MM28.
Object
Joint Local Plan Main Modifications
Representation ID: 22452
Received: 25/04/2023
Respondent: Mr Alan Lewis
Legally compliant? Yes
Sound? No
The acceptance of windfall infill developments of utpo 20% or more of an isolated hamlet will inevitably lead to the consolidation of hamlets into nearby settlements over time, particularily as the nearby settlement's boundary may change over time.
The policy should be changed to reflect the previous wording such that proposals may be acceptable, but the impact of any proposals would be considered on a case by case basis.
The acceptance of windfall infill developments of utpo 20% or more of an isolated hamlet will inevitably lead to the consolidation of hamlets into nearby settlements over time, particularily as the nearby settlement's boundary may change over time.
Object
Joint Local Plan Main Modifications
Representation ID: 22470
Received: 27/04/2023
Respondent: Sproughton Parish Council
Legally compliant? Not specified
Sound? Not specified
Hamlets, and Clusters broadly the same as a nucleus of 10 or more houses so broadly policy for same purpose but we do think that changing the approval commitment by the LPA from ‘may be’ acceptable to ‘will be’ acceptable is reckless especially as the conditions for suitability are significantly reduced including consideration of cumulative impact which may become an issue if several applications come forward in a one sparsely populated area.
p79 LP01 Hamlets, and Clusters broadly the same as a nucleus of 10 or more houses so broadly policy for same purpose but we do think that changing the approval commitment by the LPA from ‘may be’ acceptable to ‘will be’ acceptable is reckless especially as the conditions for suitability are significantly reduced including consideration of cumulative impact which may become an issue if several applications come forward in a one sparsely populated area.
Support
Joint Local Plan Main Modifications
Representation ID: 22564
Received: 02/05/2023
Respondent: Stradbroke Parish Council
Stradbroke Parish Council supports the revised wording of the policy and the clarity the amendments bring.
Stradbroke Parish Council supports the revised wording of the policy and the clarity the amendments bring.
Support
Joint Local Plan Main Modifications
Representation ID: 22577
Received: 02/05/2023
Respondent: AONB Team
No further change proposed.
No further change proposed.
Object
Joint Local Plan Main Modifications
Representation ID: 22659
Received: 03/05/2023
Respondent: Pigeon Investment Management Ltd
Agent: Turley
Legally compliant? Yes
Sound? No
Pigeon remains supportive of this modified policy as it allows for windfall development outside of settlement boundaries. However, in order to be considered sound, this policy needs to positively encourage opportunities for self and custom build housing in such instances where it accords with Policy LP08 and that a cap on development size is not ‘justified’ and should be considered on a site-by-site basis. Therefore, Pigeon continues to raise an objection with the Policy as currently modified because it is not ‘justified’ or ‘positively prepared’.
See full representation
Pigeon welcomes the modification to this policy which now allows for windfall infill development outside settlement boundaries where there is ‘a nucleus of at least 10 well related dwellings’. This change to the policy means that it is more positively worded to enable small scale development where it would be well related to existing development and would be sustainable. This is in accordance with paragraph 79 of the NPPF (2021) which requires ‘planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services’.
Pigeon would question how ‘a nucleus of at least 10 well related dwellings’ will be assessed within the context of a planning application by Officers because whether they are ‘well related’ is a subjective matter. As a result, this could lead to some ambiguity and differences in the application of the policy by the Councils across the Districts.
Whilst the policy has been amended to remove reference to the type of dwellings that might be appropriate as windfall infill development, it retains reference to it ‘usually being for one or two dwellings’. Pigeon is of the view that the wording from policy LP07 should be reflected in this policy, which specifies that the scheme should be proportionate in size to the settlement it relates to. This is because the settlement could have more than 10 related dwellings, and as such, could therefore support a larger cumulative windfall infill development of more than just one or two dwellings.
Pigeon still considers that this policy could be further modified to positively encourage opportunities for self-build and custom-build housing in such locations where the scheme accords with other relevant development plan policies such as LP08 (Self Build and Custom Build).
Pigeon continues to support the criteria-based approach as set out in the policy, but that in order to make the policy justified, it should be explicit and allow opportunities for self-build and custom-build properties in these locations. Such properties can make a meaningful contribution to the supply of housing and would assist the Council in meeting its housing need for the Districts and its responsibilities under the Self Build and Custom Build Act 2015.
Object
Joint Local Plan Main Modifications
Representation ID: 22699
Received: 03/05/2023
Respondent: Artisan PPS Ltd
Legally compliant? Not specified
Sound? Not specified
• There is no definition of a 'nucleus of at least 10 well related dwellings'. East Suffolk had to adopt a 42-page SPD to explain a similar phrase. What is a nucleus? What is well related? Can there be a nucleus of dwellings that are not well related such that it doesn't qualify under this policy? Can there be well related dwellings that aren't a nucleus such that it doesn't qualify under this policy?
