MM5.

For the avoidance of doubt it would be better to state that the dwellings per annumn noted in 1. and 2. are averages since the number of completions/year is variable and may or may not be the number described.

Stradbroke Parish Council welcomes the inclusion of reference to local housing needs surveys.

Add in the requirement for the Plan Period to be extended.

The plan covers the period 2018-2037 (19 years) but likely to be adopted in 2023 (giving 14 years). The NPPF requires plans to ‘look ahead over a minimum of 15 years from adoption’ (para.22). We recommend that this is recognised in the supporting text of Part 1 to be particularly of relevance for Part 2, with Part 2 addressing an extension of the Plan Period. We recognise that national policy may change, which can be dealt with at that time if so. As drafted, Part 2 only covers the same period as Part 1, which we consider could be found unsound at its examination and should be avoided.

Therefore, Pigeon continues to advocate that Policy SP01 should be corrected so that the minimum housing need is for at least 19,175 new homes. In addition to this, an uplift of 20% should be applied to this housing requirement to enable the Districts to address their key social issues and maximise economic growth including:
• To meet the identified need for market and the acute need for affordable housing;
• To begin to correct the imbalance between jobs growth and the number of homes delivered across the Districts in recent years and stem the number of people out-commuting to other places of work;
• To have a greater degree of flexibility in the delivery of sites; and
• To account for any future unforeseen changes in demographic behaviour or changing circumstances outside the control of the Councils.

Chapter 2 of the Modified Joint Local Plan (JLP) sets out the Key Social Issues for the District, which for completeness these are set out below:
1. Delivering Housing;
2. Achieving an Uplift in Delivery;
3. A Growing & Ageing Population; and
4. High Levels of Housing Need and a Poor Affordability

Policy SP01 is the means for the Councils to address these 4 key issues during the next Plan period up until 2037. It is an opportunity for the Councils to demonstrate that this Plan can deliver enough housing for their residents which provides appropriate levels of market and affordable homes and begins to address the historical imbalance between jobs growth and the number of homes which is perpetuating the large number of residents who out-commute to jobs outside the Districts.

The standard method provides the minimum local housing need, which is not a ceiling, but a minimum requirement. It should be a starting point on which to significantly boost the supply of housing for the Plan area as required by the Framework and in order to address the 4 key social issues for the Districts.

As part of their previous representations, Pigeon provided an assessment (Appendix 1) to demonstrate that the standard method had been misapplied in the JLP and as such does not provide for the minimum homes necessary to accord with national policy. The figure which arose from the standard method at the 2018 base-date of the Plan period produces a minimum need for at least 19,175 new homes rather than the 18,069 identified in the JLP. This comprises of 8,312 in Babergh and 11,115 in Mid Suffolk.

This representation will not rehearse these points again, but in failing to correctly calculate the correct housing need requirement the policy does not plan positively for the housing needs of Babergh and Mid Suffolk. As set out in Pigeon’s representation to Policy SP02 and relevant to this Policy, the current housing requirement within the JLP does not enable sufficient levels of market and affordable homes to be delivered within the Districts to meet their identified housing need. Pigeon is disappointed that this policy has not been modified to incorporate the correctly calculated housing need requirement and request that this is examined further by the Councils and Inspectors.

Furthermore, the Councils have identified that historically they have experienced difficulties with housing delivery rates. Whilst both Councils are improving in this area at present, for future circumstances outside of their control, delivery rates could decline again during the Plan period. Therefore, it would be sensible for the Councils to plan for some level of contingency in order to ensure the minimum housing need is achieved. Within the Regulation 19 Plan, there was a 20% buffer included within the Councils housing supply, but now that the site allocations have been removed from Part 1 of the Plan, no compensatory buffer has been applied, suggesting it is no longer required.

As set out at Section 2 of this Statement, the modified Sustainability Appraisal does not identify that an uplift in the housing requirement by 20% would result in significant negative impacts on the Districts beyond the 2020 Standard Method requirement. No justification has been provided within the Plan or evidence base to explain why the Councils have not considered an uplift in their housing requirement, particularly given the removal of the site allocations. Within the now deleted paragraph 06.07 of the JLP, the Councils identify that a buffer ‘will give greater confidence to meeting delivery targets and also to communities knowing that land for future needs is identified rather than unknown’. Pigeon would suggest that these points are equally valid and critically important to the modified Plan, in terms of flexibility, and as such, a contingency buffer of 20% should be applied.

Therefore, Pigeon continues to advocate that Policy SP01 should be corrected so that the minimum housing need is for at least 19,175 new homes. In addition to this, an uplift of 20% should be applied to this housing requirement to enable the Districts to address their key social issues and maximise economic growth including:
• To meet the identified need for market and the acute need for affordable housing;
• To begin to correct the imbalance between jobs growth and the number of homes delivered across the Districts in recent years and stem the number of people out-commuting to other places of work;
• To have a greater degree of flexibility in the delivery of sites; and
• To account for any future unforeseen changes in demographic behaviour or changing circumstances outside the control of the Councils.

