MM22.

p65 SP07 Par2 Why has a commitment to ensuring that Historic, recreational and landscape tourism will enhancing heritage, environment and landscape been removed?
Para 3 Why has a commitment to climate change measures for such development been removed?
Para 4 Not sure why compliance with other policies is removed unless that is considered a given anyway.

Identify and designate strategic tourism sites.
Redo wording to make less ambiguous and in line with the NPPF.

Objection to policy SP07-tourism.
The policy states:
1. New sustainable tourism development that supports the tourism role of the settlements
across Babergh and Mid Suffolk will be encouraged where appropriate to the scale,
character and nature of their locality.
2. Historic, recreational and landscape-based tourism proposals that demonstrate protection
of the historic and natural environment will be supported.
The objection to the policy as proposed is as follows.
Firstly, part one of the policy is unquantifiable. What is meant by “The tourism role of the
settlements“ Not all settlements in the district will have a tourism role. Secondly, the second
paragraph of the policy supports “landscape-based tourism”. Landscape based tourism is likely to
be in the countryside, not within a settlement. Furthermore, the policy does not accord with
paragraph 84 (c) of the National Planning Policy Framework (NPPF). It states that planning policies
should enable sustainable rural tourism leisure developments which respect the character of the
countryside. There is no requirement for tourism developments in the countryside to support a
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role of a particular settlement. Furthermore, paragraph 84 (c) of the NPPF whilst requiring
development to respect the character of the countryside, does not include a consideration of scale.
Policy SP07 does not explain what it means by scale. It is ambiguous.
In addition, whilst policy SP07 supports “historic, recreational and landscape-based tourism
proposals”. It does not take into account other tourism and leisure activities such as water based
recreation.
It is also the case that there are long established businesses in the countryside which provide
significant benefits to the local rural economy and which should be identified and designated as
strategic tourism sites. Stonham Barns is one such site.

Objection to Policy LP12-tourism and leisure
The first objection relates to criteria (c) of the policy which states that “new tourism and leisure
facilities or improvement/extensions to existing facilities must be accessible by public transport
and facilitates walking and cycling, whilst providing appropriate parking and access and ensuring
the associated traffic movement would not compromise highway safety. “
Existing tourist attractions which are in the countryside are not accessible by public transport.
This is because Mid Suffolk and Babergh has only a handful of railway stations and very limited bus
services. This part of the policy is contrary to the NPPF. Paragraph 84 (c) of the NPPF states that
planning policies should enable sustainable rural tourism and leisure developments which respect
the character of the countryside. It does not require existing or new sites to be accessible by public
transport.
Furthermore, paragraph 85 states in part “planning policies and decisions should recognise that
sites to meet local business and community needs in rural areas may have to be found adjacent to
or beyond existing settlements, and in locations that are not well served by public transport”
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My clients also object to criteria (e) and (f) of paragraph 1 of policy LP12. First of all, criteria (e)
doesn't make sense. Secondly, criteria (f) is unreasonable and goes far beyond what is required by
the NPPF.
Criteria (f) is unreasonable for many reasons. Firstly, all forms of development results in impact
therefore it will be impossible to avoid impacts. Secondly, the requirement to make impacts
insignificant on the local ecology biodiversity trees and hedgerowsshould be quantified. Otherwise
it is vague and ambiguous. And, the term “as a last resort” is also vague and ambiguous.
The objection also relates to the second paragraph of policy LP12. Criteria (b) of the second
paragraph requires proposalsfor tourism and leisure outside of settlement boundaries to “improve
accessibility for existing places which are not well served by public transport”. There is no such
requirement for development in rural areas to do so within any of the policies of the NPPF. It
implies that developments in the countryside are expected to provide their own bus service to and
from other settlements. This would be completely unreasonable.

Objection to policy LP13
The first paragraph of the policy states:
1. Outside settlement boundaries, applications for new tourist accommodation will be
considered on the exceptional basis. In addition, applications must accord with other
policies and the plan and:
(a) Demonstrate an overriding business need to be in that location;
(b) Be sympathetic to the character of the area; and,
(c) Be accessible by a range of transport modes.
First of all, there is no justification to restrict tourism accommodation in the countryside in this
way. The policy as worded is contrary to the National Planning Policy Framework. Paragraph 85 of
the NPPF confirms that planning policies should recognise that sites to meet local business and
community needs in rural areas may have to be found adjacent to or beyond existing settlements,
and in locations that are not well served by public transport.
The attraction of many rural tourist sites is the very fact that they are in the countryside and away
from the noise, hustle and bustle of urban centres. Their tranquil, quiet and countryside location
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is their main attraction, a business which is proposing a countryside retreat by definition needs to
be located in the countryside.
The NPPF does not require tourist accommodation proposals in the countryside to demonstrate
an overriding business need to be in that location. Nor does the NPPF require rural tourism
developments to be accessible by a range of transport modes.
On this point it is important to refer to paragraph 105 of the NPPF which states in part “significant
development should be focused on locations which are or can be made sustainable”. As proposed,
policy LP13 does not distinguish between significant or small scale developments.
Furthermore, paragraph 105 of the NPPF goes on to state “However, opportunities to maximise
sustainable transport solutions will vary between urban and rural areas and this should be taken
into account in both plan making and decision making”. Policy LP13 does not take this into account.
Paragraph 2 of policy LP13 is unnecessary.
Paragraph 3 of policy LP13 is also unnecessary. All it does is repeat the three objectives of
sustainable as described at paragraph 8 of the NPPF

The policy states:
1. New sustainable tourism development that supports the tourism role of the settlements across Babergh and Mid Suffolk will be encouraged where appropriate to the scale, character and nature of their locality.
2. Historic, recreational and landscape-based tourism proposals that demonstrate protection of the historic and natural environment will be supported.
The objection to the policy as proposed is as follows.
Firstly, part one of the policy is unquantifiable. What is meant by “The tourism role of the settlements“ Not all settlements in the district will have a tourism role. Secondly, the second paragraph of the policy supports “landscape-based tourism”. Landscape based tourism is likely to be in the countryside, not within a settlement. Furthermore, the policy does not accord with paragraph 84 (c) of the National Planning Policy Framework (NPPF). It states that planning policies should enable sustainable rural tourism leisure developments which respect the character of the countryside. There is no requirement for tourism developments in the countryside to support a role of a particular settlement. Furthermore, paragraph 84 (c) of the NPPF whilst requiring development to respect the character of the countryside, does not include a consideration of scale. Policy SP07 does not explain what it means by scale. It is ambiguous.
In addition, whilst policy SP07 supports “historic, recreational and landscape-based tourism proposals”. It does not take into account other tourism and leisure activities such as water based recreation.
It is also the case that there are long established businesses in the countryside which provide significant benefits to the local rural economy and which should be identified and designated as strategic tourism sites.

In summary, whilst a number of main modifications are welcomed and should be taken forward
to ensure Policy LP18 is sound, further changes are also necessary to ensure consistency with
national policy. This includes revising the wording from ‘supporting’ non-major proposals, to
‘restricting’ these to those which meet all of the criteria, along with requiring the submission of
an LVIA for any proposal within or affecting an AONB to ensure proposals are thoroughly
assessed. Amendments are also required to Policy LP07 to ensure that any tourism development
within the AONB is also directed to the requirements of Policy LP18.