MM14.

The Parish Council supports the moving of the spatial distribution policy to Part 2.

Stradbroke Parish Council understands and supports the reasoning behind moving the housing spacial distribution to Part 2.

Please see attached document.

MM14 (paragraphs 09.02 – 09.12, Policy SP03 and Table 04): The proposed Main Modification seeks the deletion of text including references to the following: Since the 2001 Census, both Districts have delivered housing growth predominantly in the rural areas (approximately 60%). In recent years, both Babergh and Mid Suffolk Districts have experienced difficulty in meeting the identified housing targets for the respective areas and have had a limited number of allocated sites;
Specific minimum housing requirement figures for individual Neighbourhood Areas to assist the Neighbourhood Plan groups in the formation and progression of those plans; The transport corridors of the A12, A14, A140 and railway lines within the area have a strong effect upon market forces and demand for both housing and employment land; The Settlement Hierarchy, outstanding planning permissions, new homes and total new homes 2018-2037. We consider that the proposed deletion would be regrettable because it would result in the removal of important and useful information regarding the overall housing requirement and how it will be met.
Furthermore, we believe that it would remove flexibility in terms of demonstrating how any future delays to housing delivery might be rectified.

We understand that the most significant modification proposed to the draft Plan is the deletion of the spatial distribution of housing (MM14), and site allocations policies (MM93). This is because existing completions, sites under construction, sites with full or outline planning permission, sites with a resolution to grant planning permission subject to s106 agreement, and allocations in made Neighbourhood Plans provide for the vast majority of Babergh and Mid Suffolk’s housing requirements across the Plan period. Consequently, the current Joint Local Plan (JLP) has become the ‘Part 1' local plan. This will be followed by the preparation and adoption of a 'Part 2' local plan which will address spatial strategy matters and include housing allocations if necessary, to sufficiently provide for the housing requirements of the whole Plan period.
Although not specifically relevant to the Part 1 local plan, we would take this opportunity to remind you that we would expect Historic England to be consulted on all sites being considered for inclusion in the Part 2 Plan at the appropriate time, including those we have already provided formal comments for in order to take account of any material changes that may have occurred in the intervening time.
A case in point is the site at Brantham (LA053 - land south of Ipswich Road). Historic England has in recent months been engaging in pre-application discussions with the promoter of this site. In the interests of clarity, we thought it would be helpful to set out our current position.
As you are aware Historic England had previously objected in principle to the allocation of LA053 on the basis that development would result in harm to the significance of the Grade II* listed Church of St Michael and All Angels by introducing built development into its immediate/agricultural setting.
However, pre application discussions have since demonstrated that impacts on the significance of the church could be reduced to a moderate level of less than substantial harm by reducing the extent of built development. It is therefore feasible that the site could accommodate some built development subject to design considerations if it were to be reviewed as part of the preparation of the Part 2 Plan. Historic England will provide further advice regarding site-specific proposals as the Part 2 Plan evolves.
As you develop the Part 2 Plan spatial strategy, we would remind you that harm to the historic environment should be avoided in the first instance (remembering that significance can be harmed by development within the setting of heritage assets). An assessment of impacts upon townscape, historic landscape and historic assets should be included in any future assessment of route and infrastructure options. This may necessitate the preparation of additional Heritage Impact Assessments to understand the significance of assets and the likely impact of proposed development upon that significance.

We respectfully request that the Councils take into account our previously made comments and feedback from the Inspectors as part of preparation of Local Plan Part 2. We reserve the opportunity to provide further comments on the proposed spatial distribution in response to future consultations on the emerging Local Plan Part 2.

Main Modification Reference 14 – Housing
1.1. All wording relating to the proposed spatial distribution of housing is proposed to be removed as part of Main Modification 14.
1.2. Within earlier representations submitted to the Regulation 19 Local Plan Consultation, we highlighted concerns about the supporting evidence base for the Local Plan as submitted for Examination. These concerns specifically related to the spatial distribution as proposed within the Submitted Local Plan (Core Document A01).
1.3. Within previous representations we raised objection to the spatial distribution of housing because it was considered to be too heavily focused on urban sites in the Ipswich Fringe, and was not supported by a robust and accurate evidence base.
1.4. The letter from the Inspectors dated 9th December 2021 (Examination Document G09) highlights:
“Additionally, whilst your letter [Examination Document G08] proposes potentially appraising additional reasonable alternatives for the spatial distribution of housing, it is not clear how the preferred strategy would be determined and robustly justified against these. You will recall this was a key concern we raised at the Preliminary Matter 4 Hearing Session about the existing Sustainability Appraisal, site selection process and spatial strategy formulation…”
1.5. The letter also states that the Local Plan Part 2 is likely to include:
“A spatial distribution for any housing allocations included insofar as are necessary to provide flexibility and ensure that the plan period housing requirement can be met” (para 10)
1.6. We respectfully request that the Councils take into account our previously made comments and feedback from the Inspectors as part of preparation of Local Plan Part 2. We reserve the opportunity to provide further comments on the proposed spatial distribution in response to future consultations on the emerging Local Plan Part 2.
Removal of Table 04 – Minimum housing requirement for NP Areas (Babergh)
1.7. All wording relating to the proposed housing requirement for Neighbourhood Plan areas is proposed to be removed as part of Main Modification 14.
1.8. Within earlier representations submitted to the Regulation 19 Local Plan Consultation, we highlighted concerns about the supporting evidence base for the Local Plan as submitted for Examination. These concerns specifically related to the minimum housing requirement for Neighbourhood Plan area as proposed within the Submitted Local Plan (Core Document A01) as no evidence is provided as to how the proposed requirements were derived.
1.9. It is maintained that due to the sustainability credentials of Great Waldingfield that an appropriate amount of housing is directed to the settlement either through the Neighbourhood Plan or via allocation within the Local Plan Part 2.
1.10. It is noted that the emerging Great Waldingfield Neighbourhood Plan does not currently propose to identify any specific sites for residential allocation.
1.11. We respectfully request that the Councils take into account our previously made comments and feedback from the Inspectors as part of preparation of Local Plan Part 2. We reserve the opportunity to provide further comments on the proposed spatial distribution in response to future consultations on the emerging Local Plan Part 2.