MM42.

LP09 (1c old #) Removed requirement for sustainable/green construction/operation
(1d old #) Removed requirement for sustainable/green healthy transport alternatives provision
(1e old #) Removed requirement for adequate parking
(1h old #) Removed requirement to protect biodiversity and geodiversity. These issues are becoming a national priority causing concern for most of the population. The UK is now identified as one of the most species depleted countries in the world and planning needs to take responsibility to turn this shameful situation around.
LP09 2d It is unacceptable that policy should allow commercial use of property within a residential neighbourhood that might inflict harmful impacts Up To: ‘Significant adverse impacts on health, quality of life or local amenity’. Significant is not an acceptable limit for adverse impact on a residential area. Residential areas should be places of sanctuary for communities and any commercial operations that may want to operate within them on a permanent basis should inflict no more impact than the level of impact associated with a normal residential area’s daily life. So a recurring measurable adverse impact greater than other measurable day to day adverse impacts should be unacceptable.

Clause d) requires sufficient parking. This clause should be clarified that the requirement is for staff, visitors and delivery parking.

Clause d) requires sufficient parking. This clause should be clarified that the requirement is for staff, visitors and delivery parking.

What does a high standard of design mean? What are the criteria?

Removal of 1 c) and d) are hopefully because they are covered by other policies – LP23 & LP29?

Stradbroke Parish Council supports the revised wording in the policy.

To be sound the policy should be amended to state in part 1 (new working is underlined):
proposals for employment use can be outside of settlement boundaries and must:……

We propose the following wording for part d of the policy: Have an appropriate highway access
and not have severe impact on highway network, with sufficient on-site parking.

We object to MM42 policy LP12 which has become policy LP09. The policy should clearly state
that employment development will be allowed outside of settlement boundaries. Policy SP03
states that development will be allowed outside of settlement boundaries when indicated in the
Local Plan. The Local Plan policy LP09 should therefore be clear in what circumstances this is to
be allowed.
The supporting text to LP09 states that:
‘The Plan also provides flexibility to support small scale employment use and flexible working
practices. The predominantly rural nature of the Districts means that there are many small scale
businesses, often within agricultural complexes and also within residential curtilages in both the
towns and the wider countryside. This is an important component of the Districts’ economic
sustainability and diversity.’
This part of the supporting text recognises the types of situations when employment
development should be supported outside of settlement boundaries, but the policy itself is not
as clear. The policy therefore does not provide support for the several hundred small and
medium sized businesses that are located outside of settlement boundaries. Permitted
development rights and the NPPF in paragraph 84 support the creation of business premises in
Babergh and Mid Suffolk Joint Local Plan
Consultation on Proposed Main Modifications Paper Representations Form (2023) 4
rural areas which demonstrates the governments intentions to support rural businesses.
Paragraph 84 states: ‘Planning policies and decisions should enable:
a) the sustainable growth and expansion of all types of business in rural areas, both through
conversion of existing buildings and well-designed new buildings.’
To be sound the policy should be amended to state in part 1 (new working is underlined):
proposals for employment use can be outside of settlement boundaries and must:……
We object to MM42 policy LP12 which has become policy LP09. The policy is proposed to be
amended as follows:
g. d. Have good highway access and not have severe impact on highway network Demonstrate
adequate highway capacity and access with sufficient on-site parking.
The National Planning Policy Framework (NPPF) states in paragraph 111 that: ‘Development
should only be prevented or refused on highways grounds if there would be an unacceptable
impact on highway safety, or the residual cumulative impacts on the road network would be
severe.’
The crossed out part of the policy reflects the wording in the NPPF. The revised wording does
not reflect the NPPF. The amendment is therefore not sound and will not meet the requirements
of national planning policy.
We propose the following wording for part d of the policy: Have an appropriate highway access
and not have severe impact on highway network, with sufficient on-site parking.
100 word summary: Policy LP09 should clearly state that employment development will be
allowed outside of settlement boundaries subject to the criteria in part 1 of the policy. This is to
support the important component of the Districts economic sustainability and diversity where
many businesses are in rural areas agricultural complexes. The policy should reflect the NPPF
paragraph 111 and only refuse development on highways ground where there is a severe
impact.

See full representation

Pigeon continues to support the principle of Policy LP09, which seeks to support economic growth within the two Districts. Pigeon recognises that Policy SP05 addresses the existing strategic employment sites within the Districts and makes provision for new employment sites along the strategic transport network. As such, it is for Policy LP09 to provide the policy basis for existing smaller employment sites and the development of small-scale new employment sites.

