MM49.

P119 3b Why have assessments of amenity impacts been reduced to only consider significant impacts. Relatively minor impacts on residential amenity like noise, dust, light, smells and pollution etc. especially where they are cumulative with other development or other impacts could make life unbearable in an otherwise quiet residential setting. It is not enough for these issues only to be considered at a potentially ‘significant adverse’ level.

Persimmon maintain that the use of
‘convincingly’ in the policy is not appropriate and should be deleted.

Persimmon has previously made representations to Policy LP15 (previously Policy LP17),
specifically criterion 3 relating to the mitigation of impacts of pollution arising from new
development. Persimmon objected to the policy stating mitigation must be ‘demonstrated to the
satisfaction of the LPA’. This has now been amended to state mitigation ‘must be convincingly
demonstrated by impact assessments where appropriate’. Persimmon maintain that the use of
‘convincingly’ in the policy is not appropriate and should be deleted.
The comments made here in relation to MM49 are also relevant to MM60 (Policy LP25, previously
LP27), where the phrase ‘convincingly demonstrate’ is used in criterion 3.

As amended, Policy LP15 has been reworded so that where practicable, development will enhance groundwater and surface water features and not lead to a deterioration in the quality of the environment. Pigeon supports this modification to the policy.

the provisions in the draft National Policy Statement EN-3 for
Renewable Energy Infrastructure should be acknowledged in this regard, namely:
- Paragraph 3.10.136 ‘The Secretary of State should take into account the economic and other benefits of the
best and most versatile agricultural land’ and that ‘The Secretary of State should ensure that the applicant
has put forward appropriate mitigation measures to minimise impacts on soils or soil resources.’
- Paragraph 3.10.141 ‘The time limited nature of the solar farm, where a time limit is sought as a condition of
consent, is likely to be an important consideration for the Secretary of State’.

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.

Please see attached document.

Please see attached document.

To be more effective, MM49 should include an additional sub-paragraph, such as:c. Demonstrate in a Water Supply Management Statement, in liaison with the relevant water supply company, that ground water abstraction (licenced or otherwise), does not lead to a deterioration in the quality of the environment, taking
into account the cumulative impacts resulting from similar developments in the district(s)... (or similar).

