MM4.

Copdock and Washbrook Parish Council notes the significant reduction in the housing shortfall as outlined in the Table at MM04. We further note that (as advised by BMSDC planning leadership) the reduced shortfall of 1,191 in Babergh will be lowered still further when the 750 homes recently approved at Planning Committee for ‘Wolsey Grange Phase 2’ feeds into the Committed Supply pipeline.
We welcome the confirmation that when any call for sites process is reinstated it is this drastically reduced housing shortfall that it will be aiming to address. We also support the proposed changes to SP03 (MM10) and expect this unequivocal position on development outside settlement boundaries to be reflected in practice at future planning committees.

The Parish Council supports the clearer approach to identifying the housing requirement

Stradbroke Parish Council welcomes the clarity brought by the revised table which makes clear the outstanding need for each area.

In the supporting text to Table 3, the Council must recognise that as part of the Section 2 process, the numbers will be updated to reflect the correct position at the time of adoption, or at the very least introduce flexibility to allow the numbers to change.

Table 3 provides an updated table of housing need and delivery in the two districts and confirms that there remains a shortfall of around 1,191 dwellings in Babergh district, even with an estimated windfall of 500 dwellings. Whilst it is appropriate for Section 1 to set out this position, it must be recognised that this is a snapshot in time and there will likely be changes to the numbers, which will directly impact on what Section 2 has to deliver.

For example, there are no guarantees that all the consented plots will be delivered so the shortfall will increase.

Pigeon notes that Table 3 ‘Residual Housing Need over the Plan Period’ sets out the committed supply of housing in a way that responds to the Inspectors request at the December 2021 meeting. Pigeon would comment that it would have been helpful for the Councils to publish the data to support the sites that made up the 2021 Committed Supply. This is because it is difficult to review this figure when it is caveated by the fact that certain major sites have been discounted due to delivery uncertainty and that the sites are not the same as those ‘deliverable’ sites set out in the Councils 5 Year Housing Land Supply Assessments. Pigeon suggests that publishing this information as part of the evidence base and Councils justification to their approach would have been helpful to those reviewing and commenting on the modifications.

To support the information within Table 3 of the Joint Local Plan, Pigeon suggest that it would have been helpful for the Councils to have published the data which informed it. This would have helped those commenting on the modifications given that the information cannot be extrapolated from other sources given the caveats the Councils have put against the table.

Please refer to attached representation.

Please see document for proposed change.

Please see attached document.

It is considered that the housing figures should be reconsidered and increased to ensure that the needs of all groups within the community are fully met, throughout the Plan period, in a coordinated and sustainable manner.

We object to this Modification, which sets out that the housing supply shortfall to be addressed in the Part 2 Local Plan will be 0 for Mid Suffolk and only 1,191 dwellings for Babergh, as it is not justified, effective or consistent with national policy. We consider that the proposed reliance on committed sites to deliver all of the planned housing growth within Mid Suffolk, and the majority of that in Babergh, in the period to 2037 is fundamentally flawed, and will result in delivery being heavily skewed to the earlier parts of the Plan period, with no provision made for an ongoing housing supply in later years.
In addition, it is not clear whether the committed supply will deliver sufficient affordable housing in line with Policy SP02; it appears that an assumption has been made that all committed development will provide the average level of affordable housing that has been seen over the past 5 years (24.6%). As the supply is made up largely of existing planning consents, it would be more appropriate to analyse those permissions to ensure that sufficient affordable housing is planned for the Districts.
Similarly, the approach set out in MM4 will not meet the needs of other groups in the community such as older people. There is no evidence to suggest that the committed supply of housing that makes up the vast majority of the housing supply in the Districts will deliver, for example, the quantum of accommodation that is required to meet the significant needs of the ageing population over the Plan period. In the absence of a Policy that enables such development to come forward outside of allocated sites (see also our Representation in respect of MM35), the approach set out in MM4 will leave such needs unmet, contrary to NPPF paragraph 62.
Additionally, much of the committed supply is a result of unplanned and speculative proposals, and therefore not necessarily directed to the most appropriate locations. There is a need for a more considered allocation of additional housing growth across the Districts to ensure that growth is directed to locations to sustain services and facilities in a planned and coordinated manner. The approach set out in MM4 will not result in sustainable development.
In light of the above, it is considered that the housing figures should be reconsidered and increased to ensure that the needs of all groups within the community are fully met, throughout the Plan period, in a coordinated and sustainable manner.

We believe that Table 3 needs to be amended in order to add reference to these two important considerations.

MM4 (Table 3): It is important to note that Table 3 – ‘Residual Housing Need over the Plan Period’ does not take into account affordable housing needs or any need for flexibility in the housing land supply.We are concerned that the Council appears to conclude that no allocations are necessary in Mid Suffolk through the Part 2 Local Plan on the basis that sufficient sites already have planning permission or are allocated in a made Neighbourhood Plan. This approach provides no flexibility to the housing supply, and it is clear from the housing trajectory that a very limited amount of housing is expected to be delivered towards the end of the plan period in Mid Suffolk. We believe that Table 3 needs to be amended in order to add reference to these two important considerations.

