01 Indicates that in part 1 and part 2, the district will seek to deliver a minimum of 7904 dwellings; delivery of 10165 in mid Suffolk
The housing requirement under Policy SP01 the Council consider is already (about 90%) provided for by existing completions, sites under construction, sites with full or outline planning permission, sites with a resolution to grant planning permission (subject to s106), allocations in made NPs and the allowance of 1000 windfall dwellings.
The housing requirement which includes a 20% buffer, is still a minimum requirement.
With regard to existing planning permissions, it is reasonable to expect that a proportion will not come forward over the lifetime of the plan.
It is submitted that windfalls should not be relied upon to meet the housing requirement. The Council should be planning positively by allocating sufficient sites to meet the total housing requirement (including 20% buffer).
In this regard (again) the plan is not positively prepared and effective. Windfalls should be seen as a ‘bonus’
There is a suggestion that sites which have planning permission should be included in the plan in case the existing permission is not implemented. It is unclear about how that then contributes towards the requirement being met
The Inspectors Letter (G09) confirms that Part 2 will contain
•An up to date robust settlement hierarchy
•A spatial distribution for any housing allocations included insofar as necessary to provide flexibility and ensure that the plan period housing requirement can be met
•Consequent housing requirement figures for neighbourhood plan areas.
•Up to date and justified settlement boundaries reflecting commitments and allocations.
But there is no confirmation as how that this can be achieved outside of the examination process and with the benefit of an up to date plan in place setting out a housing requirement figure and development management policies (§11).
Usually a part 1 and part 2 plan is broken down as follows: to set out the strategic policies, settlement hierarchy, what the requirement is, and broad locations for where development would be acceptable (in Part 1) and then specific allocations to meet the identified need would come forward in Part 2. That is not the approach being taken here – there must be severe doubts about how this can all come forward in Part 2.
With regards to the proposed Part 2 Plan we support the provision of Housing requirement for Neighbourhood Plan areas (01.08)
It is considered that the Plan could be made sound by Part 1 setting out strategic policies, the settlement hierarchy and the broad locations of development, and in that regard that Part 2 should be allocating sites (including confirming the housing requirement for Neighbourhood Plans).

It is considered that the Plan could be made sound by Part 1 setting out strategic policies, the settlement hierarchy and the broad locations of development, and in that regard that Part 2 should be allocating sites (including confirming the housing requirement for Neighbourhood Plans).

Policy SP01 Indicates that in part 1 and part 2, the district will seek to deliver a minimum of 7904 dwellings; delivery of 10165 in mid Suffolk
The housing requirement under Policy SP01 the Council consider is already (about 90%) provided for by existing completions, sites under construction, sites with full or outline planning permission, sites with a resolution to grant planning permission (subject to s106), allocations in made NPs and the allowance of 1000 windfall dwellings.
The housing requirement which includes a 20% buffer, is still a minimum requirement.
With regard to existing planning permissions, it is reasonable to expect that a proportion will not come forward over the lifetime of the plan.
It is submitted that windfalls should not be relied upon to meet the housing requirement. The Council should be planning positively by allocating sufficient sites to meet the total housing requirement (including 20% buffer).
In this regard (again) the plan is not positively prepared and effective. Windfalls should be seen as a ‘bonus’ There is a suggestion that sites which have planning permission should be included in the plan in case the existing permission is not implemented. It is unclear about how that then contributes towards the requirement being met
The Inspectors Letter (G09) confirms that Part 2 will contain
• An up to date robust settlement hierarchy
• A spatial distribution for any housing allocations included insofar as necessary to provide flexibility and ensure that the plan period housing requirement can be met
• Consequent housing requirement figures for neighbourhood plan areas.
• Up to date and justified settlement boundaries reflecting commitments and allocations.
But there is no confirmation as how that this can be achieved outside of the examination process and with the benefit of an up to date plan in place setting out a housing requirement figure and development management policies (§11).
Usually a part 1 and part 2 plan is broken down as follows: to set out the strategic policies, settlement hierarchy, what the requirement is, and broad locations for where development would be acceptable (in Part 1) and then specific allocations to meet the identified need would come forward in Part 2. That is not the approach being taken here – there must be severe doubts about how this can all come forward in Part 2.
With regards to the proposed Part 2 Plan we support the provision of Housing requirement for Neighbourhood Plan areas (01.08)
It is considered that the Plan could be made sound by Part 1 setting out strategic policies, the settlement hierarchy and the broad locations of development, and in that regard that Part 2 should be allocating sites (including confirming the housing requirement for Neighbourhood Plans).