Criteria for 'well-related' could be based on the approach set out in CS20 of the Babergh Core Strategy (2014):
Please see attached document
Object
Joint Local Plan Main Modifications
Representation ID: 22700
Received: 03/05/2023
Respondent: Artisan PPS Ltd
Legally compliant? Not specified
Sound? Not specified
In paragraph c), the phrase 'would usually be for only one or two dwellings' is unnecessarily imprecise. The supporting text suggests in some circumstances a terrace of three dwellings might be more appropriate. Accordingly, there needs to be more clarity in the policy itself as to when three might be more appropriate. What criteria are considered when trying to determine whether a development complies with this paragraph of the policy?
Please see attached document
Support
Joint Local Plan Main Modifications
Representation ID: 22722
Received: 03/05/2023
Respondent: George Durrant & Sons Ltd
On behalf of our clients, George Durrant & Sons welcomes this simplified policy. The removal of the reference to 'clusters', and the straightforward definition of a nucleus (i.e. 10 dwellings) should avoid the problems experienced in East Suffolk with their comparable policy. We hope that this policy will provide opportunities for sustainable infill development across the district.
On behalf of our clients, George Durrant & Sons welcomes this simplified policy. The removal of the reference to 'clusters', and the straightforward definition of a nucleus (i.e. 10 dwellings) should avoid the problems experienced in East Suffolk with their comparable policy. We hope that this policy will provide opportunities for sustainable infill development across the district.
Object
Joint Local Plan Main Modifications
Representation ID: 22764
Received: 03/05/2023
Respondent: . Christchurch Land & Estates (Elmswell south) Ltd
Agent: Richard Brown Planning
Legally compliant? Not specified
Sound? Not specified
It is said that there is a possibility for sustainable windfall development; why does it have to be infill? particularly where LP01 was originally directed at hamlets and clusters of development in the countryside – that seems to be different to ‘infill’.
•Therefore, in our view, ‘infill’ being added is unnecessary.
•10 dwellings? Is that an arbitrary number? Likely not been assessed as part of the SA as it is an addition.
•Not helpful to have ‘one or two’ dwellings. It might be that more is more appropriate. Also not likely been subject to the SA
Therefore, in our view, ‘infill’ being added is unnecessary.
•10 dwellings? Is that an arbitrary number? Likely not been assessed as part of the SA as it is an addition.
•Not helpful to have ‘one or two’ dwellings. It might be that more is more appropriate. Also not likely been subject to the SA
It is said that there is a possibility for sustainable windfall development; why does it have to be infill? That seems to be an unnecessary qualifier. What about windfall within the settlement boundary? Or windfall in a sustainable location – it is not understood why it has to be infill, particularly where LP01 was originally directed at hamlets and clusters of development in the countryside – that seems to be different to ‘infill’.
Struck out the text from the ageing population (page 78). This does not seem to be necessary in our view. There is (and continues to be) an identified need to meet the future housing demands regarding accessible and adaptable dwellings.
• Therefore, in our view, ‘infill’ being added is unnecessary.
• 10 dwellings? Is that an arbitrary number? Likely not been assessed as part of the SA as it is an addition.
• Not helpful to have ‘one or two’ dwellings. It might be that more is more appropriate. Also not likely been subject to the SA
Object
Joint Local Plan Main Modifications
Representation ID: 22766
Received: 05/05/2023
Respondent: Lavenham Parish Council
Legally compliant? Not specified
Sound? Not specified
Lavenham Parish Council welcomes the changes made to LP01 but would prefer that the existing nucleus should be changed from at least 10 to at least 12 established dwellings. This change supports the aspiration in the submission version of the Revised Lavenham Neighbourhood Plan (LNP2) to seriously restrict any development outside of its proposed settlement boundary.
Lavenham Parish Council welcomes the changes made to LP01 but would prefer that the existing nucleus should be changed from at least 10 to at least 12 established dwellings. This change supports the aspiration in the submission version of the Revised Lavenham Neighbourhood Plan (LNP2) to seriously restrict any development outside of its proposed settlement boundary.
Object
Joint Local Plan Main Modifications
Representation ID: 22898
Received: 03/05/2023
Respondent: Gladman Developments Ltd
Legally compliant? Not specified
Sound? Not specified
It is stated that ‘infill’ development will be permitted outside of settlement boundaries for minor development. At present with revised wording set in the proposed modification, this policy is poorly worded and at best confusing and a contradiction in terms. This is clearly not a strategic policy to deliver the quantum of growth in the ‘Part 1’ plan.
Please see attached full rep.