Table 3 should be deleted from the Plan as it puts forward figures not supported by evidence; and the relevant housing need figures are already put forward in Policy SP01

see attached for full submission

This response principally relates to Main Modifications MM4.
Bloor Homes supports the total local housing need requirement of 7,904 dwellings across Babergh
during the Plan Period (2018-2037). Chapter 6 (Housing Needs and Requirements), Table 3 has
identified a shortfall of 1,191 dwellings to be addressed in the Part 2 Plan and Bloor Homes are
committed to helping the Councils facilitate this requirement.
Bloor Homes are aware Glemsford Parish Council are preparing a draft Neighbourhood Plan with
a consultation anticipated soon after the May 2023 elections. Bloor Homes are monitoring the
progress of this and are keen to engage proactively with the Parish Council moving forward. Bloor
Homes are committed to contributing to the sustainable growth in Babergh and Mid Suffolk and
believe land to the west of Duffs Hill could play an important role in delivering much needed
sustainable development to Glemsford. Through engagement with the Local Plan and
Neighbourhood Plan process, it is envisaged the Site could be of significant benefit in meeting
Glemsfords development needs while providing significant community benefits to the local area.

Please see attached full rep.

Please see attached full rep.

It is also important to note that the Councils are currently working on the basis of only needing to deliver the local housing need requirement. The Councils have provided no evidence or breakdown of identified housing supply; indeed, stating that the supply identified in the JLP is not
the supply identified within the Councils Five Year Housing Land Supply Position Statements.

Comment cannot therefore be passed on the accuracy or soundness of the figures presented
within Table 3 until further evidence is provided.
Notwithstanding, the housing need requirement is a minimum, as confirmed by paragraph 11b)
of the Framework. The Councils should therefore be planning proactively above and beyond the
minimum requirement, to ensure the economic growth and infrastructure needs of the Districts
can be met. For instance, the parties’ site in Hadleigh has the ability to deliver sports, community
and commercial facilities alongside pedestrian and cycle enhancements and public open space,
the need for which has been established through extensive engagement with local stakeholders.
These facilities cannot be delivered without enabling housing development that can facilitate
delivery

The modified Table 3 states a shortfall for the District of Babergh, equating to 1,191 homes. The
parties consider it is this unmet need that justifies a requirement for Part 1 to plan effectively and
contain a policy that allows housing to meet this shortfall to be delivered – comments made in
respect of MM1 should be referred to.
It is also important to note that the Councils are currently working on the basis of only needing to
deliver the local housing need requirement. The Councils have provided no evidence or
breakdown of identified housing supply; indeed, stating that the supply identified in the JLP is not
the supply identified within the Councils Five Year Housing Land Supply Position Statements.
Comment cannot therefore be passed on the accuracy or soundness of the figures presented
within Table 3 until further evidence is provided.
Notwithstanding, the housing need requirement is a minimum, as confirmed by paragraph 11b)
of the Framework. The Councils should therefore be planning proactively above and beyond the
minimum requirement, to ensure the economic growth and infrastructure needs of the Districts
can be met. For instance, the parties’ site in Hadleigh has the ability to deliver sports, community
and commercial facilities alongside pedestrian and cycle enhancements and public open space,
the need for which has been established through extensive engagement with local stakeholders.
These facilities cannot be delivered without enabling housing development that can facilitate
delivery.

In addition, whilst at face value the Councils assertions that 85% of Babergh’s housing need can
be met through identified housing supply sounds positive, this does not appear to take into
account delivery of affordable housing. The Councils most recent Annual Monitoring Report
(December 2022) demonstrates that in Babergh affordable housing delivery has been significantly
below both the adopted and emerging policy requirement of 35% affordable housing provision for
5 of the reported 7 years – with only 17% delivery in 2021 / 22. This equates to a shortfall in
delivery of at least 135 affordable homes for the year 2021 / 22, with a backlog of around 272
dwellings based on data contained within the SHMA.
To meet this shortfall, once extrapolated over the Plan period, a significant uplift to the ‘shortfall
to be addressed in Part 2’ figure stated in Table 3 is likely to be needed. This uplift would need to
include not just the additional affordable homes, but also the associated open market homes that
would be required to deliver those affordable homes.
This is a further important reason for a breakdown of Table 3 to be provided, as without this
information more specific comment on shortfall cannot be provided.
Furthermore, it should be noted that the above affordable housing need figures are not area
specific, and certain areas might have higher demand. For instance, consultation with the Councils
Strategic Housing Team has indicated a high demand for affordable housing in Hadleigh, with
many on the housing register waiting list.
Therefore, while the District might be delivering sufficient housing overall, there is a hidden
demand for affordable housing that is not being met. This provides another important reason to
not constrain housing delivery in the intervening period between Part 1 and Part 2, and to plan
proactively beyond the minimum housing need figure currently stated in Part 1.

Suggested Remedy - Proposed Policy Wording - Local Plan Part 2
1.1. “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.
1.2. 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”

Suggested Remedy - Proposed Policy Wording - Local Plan Part 2
1.1. “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.
1.2. 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”
Main Modification Reference MM4 – Chapter 06 – Housing Needs & Requirements
Residual Housing Need over the Plan Period
1.3. Table 3 clearly identifies that in Babergh there is a 15% shortfall in the housing supply when compared to the minimum local housing need based requirement in the period to 2037. It is reiterated that this shortfall already takes off a separate provision for windfall housing amounting to 500 dwellings.
1.4. In short, Table 3 highlights that there is a residual need to plan for 1,191 dwellings, almost 3 years’ worth of housing requirement before the end of the plan period. This is not an insignificant amount and this highlights the importance of progressing Local Plan Part 2, particularly related to Babergh, immediately. New Proposed Policy Wording for the Local Plan Part 2 is suggested at paragraphs 2.9 and 2.10 of these representations.