Inclusion of a timetable for Part 2

Dear Sir/ Madam
Response by the Home Builders Federation to the Main modifications of Babergh and
Mid Suffolk Local Plan
1. Please find below the Home Builders Federation (HBF) response to the consultation on
the Main Modifications to the Local Plan. The HBF is the principal representative body
of the housebuilding industry in England and Wales and our representations reflect the
views of discussions with our membership of national and multinational corporations
through to regional developers and small local housebuilders. Our members account for
over 80% of all new housing built in England and Wales in any one year.
MM1
Modification is unsound as it lacks clarity as required by paragraph 16 of the NPPF and is
not effective.
2. The HBF recognise the importance of having a plan in place to support development and
that the only way to achieve this would be through a two-part local plan. However, we
are concerned that whilst the councils have committed to delivering a part 2 local plan
there is no policy committing the council to a timetable and no consequences should any
proposed timetable not be achieved. At the very least a timetable should be included in
the local plan as to when the part 2 local plan will be submitted for examination in order
to ensure that the proposed modification is effective and can be monitored.
MM8
3. The HBF supports the modification to reduce the contributions for affordable on
brownfield sites which better reflects the approach advocated in paragraph 59 of the
National Planning Policy Framework (NPPF).
MM50
Modification is unsound as it is inconsistent with government policy or effective.
4. Reference needs to be made in the policy or supporting text to the transition period for
the introduction of the mandatory 10% Biodiversity Net Gain (BNG). At the time of
examination, it was intended that it would apply to all development from November 2023.
However, the Government have confirmed in its response to the recent consultation on
regulations and implementation of BNG1
this period has been extended to April 2024 for
small developments of less than 10 units or under 0.5 ha. The Council must be clear that
the 10% BNG will apply from these dates as set out in the Act and its supporting
regulations. In addition, the Government’s response also sets out its intention with
regards to exemptions and as such a statement confirming that the Council will deliver
mandatory requirements for BNG in line with the Environment Act would provide the
necessary clarity for applicants and decision makers.
5. The Council are also proposing to amend part 2 subsection e to state that the Council
will seek appropriate resources from developers for monitoring of biodiversity net gains.
The HBF consider it necessary that this reference to monitoring should be amended and
the statement that appropriate resources will be sought from developers for the
monitoring of biodiversity net gain. Whilst in some circumstances the most appropriate
way forward may be in the form of a payment, there may be other approaches to
monitoring of delivery that do not require a financial contribution. For example, where
BNG are secured through a conservation covenant the Government have stated in the
recent consultation2
that this is to be included in the price of the units and as such an
additional contribution would not be required. To ensure that there is sufficient flexibility n the policy we would suggest the following wording which is more consistent with that
used by Government in their response to the recent consultation.
“Monitoring of biodiversity net gains will be proportionate and where appropriate set out
as a planning condition or obligation”.
MM57
Modification is unsound as it is not needed as it is an unnecessary repetition of national policy
and lacks the necessary clarity required by the NPPF.
6. Rather than amend Part 2a of policy LP25 the HBF would recommend that it is deleted
as it is not necessary to repeat building regulations nor state that future iterations of said
regulations should be adhered to. These are mandatory standards that are delivered
outside of the planning system and as such do not need to be repeated. The same
applies to subsequent regulations and there is no need to stipulate that these will also
need to be met. Whilst their inclusion may not be considered problematic at present there
is the potential for the misapplication of future policy if any technical standards are
optional and require the Council to justify their inclusion though the local plan. Whilst we
recognise this is a hypothetical situation decision makers could potentially seek to apply
future optional standards without the necessary process for their adoption being
undertaken.
7. The HBF are concerned that the wording of part e could still lead to decision makers
asking for viability evidence to show that the most viable and feasible level of low carbon
energy is provided on site. The HBF recognise that this should be a consideration but
the viability or feasibility considerations should relate to its provision or not rather than
maximisation of onsite renewable energy provision. We would suggest the policy
amended to read:
“Onsite renewable and other low carbon energy generation will be required where viable
and feasible.”
8. The HBF still consider part f to be unsound. The 100 litres per person per day (lpppd)
water unsound as it goes beyond the optional technical standard in paragraph 56-014 of
Planning Practice Guidance (PPG). NPPF states at paragraph 154 that technical
standards relating to sustainable buildings should reflect the Government’s policy for
national technical standards and should be set at the 110 lpppd option standard of PPG.
MM59
Modification is unsound as it is not consistent with national policy.
9. Part 2e requires developers to adhere to Building for Healthy Life framework. Whilst the
HBF is supportive of the use of Building for a Healthy Life the policy as written is too
prescriptive and requires development to adhere to a framework set out side of the local
plan making process. We would suggest that this is amended to “take account of…” or
“have regard to …”

