MM9.

The existing Plan1 and new Plan 2 should change to reflect AONB priority protection and enhancement of the whole Shotley Peninsula with more Development located around the main towns of Ipswich, Sudbury and Hadleigh and the main roads of A12/A14 to meet the National and Local Housing needs.
All village housing/commercial development policies on the Peninsula need to be reviewed accordingly.
More emphasis of Peninsula development needs setting against the B1456 main long single access road with bends, poor visibility, pinch points, excess use volumes, village pedestrian crossings, emergency services timings all being dangerous and ecologically against pollution and efficiency.

The Plan does not reflect the DUTY IN LAW to protect and enhance AONB's and surrounding land on the Shotley Peninsula.
The Plan should include special protection/enhancement clauses for all peninsula AONB's and adjacent lands to stop wasting Developers and Land owners time and causing unnecessary local resident democratic process planning unrest.
To date the Planning Officer, Parish Council and local residents have objected to Peninsula AONB development but Councillors narrowly approved in Committee. Such Councillors did not ideally declare "predisposition" for or against but appeared by actions to be "predetermined" and not in accordance of the Councillor PROTOCOL's.

p39 08.04 Paragraph recognises existing village envelopes but excludes any extant planning applications outside the envelopes from coming forward. This comment is creating a window between JLP Part 1 and Part 2 for development that is only at initial stages of submission and not even at consultation or planning committee stage, to be progressed without consideration for the village envelope limits regardless of how controversial it may be in relation to a village expansion or without consideration of whether it is outside the envelope and outside any logical and reasonable Part 2 extension of the envelope. This we feel could be extremely damaging to small communities.

Clarification of revised Hadleigh settlement boundary or moratorium on further development until Part 2.

MM9 states “Whilst many of the extant planning permissions for new housing development are outside these [settlement] boundaries, this will not prevent them coming forward. A review of settlement boundaries on a comprehensive and consistent basis is a substantial undertaking and to carry out such work at the present time would be likely to significantly delay the adoption of the Plan (Part 1). The settlement boundaries will be reviewed as part of the Part 2 Plan but until that point it is considered that the existing boundaries, applied through policy SP03, will enable the Districts’ development needs to be met whilst also recognising the intrinsic character of the countryside.” For Hadleigh this seems to ignore the Inspectors’ planning review statement “…the vast majority of the plan area’s housing requirement…already provided for by existing dwelling completions, sites under construction, sites with full or outline planning permission, sites with a resolution to grant planning permission subject to s106 agreement…” as a) more dwellings are currently being built; b) CS6 is retained which allows for approx. another 250 dwellings; c) planning permission for a further 300 houses outside the existing settlement boundary (and outside CS6) is being sought. None of these are recognising the intrinsic character of the neighbouring countryside outside the extant settlement boundary. Are all of these approx. 700 extra dwellings still needed? A review of Hadleigh’s settlement boundary in Plan Part 2 will be shutting the stable door after the horse has bolted.

see submitted Representations document

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.

Please see attached document

In the supporting text to Sp03, it is said that the ‘existing settlement boundaries have been in place for some time and are well-understood by local communities, landowners and developers. Whilst many of the extant planning permissions for new housing development are outside these boundaries, this will not prevent development from coming forward’.
This is problematic because there is an acknowledgement that
(i) the boundaries have been in place for a long time and
(ii) the planning permissions have been outside of the settlement boundary anyway.
Whilst it can be recognised that the review of settlement boundaries is a substantial undertaking, it is worth noting that given the (i) time that has passed and (ii) the fact that development is already outside of the settlement boundary, it would be sensible to build in some flexibility to allow development to come forward if it is slightly outside the settlement boundary, but sustainably located.

Please see attached document.

Please see attached document.

We object to the proposed modification, which will result in the existing Settlement Boundaries being retained and not reviewed until the Part 2 Plan is produced, as it is not justified or effective. The existing boundaries are significantly out of date, and in many cases either do not reflect the situation on the ground at present, or will not reflect the situation once committed development is delivered. Unless the Part 2 Plan is progressed at pace, this will have knock-on implications for the consideration of proposals in accordance with the other policies in the Part 1 Plan (please also refer to our comments in respect of MM35).

We are concerned that settlement boundaries are unlikely to be amended if there is no requirement for allocations in Mid Suffolk. Accordingly, we consider that there is a strong need for the Plan to be amended by making reference to the need to make provision for housing allocations in Mid Suffolk in the Part 2 Local Plan.