Lavenham Parish Council is disappointed that the contribution of affordable housing on brownfield sites has been reduced to 25% and we would strongly prefer it to remain at 35% for all major developments (as defined by the NPPF).

There is an established need for affordable dwellings in this community. This is demonstrated in the submission version of LNP2 which promotes development within its proposed settlement boundary, but also looks to seriously restrict any development outside of its boundary. Therefore, developments are more likely to be on brownfield rather than greenfield sites and the reduction in the percentage of affordable homes required is unhelpful and arguably regressive.

Please see attached document for proposed changes.

Please see attached document.

Please see attached document.

We think the policy should be clear in its intentions, and therefore clearly signpost the housing need surveys it is referring to as well as the mechanisms that the Councils will rely on to update or revise it over the plan period, being careful to only ensure that policy requirements are tested fully in accordance with the regulations for preparing Local Plans and the tests of soundness as detailed in the National Planning Policy Framework.

Please see attached document.

We believe that Policy SP01 needs to be amended in order to add reference to these two important considerations given that the need for affordable housing provision is acute and not all allocated sites or sites with planning permission will actually come forward for delivery.

MM5 (Policy SP01 – Housing Needs):
It is important to note that Policy SP01 (Housing Needs) 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.
We believe that Policy SP01 needs to be amended in order to add reference to these two important considerations given that the need for affordable housing provision is acute and not all allocated sites or sites with planning permission will actually come forward for delivery.

However, criterion 3 and the supporting text for Policy SP01 should be amended to clarify that up
to date evidence of market demand provided by developers will also be accepted as important
supporting evidence to inform the mix, type and size of new homes.

The supporting text to Policy SP01 (para. 06.05) notes that the Councils are not required to meet
any unmet need from neighbouring authorities and as such this is not accounted for in the housing
requirement that has been identified. The parties maintain that this is an imprudent approach that
does not build in flexibility and future-proofing of the housing requirement. Indeed, the adopted
Ipswich Local Plan 2022 which covers the period up to 2031, notes that it is restricted and will
require a cross-boundary approach to housing delivery to be taken to meet future need. To ensure
a justified and sustainable approach is taken to planning housing delivery, the needs of
neighbouring authorities should be accounted for now.
The modification to Policy SP01 to include the new criterion 3 is welcomed, as the provision of up
to date evidence of local need is important, particularly given the Strategic Housing Market
Assessment (EH05) was last updated in 2019.
However, criterion 3 and the supporting text for Policy SP01 should be amended to clarify that up
to date evidence of market demand provided by developers will also be accepted as important
supporting evidence to inform the mix, type and size of new homes. Evidence provided by
developers is key to ensuring all relevant factors are taken into account when determining housing
mix, including factors such as site availability, sales information, local market signals and sitespecific opportunities and constraints. Previous representations made on this policy should be
referred to for discussion on this matter.

Please see attached full document.

We think the policy should be clear in its intentions, and therefore clearly signpost the housing need surveys it is referring to as well as the mechanisms that the Councils will rely on to update or revise it over the plan period, being careful to only ensure that policy requirements are tested fully in accordance with the regulations for preparing Local Plans and the tests of soundness as detailed in the National Planning Policy Framework.

Please see attached full document.

Please see attached full document.

Please see attached full document

Please see attached full document

We think the policy should be clear in its intentions, and therefore clearly signpost the housing need surveys it is referring to as well as the mechanisms that the Councils will rely on to update or revise it over the plan period, being careful to only ensure that policy requirements are tested fully in accordance with the regulations for preparing Local Plans and the tests of soundness as detailed in the National Planning Policy Framework.

Please see attached full document

Suggested amendment to Policy SP01:
“1. In Babergh District the Joint Local Plan (Parts 1 and 2) will deliver a minimum of 7,904 net additional dwellings (416 dwellings per annum) over the plan period.
2. In Mid Suffolk District the Joint Local Plan (Parts 1 and 2) will deliver a minimum of 10,165 net additional dwellings (535 dwellings per annum) over the plan period.
3. Across the Plan area the mix, type and size of new housing development should be informed by the relevant District needs assessment, or any local housing needs surveys where relevant.”

Main Modification Reference MM5 – Policy SP01 – Housing Needs
1.1. Support is given to the proposed amendments to Policy SP01 in so far as specific reference is made to both Part 1 and Part 2 of the Local Plan however it is suggested that the Policy should be amended as follows to be more committal about delivering the minimum housing requirement within Babergh and Mid Suffolk.
1.2. Suggested amendment to Policy SP01:
“1. In Babergh District the Joint Local Plan (Parts 1 and 2) will seek to deliver a minimum of 7,904 net additional dwellings (416 dwellings per annum) over the plan period.
2. In Mid Suffolk District the Joint Local Plan (Parts 1 and 2) will seek to deliver a minimum of 10,165 net additional dwellings (535 dwellings per annum) over the plan period.
3. Across the Plan area the mix, type and size of new housing development should be informed by the relevant District needs assessment, or any local housing needs surveys where relevant."