The wording is vague and non-committal, particularly paragraph 01.08 which states that the Part 2 Plan is “likely” to include the listed matters.

In order to ensure that the Plan is effective, this wording should be amended to provide absolute clarity on the matters to be included within the Part 2 Plan, and to compel the Councils to meet a specified timetable for its preparation.

We generally support this Modification, which seeks to ensure that a Local Plan is in place for the District as quickly as possible. However, there is no policy commitment to prepare the Part 2 Plan within a specified timeframe, nor any indication of the consequences should this not be achieved. The wording is vague and non-committal, particularly paragraph 01.08 which states that the Part 2 Plan is “likely” to include the listed matters.
It is imperative that the Part 2 Plan is progressed at pace, as there are a significant number of matters that will not be satisfactorily dealt with until the Part 2 Plan is in place. For example, and as set out in our comments in relation to MM9, the retention of the existing Settlement Boundaries is problematic as they are significantly out of date and in many cases either do not reflect the situation on the ground at present where there has been considerable development, or will not reflect the situation once committed development is delivered.
In order to ensure that the Plan is effective, this wording should be amended to provide absolute clarity on the matters to be included within the Part 2 Plan, and to compel the Councils to meet a specified timetable for its preparation.

Spatial distribution of housing is also required to support the Part 1 Plan's employment growth aspirations and the delivery of new local infrastructure in both Mid-Suffolk and Babergh.
The bullet point in para 01.08 should be amended to reflect this important point (as without a well related supply of new housing, job creation may not be realised to its full potential and locally important infrastructure, enabled by housing growth, may not be delivered.

see attached for full submission

Please see attached full rep.

Please see attached full rep.

Please see attached full rep.

Please see attached full rep.

It is clear that the plan should contain a requirement for the Councils to prepare a new, full JLP which accounts for and addresses all of the above issues and provides a robust and fully justified and effective strategic framework for development across Babergh and Mid Suffolk, rather than a piecemeal part 2 plan.

Please see attached full rep.

