MM10.

The councillors consider that the Newton Neighbourhood Development Plan, which Babergh adopted in March 2022, and Policy SP03 will work well together when the LPA considers planning applications for development outside the settlement boundary.

p61 SP05 para 2. Why has sensitivity been removed at the end of this paragraph. The strategic policy conditions against which the Sproughton Enterprise Park was approved, and against its development should progress required that there should be no adverse impact on the sensitivity of the residential amenity. This commercial estate, if developed irresponsibly and without compassion and understanding of the proximity and vulnerability of the residential community the other side of the river valley or the intended Local nature Reserve between has the potential to cause significant harm to nature and community and the removal of ‘sensitivity’ appears to open the door for exactly that. Our concerns are further raised by the change to SP05 Para 5(d) where ‘must be’ in relation to sensitivity is changed to ‘being’ removing an absolute obligation to sensitivity and our concerns regarding lack of commitment to protection of the Residential Amenity are further raised in that Residential amenity is also not referenced in this paragraph.

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.

Stradbroke Parish Council welcomes the reference to made Neighbourhood Plans in the revised policy wording.

see submitted Representations document

It would be appropriate for policy SP03 to include the above list (please see full submission text) so that the policy clearly sets out
what development is appropriate outside settlement boundaries. The SP03 list should also
include infill housing in accordance with policies in the Plan.

We object to MM10 policy SP03. Part 2 of the policy sets out that ‘Outside of the settlement
boundaries, development will normally only be permitted where the site is allocated for
development, or in a made Neighbourhood Plan, or is specifically permitted by other relevant
policies in this Plan, or it is in accordance with paragraph 80 of the NPPF (2021).’
This is not as clear as the Mid Suffolk Core Strategy 2008. The Core Strategy contains policy CS2
Development in the Countryside and Countryside Villages. This policy sets out a simple list of
development which is permitted outside settlement boundaries and a similar list would be
appropriate in the Local Plan.
Policy CS2 stated the following:
‘In the countryside development will be restricted to defined categories in accordance with other
Core Strategy policies. These will include:
• agriculture and forestry;
• the preservation of Listed Buildings;
• rural exception housing to include: -
agricultural workers dwellings
possible conversion of rural buildings
replacement dwellings
affordable housing on exception sites
sites for Gypsies and Travellers and travelling showpeople
• the extension of dwellings
Babergh and Mid Suffolk Joint Local Plan
Consultation on Proposed Main Modifications Paper Representations Form (2023) 4
• the reuse and adaptation of buildings for appropriate purposes, as defined elsewhere in
this document
• new-build employment generating proposals where there is a strategic, environmental or
operational justification
• recreation and tourism
• community services and facilities meeting a proven local need
• development by statutory undertakers or public utility providers
• flood protection
• renewable energy projects
• mineral extraction
• waste management facilities.’
It would be appropriate for policy SP03 to include the above list so that the policy clearly sets out
what development is appropriate outside settlement boundaries. The SP03 list should also
include infill housing in accordance with policies in the Plan.

Removal of "if necessary"

It is encouraging to see MM10 recognise that settlement boundaries will be reviewed, but object to the use of "if necessary". Table 3 clearly demonstrates that there is a shortfall in delivering the required number of plots to meet housing need. This should be consistently stated throughout Part 1.

CHANGES NECESSARY TO MAKE THE POLICY SOUND
Criterion 2 of Policy SP03 to be amended by;
Deleting the following text;
❖ ‘or in a made Neighbourhood Plan’

Inserting the following text;
❖ “allocated for development within a Neighbourhood Plan, or in accordance with housing policy criteria objectives within a Neighbourhood Plan”

Amended Criterion 2 of Policy SP03 to read as follows;
“Settlement boundaries are defined on the Policies Map. These boundaries were established in earlier Local Plans and Core Strategies and have not been reviewed as part of the Plan but are carried forward without change at the present time. The principle of development is established within settlement boundaries in accordance with the relevant policies of this Plan. Outside of the settlement boundaries, development will normally only be permitted where the site is allocated for development in this Plan, allocated for development within a Neighbourhood Plan, or in accordance with housing policy criteria objectives within a Neighbourhood Plan, or is specifically permitted by relevant policies of this Plan, or it is in accordance with paragraph 80 of the NPPF (2021)”