In Pigeon’s view, the modifications around Part ‘1’ of the policy continue to be worded in such a way that it does not positively support development for the expansion of existing employment sites and firms or to develop new small scale employment sites. The Councils recognise that there is a qualitive and quantitative need for employment floorspace in the Districts and that in order to retain existing firms in the Districts and encourage new firms to locate here, there is a need to ensure that available floorspace is of the right quality and with the correct services and facilities.

In order to achieve this, future development may be required and the starting point for any application, as set out in the NPPF, is that there is a presumption in favour of sustainable development with plans providing a positive vision for the future of each area, including economic development.

As set out at the start of the JLP, the Councils have identified that key economic issues include projected growth in a wide range of employment sectors and that there is a priority to further diversify the economic base in order to encourage investment in infrastructure, skills and innovation.

Therefore, Pigeon is of the opinion that in order to address these issues, the policy should be more supportive to allow for all of the following;

• the expansion of existing employment sites;
• the growth of existing businesses, without the need to relocate; and
• Recognition of the contribution that micro and SME businesses make to overall employment provision.

In summary, Policy LP12 does not currently meet the objectives set out within the NPPF and so should be revised so that it adopts a more positive approach, which recognises all types of new employment development, with supporting text that is fully responsive to changing needs over time.

This should include supporting a range of new employment opportunities in sustainable locations, particularly where good accessibility to main transport routes is available and where the development is compatible with adjoining uses, would not give rise to any adverse impacts on existing residential amenity, or otherwise conflict with other existing land uses.

It is suggested that this inclusion is articulated as policy addition, and inserted as:
‘3. Proposals that facilitate or support access to low carbon energy, which is either generated or stored locally, will
be encouraged ‘
The acknowledges the ability for developments in The Councils area to access local power at a distribution level in
support of local and regional economic activity and prosperity.

This document responds to the Main Modifications pertinent to the Taiyo portfolio and aspirations
within the Councils jurisdictions, principally the promotion of solar farms, and their contribution to the
government target of 70 GW of solar generation capacity by 20351
. The Main Modifications (“MM”)
and Additional Modifications (“AM”) that this document responds on are as follows:
• MM19 Economic Growth, Chapter 10, supporting policy SP05 and AM55;
• MM23 Strategic Infrastructure Provision Policy SP08;
• MM26 Enhancement and Management of the Environment Policy SP09;
• MM27 Climate Change Policy SP10;
• MM42 Supporting a Prosperous Economy Policy LP09;
• MM49 Environmental Protection and Conservation Policy LP15; and
• MM60 Energy Sources, Storage and Distribution Policy LP25.

The crossed out part of the policy reflects the wording in the NPPF. The revised wording does not reflect the NPPF. The amendment is therefore not sound and will not meet the requirements of national planning policy.

We propose the following wording for part d of the policy: Have an appropriate highway access and not have severe impact on highway network, with sufficient on-site parking.

We object to MM42 policy LP12 which has become policy LP09. The policy should clearly state that employment development will be allowed outside of settlement boundaries. Policy SP03 states that development will be allowed outside of settlement boundaries when indicated in the Local Plan. The Local Plan policy LP09 should therefore be clear in what circumstances this is to be allowed.
The supporting text to LP09 states that:
‘The Plan also provides flexibility to support small scale employment use and flexible working practices. The predominantly rural nature of the Districts means that there are many small scale businesses, often within agricultural complexes and also within residential curtilages in both the towns and the wider countryside. This is an important component of the Districts’ economic sustainability and diversity.’
This part of the supporting text recognises the types of situations when employment development should be supported outside of settlement boundaries, but the policy itself is not as clear. The policy therefore does not provide support for the several hundred small and medium sized businesses that are located outside of settlement boundaries. Permitted development rights and the NPPF in paragraph 84 support the creation of business premises in rural areas which demonstrates the governments intentions to support rural businesses. Paragraph 84 states: ‘Planning policies and decisions should enable:
a) the sustainable growth and expansion of all types of business in rural areas, both through conversion of existing buildings and well-designed new buildings.’
To be sound the policy should be amended to state in part 1 (new working is underlined): proposals for employment use can be outside of settlement boundaries and must:……
We object to MM42 policy LP12 which has become policy LP09. The policy is proposed to be amended as follows:
g. d. Have good highway access and not have severe impact on highway network Demonstrate adequate highway capacity and access with sufficient on-site parking.
The National Planning Policy Framework (NPPF) states in paragraph 111 that: ‘Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.’
The crossed out part of the policy reflects the wording in the NPPF. The revised wording does not reflect the NPPF. The amendment is therefore not sound and will not meet the requirements of national planning policy.
We propose the following wording for part d of the policy: Have an appropriate highway access and not have severe impact on highway network, with sufficient on-site parking.