These representations to the Babergh and Mid Suffolk Joint Local Plan (JLP) consultation on
Proposed Main Modifications (MM) are made by Pegasus Group on behalf of Ballymore Group
and Mr & Mrs Price (the parties). These representations should be read in conjunction with
representations made on behalf of the parties at previous stages of the JLP examination, including
various statements for the 2021 Hearing Sessions, and representations submitted to the
Regulation 18 and 19 consultations.
These representations are made in the context of the promotion by the parties of Land south of
Pond Hall Road, Hadleigh for development led by a hub of new sports, community and commercial
facilities alongside new homes. The site was not allocated in the submitted version of the emerging
JLP but can be identified with the reference SS0221 in the Strategic Housing and Economic Land
Availability Assessment (Reference EH06, October 2020).
The parties rebutted in detail the Councils reasons for discounting the site as a potential allocation.
The Inspectors recommendations for the housing site selection process to be reviewed, as set out
in their letter dated 9 December 2021 (G09), were welcomed. This is in line with representations
made by the parties about the deficiencies of the assessment process, and consequently the
soundness of the JLP. Since the Hearing Sessions in 2021, the parties have been engaged in
undertaking detailed technical assessment which have further demonstrated that there are no
technical constraints to the delivery of the site – and thus that the Councils assessment of the site was not justified. The parties look forward to a re-assessment of the deliverability of the site in
due course and welcome engagement from the Councils in this process.
There are some outstanding concerns as set out in representations to individual Main
Modifications, which require addressing to ensure the JLP is positively prepared, is justified,
effective and consistent with national policy, in accordance with the National Planning Policy
Framework 2019 (the Framework).
The parties acknowledge the unique situation the Councils are in, and that the approach of
splitting the JLP into Parts 1 and 2 is proposed as a pragmatic solution that enables plan making to
continue while resolving the soundness issues summarised in the Inspectors letter dated 9
December 2021 (G09). The parties agree that there were issues of soundness with the JLP as
submitted; these issues were well-rehearsed in previous representations. However, it is of concern
that the time taken to reach this stage for Part 1 is by itself eroding effective plan making in the
Districts. The evidence that underpins Part 1 is now dated, and the evidence base for Part 2 will
have to be re-produced, making it unlikely that the timescales for adoption of Part 2 set out in the
Local Development Scheme (October 2022, H37) will be adhered to. The datedness of supporting
evidence was an issue raised by the Inspectors in their letter dated 16 September 2022 (G12). A
further seven and a half months1
(at the time of writing) have passed since then.
It is contended that the above has not been appropriately considered when drafting the Main
Modifications for Part 1. MM1 confirms that Part 1 will identify the housing requirement, and Part
2 will make the allocations required to meet that requirement. Paragraph 01.07 confirms that the
‘majority of housing requirements’ for each District is provided for by extant planning permissions.
The parties’ representations on MM4 and MM5 should be referred to for further comment on
housing need, however 01.07 makes clear that there is existing need, particularly in Babergh, that
is currently not being planned for.
The housing delivered and approved under recent planning permissions has established the
sustainability of certain settlements in the Districts. Part 1 needs to establish a strategy for the
suitable spatial distribution of housing now using this evidence, most effectively through an
expansion of Policy SP03. This will allow sustainable development to come forward in advance of
the adoption of Part 2, ensuring the outstanding shortfall can be met without any further delay. It
is not just housing needs that will be met through this approach, but will also ensure that the JLP’s
aspirations for economic growth as set out in MM19 and MM20 can be met.
The parties consider that the market town of Hadleigh is an ideal location and an example of a
sustainable settlement, demonstrated by recent permitted development. Hadleigh is capable of
accommodating further development in a sustainable manner to meet local housing needs and to
further enhance and sustain the growth required to enhance the vitality and viability of both
Hadleigh and the surrounding area which it supports.
Part 1 should contain policies that allow for housing delivery and supporting infrastructure in
suitable and sustainable settlements like Hadleigh, subject to local level consideration against
development management policies. Please refer to our later representations on Policy SP03,
which is an ideal policy that can be effectively modified to fulfil this requirement

Suggested remedy: It is suggested that a new policy is inserted to the Part 1 Local Plan which sets out both the context requirement and timescale requirement for the Part 2 Local Plan. Suggested wording for such a policy is provided below. Suggested Remedy - Proposed Policy Wording - Local Plan Part 2
1.9. “Babergh Council and Mid Suffolk Council, will immediately undertake preparation of the Local Plan Part 2 for each respective area. Specific matters to be addressed in Part 2 will include the following:
Settlement hierarchy;
A spatial distribution for any housing allocations insofar as necessary to provide flexibility to ensure plan period housing requirements can be met;
Housing requirement figures for Neighbourhood Plan areas;
First Homes policy;
Settlement boundaries;
Open space designations;
An assessment of Gypsy, Travellers and Travelling Showpeople needs, and if necessary, allocations to provide for these needs;
An assessment of Houseboat Dwellers’ needs, and a relevant development management policy for houseboat dwellers, moorings and marinas; and
Other matters which are considered necessary by the Councils, dependent upon the monitoring of the Plan and the circumstances at the time.
1.10. The Local Plan Part 2 shall be progressed in accordance with the following timescales:
Summer 2023 - Regulation 18 Local Plan Consultation
Spring 2024 – Regulation 18 Local Plan Consultation
Autumn 2024 – Regulation 19 Local Plan Consultation
Winter 2024 – Submission for Examination”
1.11. It is recognised that Babergh has a residual need to identify additional land to meet its identified housing need across the plan period.
1.12. The timescales referenced in the above suggested wording reflect the Local Development Scheme as dated October 2022 and therefore should represent a realistic timescale that Babergh and Mid Suffolk could adhere to.
1 1,191 dwellings / 416 = 2.86 years