MM10 as currently drafted does not meet the following tests of soundness for examining plans as set out in the NPPF paragraph 35;

❖ B) Justified
❖ C) Effective
❖ D) Consistent with national policy

The last sentence of criterion 2. of the policy states that development outside settlement boundaries will normally only be permitted where the site is allocated for development, or in a made Neighbourhood Plan, or is specifically permitted by relevant policies of the Plan, or is in accordance with paragraph 80 of the NPPF (2021) which deals with ‘isolated homes’.

The approach fundamentally conflicts with policy objectives within Made Neighbourhood Plans across the Districts (including Whatfield Neighbourhood Plan Policy WHAT 4) which meets the housing needs of the village by permitting sites of up to 5 dwellings within and outside the defined settlement boundary, subject to stated criteria being met.

The Made Neighbourhood Plans within Babergh & Mid Suffolk (including Whatfield) form part of the statutory development plan for the area, and the suggested policy (as currently drafted) therefore conflicts with statutory policy objectives for meeting local housing needs at the village level.

Criterion 2 of Policy SP03 to be amended by;
Deleting the following text;
❖ ‘or in a made Neighbourhood Plan’
Inserting the following text;
❖ “allocated for development within a Neighbourhood Plan, or in accordance with housing policy criteria objectives within a Neighbourhood Plan”

Amended Criterion 2 of Policy SP03 to read as follows;
“Settlement boundaries are defined on the Policies Map. These boundaries were established in earlier Local Plans and Core Strategies and have not been reviewed as part of the Plan but are carried forward without change at the present time. The principle of development is established within settlement boundaries in accordance with the relevant policies of this Plan. Outside of the settlement boundaries, development will normally only be permitted where the site is allocated for development in this Plan, allocated for development within a Neighbourhood Plan, or in accordance with housing policy criteria objectives within a Neighbourhood Plan, or is specifically permitted by relevant policies of this Plan, or it is in accordance with paragraph 80 of the NPPF (2021)”

Persimmon do not agree with the statement 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)’. This is a task that can quite
reasonably be undertaken now, with the policy map updated to accurately reflect development
that has been built out or commenced. Persimmon request that this element of Part 1 is reviewed
and updated accordingly.

Policy SP03 previously related to the settlement hierarchy but is now deleted. Paragraph 01.08 of
the newly inserted introduction is acknowledged which confirms that the Part 2 Plan is likely to
include the settlement hierarchy and settlement boundaries. The use of ‘likely’ in this paragraph is
noted – this does not provide confidence and should either be deleted, or clarification should be
provided by the Councils on why certainty cannot be given at this stage about the scope of Part 2.
The settlement hierarchy set out in the submission version of the JLP was supported by Persimmon
as being an appropriate and suitable reflection of the sustainability of settlements within the
Districts – drawing in particular attention towards the designation of Capel St Mary as a ‘Core
Village’ and of Hadleigh as a ‘Babergh Market Town and Urban Area’. The sustainability of these
settlements and their ability to support development has been further established through the
development management process, and the granting of planning permission for new housing.
The settlement hierarchy plays an important role in the appropriate spatial distribution of housing
across the settlement hierarchy. As the evidence is already available, Persimmon consider the
settlement hierarchy should be retained within Part 1 to ensure the sustainability of settlements
is appropriately reflected.
With respect to settlement boundaries. Persimmon considers Policy SP03 as modified is not
effective. The new paragraph 08.01 is noted, which states that the existing settlement boundaries
‘have been in place for some time’ and will not be amended by Part 1 despite ‘many of the extant
planning permissions for new housing development are outside of these boundaries’. Persimmon object to the approach that is currently suggested of not reviewing settlement boundaries at all
until Part 2.
Fixing settlement boundaries as they are currently would mean the boundaries would not
accurately reflect the changes to settlement boundaries that have taken place in recent years as a
result of extant planning permissions, and indeed development taking place in accordance with
those planning permissions. Taking as an example the market town of Hadleigh, the existing
settlement boundaries do not include significant housing development to the east (around Ellen
Aldous Avenue) that has been constructed by Persimmon. The settlement boundaries also do not
include a further phase of development in this area that Persimmon has recently been granted
planning permission for.
This is just one example of the datedness of the existing settlement boundaries. Persimmon
therefore posit that there is a clear need for settlement boundaries to be updated now if planning
applications are to be suitably assessed against the policies contained in Part 1. Persimmon do not
agree with the statement 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)’. This is a task that can quite
reasonably be undertaken now, with the policy map updated to accurately reflect development
that has been built out or commenced. Persimmon request that this element of Part 1 is reviewed
and updated accordingly.