MM9 (paragraphs 08.02 – 08.04):
The proposed replacement text states that a review of settlement boundaries on a comprehensive and consistent basis is a substantial undertaking and to carry out such work at the present time would be likely to significantly delay the adoption of the Plan (Part 1).
It is stated that the settlement boundaries will be reviewed as part of the Part 2 Plan, but until that point it is considered that the existing boundaries, applied through policy SP03, will enable the Districts’ development needs to be met whilst also recognising the intrinsic character of the countryside.
We are concerned that settlement boundaries are unlikely to be amended if there is no requirement for allocations in Mid Suffolk. Accordingly, we consider that there is a strong need for the Plan to be amended by making reference to the need to make provision for housing allocations in Mid Suffolk in the Part 2 Local Plan.
We believe this is necessary to ensure that a continuous pipeline of housing delivery is maintained throughout the plan period.
Our Client’s land at Haughley (east of Steggall Road) is one such suitable site.

Part 1 Plan should amend settlement boundaries to reflect the delivery of new completed developments since the existing Proposals Maps were adopted by the LPAs.

The Main Modifications need to identify key plan preparation milestones, in planning policy, to allow for effective monitoring over the forthcoming period. Given

see attached for full submission

This response principally relates to Main Modifications MM9.
It is acknowledged that the existing settlement boundaries, as applied in Policy SP03 will stand in
the short-medium term as set out in the Main Modifications Explanatory Note from the Inspectors.
Bloor Homes supports the intention to review the settlement boundaries as part of the Part 2 Plan
and recognises the additional time required to facilitate this key aspect of a successful Local Plan.
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 document.

Please see attached full document

Suggested Remedy: ““08.04 The existing settlement boundaries have been in place for some time and are well understood by local communities, landowners, and developers. Whilst many of the extant planning permissions for new housing development are outside these boundaries, this will not prevent them coming forward. A review of settlement boundaries on a comprehensive and consistent basis is a substantial undertaking and to carry out such work at the present time would be likely to significantly delay the adoption of the Plan (Part 1). The settlement boundaries will be reviewed as part of the Part 2 Plan as required by New Policy.

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 MM9 – Paragraphs 08.02 – 08.04 - The sustainable location of new development and Additional Modification AM23
1.3. It is noted that the tracked changes version of the Local Plan Part 1 proposes new paragraph 08.01 which cross refers to the amended text within the Introduction to the Joint Local Plan Part 1. It states: “Part 2 Plan is anticipated to address further issues including, a settlement hierarchy, the spatial housing strategy, the approach to Gypsy, Travellers and Travelling Showpeople, houseboat dwellers and any potential new allocations needed.” As highlighted earlier in these representations, it is suggested that new policy is inserted to the Local Plan Part 1 to be more committal about the content of the Local Plan Part 2.
1.4. It is also reiterated at paragraph 08.03 that “National policy also emphasises the importance of recognising the intrinsic character of the countryside. To this end the plan seeks to restrict most development outside defined settlement boundaries.”
1.5. It is clarified at proposed paragraph 08.04, included within the Main Modification Schedule, that the existing settlement boundaries have not been reviewed but will be under Part 2 Plan.
1.6. “08.04 The existing settlement boundaries have been in place for some time and are well understood by local communities, landowners, and developers. Whilst many of the extant planning permissions for new housing development are outside these boundaries, this will not prevent them coming forward. A review of settlement boundaries on a comprehensive and consistent basis is a substantial undertaking and to carry out such work at the present time would be likely to significantly delay the adoption of the Plan (Part 1). The settlement boundaries will be reviewed as part of the Part 2 Plan but until that point it is considered that the existing boundaries, applied through policy SP03, will enable the districts’ development needs to be met whilst also recognising the intrinsic character of the countryside.” (emphasis added by underlining).
1.7. Objection is raised to the final part of the paragraph as underlined. It is questioned how this statement can be made when proposed Table 3 clearly identifies that only 85% of the Babergh minimum housing requirement has been planned for to date. As a consequence there is a need to comprehensively review both the stated supply of housing and settlement boundaries, and consequentially identify suitable allocations, particularly within Babergh, to ensure sufficient provision is made to meet the minimum local housing need.
1.8. Suggested Remedy: ““08.04 The existing settlement boundaries have been in place for some time and are well understood by local communities, landowners, and developers. Whilst many of the extant planning permissions for new housing development are outside these boundaries, this will not prevent them coming forward. A review of settlement boundaries on a comprehensive and consistent basis is a substantial undertaking and to carry out such work at the present time would be likely to significantly delay the adoption of the Plan (Part 1). The settlement boundaries will be reviewed as part of the Part 2 Plan as required by New Policy. but until that point it is considered that the existing boundaries, applied through policy SP03, will enable the districts’ development needs to be met whilst also recognising the intrinsic character of the countryside.”
1.9. Please cross refer to suggested New Policy wording at paragraph 2.9 and 2.10 of these representations.