Main Modification Reference MM1 - Chapter 01 – 01.01-01.19
1.1. General support is given to the proposed text introduction explaining the amendments to the Local Plan Part 1. It clarifies that the Local Plan will take the format of Part 1 followed by Part 2. Detailed comments are main in response to specific aspects of the proposed text.
Issue: Live List of Planning Policies
1.2. Proposed paragraph 01.06 makes reference to a list of relevant policies being contained within a ‘live list of planning policies (including remaining saved policies) is maintained on each Council’s website respectively’ however the respective list has not been provided for the purpose of the Main Modifications Consultation.
Issue: Housing Requirement
1.3. Proposed paragraph 01.07 correctly identifies “A key element of plan making is to identify an overall housing requirement and ensure that it is delivered by planning policies. However, in Babergh and Mid Suffolk Districts an unusual situation applies where extant planning permissions provide for the vast majority of each District’s housing requirements across the Plan period. Accordingly, the Plan identifies the volume of identified housing supply relative to the housing requirement…” (emphasis added by underlining)
1.4. It is considered important not to underplay that Table 3 (Main Modification 4) clearly identifies that there is a residual need to plan for 1,191 homes within Babergh District, equivalent to almost 3 years’1 worth of supply over the period 2018 to 2037.
Issue: Timely Progression of Local Plan Part 2
1.5. Proposed paragraph 01.07 continues: “The Part 2 Plan will review the identified housing supply against the relevant housing requirement and will make allocations if necessary to sufficiently provide for the housing requirements of the whole Plan period.” (emphasis added by underlining). Whilst support is given to this statement, objection is raised as there is no proposed policy obligating the Councils, Babergh District in particular, to progress the Local Plan Part 2 in a timely manner.
Issue: Content of Local Plan Part 2
1.6. Similarly, proposed paragraph 01.08 only makes reference to the matters the Local Plan Part 2 is “likely to include” (emphasis added by underlining) rather than making any firm policy obligation for specific matters to be addressed.
1.7. Proposed paragraph 01.08 states: “In addition to this, the Part 2 Plan, which upon adoption will also form part of the Development Plan, is likely to include the following matters:
• Settlement hierarchy;
• A spatial distribution for any housing allocations insofar as necessary to provide flexibility to ensure plan period housing requirements can be met;
• Housing requirement figures for Neighbourhood Plan areas;
• Settlement boundaries;
• Open space designations;
• An assessment of Gypsy, Travellers and Travelling Showpeople needs, and if necessary, allocations to provide for these needs;
• An assessment of Houseboat Dwellers’ needs, and a relevant development management policy for houseboat dwellers, moorings and marinas; and
• Other matters which are considered necessary by the Councils, dependent upon the monitoring of the Plan and the circumstances at the time.”
1.8. Suggested remedy: It is suggested that a new policy is inserted to the Part 1 Local Plan which sets out both the context requirement and timescale requirement for the Part 2 Local Plan. Suggested wording for such a policy is provided below. Suggested Remedy - Proposed Policy Wording - Local Plan Part 2
1.9. “Babergh Council and Mid Suffolk Council, will immediately undertake preparation of the Local Plan Part 2 for each respective area. Specific matters to be addressed in Part 2 will include the following:
Settlement hierarchy;
A spatial distribution for any housing allocations insofar as necessary to provide flexibility to ensure plan period housing requirements can be met;
Housing requirement figures for Neighbourhood Plan areas;
First Homes policy;
Settlement boundaries;
Open space designations;
An assessment of Gypsy, Travellers and Travelling Showpeople needs, and if necessary, allocations to provide for these needs;
An assessment of Houseboat Dwellers’ needs, and a relevant development management policy for houseboat dwellers, moorings and marinas; and
Other matters which are considered necessary by the Councils, dependent upon the monitoring of the Plan and the circumstances at the time.
1.10. The Local Plan Part 2 shall be progressed in accordance with the following timescales:
Summer 2023 - Regulation 18 Local Plan Consultation
Spring 2024 – Regulation 18 Local Plan Consultation
Autumn 2024 – Regulation 19 Local Plan Consultation
Winter 2024 – Submission for Examination”
1.11. It is recognised that Babergh has a residual need to identify additional land to meet its identified housing need across the plan period.
1.12. The timescales referenced in the above suggested wording reflect the Local Development Scheme as dated October 2022 and therefore should represent a realistic timescale that Babergh and Mid Suffolk could adhere to.
1 1,191 dwellings / 416 = 2.86 years