Pigeon is generally supportive of the changes to this policy, which identifies where new development will be allowed until the forthcoming Part 2 Plan is adopted. In order to make the policy sound, Pigeon is of the view that reference should be made within the policy to support for new housing development where it is in a sustainable location, such as the Ipswich Fringe and where it has community support, which is in line with the requirements of policy LP07 of the JLP. Subject to these changes, Pigeon is fully supportive of this policy.

Pigeon is generally supportive of the changes to this policy, which identifies where new development will be allowed until the forthcoming Part 2 Plan is adopted. In order to make the policy sound, Pigeon is of the view that reference should be made within the policy to support for new housing development where it is in a sustainable location, such as the Ipswich Fringe and where it has community support, which is in line with the requirements of policy LP07 of the JLP. Subject to these changes, Pigeon is fully supportive of this policy.

Please see attached document

On behalf of our clients, George Durrant & Sons welcomes this simplified policy. Our only caution would be that it is reliant upon extremely outdated settlement boundary plans, though these are due for review and amendment in the coming years.

Having accepted the premise that Thurston is a core village, the Parish Council is supportive of the scale of development that is being promoted under Policy SP03 in that new housing development is to come forward through extant planning permissions, allocations in the made NDP and windfall development which is in accordane with the relevant policies of the Draft Local Plan. It is understood that further allocations may come forth in Part 2 of the Plan which will be consulted upon at a later stage.
All such growth should take into account the capacity of physical and social infrastructure.

On policy SP03, (2) in particular does not need be to cut out – it is locating development in Ipswich, market towns and core villages. Which are sustainable locations.

Please see attached document.

‘In the countryside development will be restricted to defined categories in accordance with other Core Strategy policies. These will include:
• agriculture and forestry;
• the preservation of Listed Buildings;
• rural exception housing to include: -
agricultural workers dwellings
possible conversion of rural buildings
replacement dwellings
affordable housing on exception sites
sites for Gypsies and Travellers and travelling showpeople
• the extension of dwellings
• the reuse and adaptation of buildings for appropriate purposes, as defined elsewhere in this document
• new-build employment generating proposals where there is a strategic, environmental or operational justification
• recreation and tourism
• community services and facilities meeting a proven local need
• development by statutory undertakers or public utility providers
• flood protection
• renewable energy projects
• mineral extraction
• waste management facilities.’

It would be appropriate for policy SP03 to include the above list so that the policy clearly sets out what development is appropriate outside settlement boundaries. The SP03 list should also include infill housing in accordance with policies in the Plan.

