MM33.

Delete it.

This policy allows for no scope for interpretation from planning officers where a new agricultural activity can be proven financially viable from the outset. A blanket statement of "c. The enterprise has been established for at least three years and there is an agreed sustainable business plan to ensure the enterprise will remain financially viable for the foreseeable future" is too onerous and will hinder new agricultural development in Babergh & Mid Suffolk where a premenant dwelling is necessary for recruitment purposes.

"d. New permanent accommodation can only be justified if the enterprise is economically viable and is likely to remain viable for the foreseeable future. Where the business has not been established long enough to demonstrate financial soundness, permission may be granted for a temporary dwelling in the form of a residential caravan, mobile home or other prefabricated structure which can easily be dismantled and removed from the site;" will hinder new agricultural developments where it is critical to recruit employees that and hinder economic sustainability of agricultural development.

This modification to the JLP is not ‘sound’ as it is not:

a) Positively prepared – the modification provides a strategy to prevent development of "intensive livestock and poultry farming” in Babergh and Mid Suffolk and is inconsistent with achieving sustainable development as new livestock developments will commonly require a new agricultural dwelling for the reasons of animal welfare.
b) Justified – The strategy is inappropriate and provides no reasonable alternatives, and is based on little to no evidence.
c) Effective –it is effective in that it would allow scope for all new agricultural dwelling proposals to be refused or held up in the planning process due to the ambiguous wording.
d) Consistent with national policy – please see my notes above on how this modification to the JLP contradicts, negates or is already satisfied by the NPPF.

Subject to continuation of agricultural ties etc

New Rural Dwellings Policy new -
Support but subject to continuation of agricultural ties etc

A conditional limit of the period that 'temporary accomodation' e.g. a caravan should be defined.

It is reasonable to allow temporary accomodation, e.g. Caravan, where the business has not met the 'establishement clause', this must not become a loophole to allow the long term use of caravan accomodation.

There are already policies which deal with this issue - just delete it.

This policy allows for no scope for interpretation from planning officers where a new agricultural activity can be proven financially viable from the outset. A blanket statement of "c. The enterprise has been established for at least three years and there is an agreed sustainable business plan to ensure the enterprise will remain financially viable for the foreseeable future" is too onerous and will hinder new agricultural development in Babergh & Mid Suffolk where a premenant dwelling is necessary for recruitment purposes. "d. New permanent accommodation can only be justified if the enterprise is economically viable and is likely to remain viable for the foreseeable future. Where the business has not been established long enough to demonstrate financial soundness, permission may be granted for a temporary dwelling in the form of a residential caravan, mobile home or other prefabricated structure which can easily be dismantled and removed from the site;" will hinder new agricultural developments where it is critical to recruit employees that and hinder economic sustainability of agricultural development. This modification to the JLP is not ‘sound’ as it is not: a) Positively prepared – the modification provides a strategy to prevent development of "intensive livestock and poultry farming” in Babergh and Mid Suffolk and is inconsistent with achieving sustainable development as new livestock developments will commonly require a new agricultural dwelling for the reasons of animal welfare. b) Justified – The strategy is inappropriate and provides no reasonable alternatives, and is based on little to no evidence. c) Effective –it is effective in that it would allow scope for all new agricultural dwelling proposals to be refused or held up in the planning process due to the ambiguous wording. d) Consistent with national policy – please see my notes above on how this modification to the JLP contradicts, negates or is already satisfied by the NPPF.

Stradbroke Parish Council welcomes the inclusion of this new policy which brings clarity on development for rural worker dwellings.

On behalf of our clients, George Durrant & Sons welcomes this policy, though would make a few comments. I am not sure that 'outside of settlement boundaries' is in fact needed within the wording, and this could be wrongly used as a reason for refusal of an otherwise compliant proposal. I think the wording needs to be reviewed slightly as it is a little clumsy in places (e.g. point B 'there being'). We would also add that point B needs to be clarified to ensure that any such accommodation is not only available, but affordable/viable for the worker.

This policy needs to be completely re-written to remedy these weaknesses.

Whilst this policy is derived NPPF 2021 para 80a), Lavenham Parish Council considers the wording of LP05 to be imprecise and insufficiently defined. As a result of this, there is a danger that ‘a coach and horses’ could be driven through it. In particular:
• there is no apparent definition of a rural worker or a rural enterprise
• there is no restriction over the areas in which a development might take place – for example, Lavenham would not want to see development take place within the Area of Local Landscape Sensitivity proposed in the submission version of LNP2
• there are no design restrictions to avoid such development becoming a ‘blot on the landscape’

This policy needs to be completely re-written to remedy these weaknesses.