We object to MM10 policy SP03. Part 2 of the policy sets out that ‘Outside of the settlement boundaries, development will normally only be permitted where the site is allocated for development, or in a made Neighbourhood Plan, or is specifically permitted by other relevant policies in this Plan, or it is in accordance with paragraph 80 of the NPPF (2021).’
This is not as clear as the Mid Suffolk Core Strategy 2008. The Core Strategy contains policy CS2 Development in the Countryside and Countryside Villages. This policy sets out a simple list of development which is permitted outside settlement boundaries and a similar list would be appropriate in the Local Plan.
Policy CS2 stated the following:
‘In the countryside development will be restricted to defined categories in accordance with other Core Strategy policies. These will include:
• agriculture and forestry;
• the preservation of Listed Buildings;
• rural exception housing to include: -
agricultural workers dwellings
possible conversion of rural buildings
replacement dwellings
affordable housing on exception sites
sites for Gypsies and Travellers and travelling showpeople
• the extension of dwellings
• the reuse and adaptation of buildings for appropriate purposes, as defined elsewhere in this document
• new-build employment generating proposals where there is a strategic, environmental or operational justification
• recreation and tourism
• community services and facilities meeting a proven local need
• development by statutory undertakers or public utility providers
• flood protection
• renewable energy projects
• mineral extraction
• waste management facilities.’
It would be appropriate for policy SP03 to include the above list so that the policy clearly sets out what development is appropriate outside settlement boundaries. The SP03 list should also include infill housing in accordance with policies in the Plan.

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.

MM10 (Policy SP03 – The Sustainable Location of New Development):

The proposed policy wording states that settlement boundaries (as defined on the Policies Map) were established in earlier Local Plans and Core Strategies and have not been reviewed as part of the Plan, but are carried forward without change at the present time.

It specifies that the principle of development is established within settlement boundaries in accordance with the relevant policies of this Plan. Outside of the settlement boundaries, development will normally only be permitted where the site is allocated for development, or in a made Neighbourhood Plan, or is specifically permitted by other relevant policies of this Plan, or it is in accordance with paragraph 80 of the NPPF (2021).

Consequently, it is evident that there will be limited opportunities to develop outside the defined settlement boundaries.

Whilst reference is made to the fact that settlement boundaries will be reviewed, and if necessary revised, as part of the preparation of the Part 2 Plan, we remain 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.

Our Client’s land at Haughley (east of Steggall Road) is one such suitable site.

This response principally relates to Main Modifications MM10.
Glemsford was previously identified as a Core Village (a focus area for development) under Policy
SP03 (Settlement Hierarchy) however it is noted the intention is to remove this policy from the
Part 1 Local Plan. Under Policy SP04 (Housing Spatial Distribution), Glemsford was required to
provide a minimum of 37 new homes across the plan period, however it is noted that the proposal
is to also remove this Policy from the Part 1 Local Plan. Bloor Homes supports this decision. It is
recognised that in order to make the Plan sound and robust, a more fundamental review is
required to reassess the housing allocations in all tiers of settlement. Bloor Homes would also
support appraising additional reasonable alternatives for the spatial distribution of housing as set
out in the Councils’ letter dated 18th November 2021.
As set out in our response to MM9, 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 rep.

The representations made to MM1 and MM4 should be referred to, as the discussion in those
representations makes clear why Policy SP03 as modified is not fit for purpose. The policy is not
sufficient at providing for new development to be delivered that does not already benefit from
extant planning permissions or allocation in Neighbourhood Plans. Reference is made to windfall
development in Policy SP03, however Policy LP01 (as modified) confirms that only infill
development is planned for outside of settlement boundaries. This is not sufficient to allow for
development of the scale needed to sustain economic growth, provide for and support local
infrastructure development and meet affordable housing needs.
Policy SP03 needs to include confirmation of the settlements that are considered to be sustainable
such as the market town of Hadleigh. The parties Matter 4 Hearing Statement should be referred
to for discussion on the sustainability of Hadleigh and its suitability for supporting additional
growth.
Policy SP03 should also allow for development to be delivered adjacent to the sustainable
settlement boundaries , where such development is justified and appropriate when considered
against other relevant policies in the JLP and can clearly meet existing needs. This approach to
clarifying spatial distribution of future development will allow for the needs discussed in
representations to MM1 and MM4 to be met now, rather than delayed for the number of years it
is likely to take for Part 2 of the JLP to be prepared and adopted. There is also of course no certainty
that Part 2 will ever be adopted.

Main Modification Reference 10 – Policy SP03
1.1. Support is given to the proposed inclusion of additional text at Policy SP03 “Settlement boundaries will be reviewed, and if necessary revised, as part of the preparation of the Part 2 Plan.”