In general, I support the proposed main modifications.
The following comments represent my views in relation to some of the proposed
main modifications (MM20, MM47, MM48, MM49 and MM57), where I feel that the
policy wording could be revised to more effectively meet the Joint Local Plan’s
strategic objectives, particularly in light of new evidence concerning the expansion of
the intensive poultry industry.
1) Summary of New Evidence
1.1 Poultry meat production growth
Cranswick Plc has indicated its intension to increase the volume capacity of the
poultry meat processing factory located on Eye Airfield through recent press
announcements:
“Cranswick said broad investment plans were firmly on track with "several substantial
projects in progress which will enhance the capability of and add capacity to several
of our flagship production facilities as well as driving through further operating
efficiencies". (Business Live 2/2/23)
The factory at Eye is regarded by Cranswick as a ‘flagship production facility’.
Proposed expansion of the factory is substantiated by a recent application to the LPA
on 24th April 2023, for a Screening Opinion:
DC/23/01969 | Environmental Impact Assessment Screening Opinion request for
proposed production building facility and mill building | Eye Airfield Business Park
Eye
An expansion of the poultry meat factory’s processing capabilities, in conjunction
with Cranswick’s stated objective to produce meat to the ‘Better Chicken
Commitment’ standards for intensive broiler units (stocking levels per square metre
lower compared to the Red Tractor scheme) means that the company will need to
increase the number of intensive poultry units in its supply chain in order to grow the
requisite number of birds for processing at the factory.
1.2 Impact on water resources
The operation of intensive poultry units requires extremely high water useage.
Essex & Suffolk Water (ESW) recently made its position very clear in an ongoing
planning application within the Hartismere Water Resources Zone
(DC/21/06824 | Planning Application - Erection of 6no poultry houses with associated
admin blocks, feed bins and ancillary development. (EIA Development)):
See attachment: Appendix A – Letter from William Robinson (Water Resources &
Supply Strategy Manager) to Philip Isbell (Chief Planning Officer, BMSDC) dated 6th
February 2023.
In summary, ESW objected to the planning application for the following reasons:
• The development is likely to result in an increase in mains water use which
will require an increase in groundwater abstraction to levels likely to be
unsustainable as confirmed through our AMP7 WINEP groundwater
abstraction sustainability investigations and documented in our dWRMP24;
• in the absence of supply headroom in our Hartismere water resource zone,
new non-domestic water demand would lead to us exceeding the annual
licensed quantities on our abstraction licences; and
• based on current programmes, new supply schemes will not be operational
until 2032 at which point the moratorium will be lifted.
In order to overcome the objection, ESW requested a Grampian condition to ensure
that the development could prove to be water neutral; this would entail the
construction of a grey water reuse storage reservoir to be filled by a combination of:
• Rainwater harvesting
• Diversion of land drainage flows
• A new groundwater or surface water abstraction
The Environment Agency has confirmed that it will not grant abstraction licences
(required for more than 20,000 litres per day) due to current water stress levels in the
Hartismere Water Resources Zone (see attachment: Appendix B – letter from the
Environment Agency to the LPA, dated 1/2/23).
The groundwater abstraction in ESW’s proposed Grampian condition refers to
unlicenced extraction of water (up to 20,000 litres per day).
If this approach to overcoming ESW’s moratorium on ‘new non-domestic supplies’ in
the Hartismere Water Resources Zone is adopted for other planning applications for
more intensive poultry units in the period to 2032, then the potential for harm caused
by the cumulative impact is likely to be very high.
An increase in unlicenced groundwater abstraction could lead to extreme use of
groundwater resources causing serious issues including (not exclusively) ecological
environment deterioration, land subsidence, vegetation degradation, reduction of
water in streams, rivers and lakes and deterioration of water quality.
2) Comments on Proposed Main Modifications in Light of New Evidence
2.1 MM20 Page 50 Policy Paragraph SP05
6. Any application for non-domestic proposals requiring heavy water usage across
the two Districts will be required to demonstrate that sufficient water capacity is
available through a Water Supply Management Statement in liaison with the relevant
water supply company. Any use of this nature in the Hartismere Water Resource Zone
(Mid Suffolk District) will be prohibited until confirmation of sufficient water capacity
by the relevant water supply company (currently anticipated from 2032).
To be more effective, this modification needs to specify that the Water Supply
Management Statement will be expected to include a cumulative impact analysis of
proposed alternative water sources…. (or similar).
2.2 MM47 Page 89 New policy supporting text
Importantly, whilst an individual intensive livestock and/or poultry development may
be acceptable, the cumulative impacts resulting from similar developments nearby
should also be taken into account.
To be effective and consistent, the word ‘should’ ought to be replaced with ‘must’ –
see (3) in MM48 Page 89:
3 Where an individual intensive livestock or poultry development is considered
acceptable, the cumulative impacts resulting from similar developments
nearby must also be taken into account.
2.3 MM48 Page 89 New Policy
To be effective point 4 needs to protect existing residential buildings or sensitive land
uses and should be amended to include the following text:
4 Proposals for residential buildings or other sensitive land uses within 400m of
established intensive livestock and/or poultry units will be subject to special
consideration. Likewise, proposals for intensive livestock and poultry units
within close proximity to existing residential buildings or sensitive land uses
will be subject to special consideration. Such proposals which would be
subject to significant adverse environmental impact will not be permitted.
2.4 MM49 Page 90 Policy Paragraph LP17
4. WATER
a. Comply with the relevant SCC Construction Surface Water Management Plan.
b. Demonstrate protection and where practicable enhancement of groundwater, surface
water features and must not lead to a deterioration in the quality of the environment to help
achieve the objectives254 of the Water Framework Directive.
To be effective this modification needs to address the cumulative impact of an
increase in groundwater abstraction, as evidenced in 1.2 ‘Impact on Water
Resources’ above and as set out in the Sustainability Appraisal (p2) as follows:
22: The NPPF sets out information about the purposes of local plan-making, stating
that plans should
• Be shaped by early, proportionate and effective engagement between planmakers and communities, local organisations, businesses, infrastructure
providers and operators and statutory consultees;
23. In terms of sustainable social, environmental and economic development;
however significant adverse impacts in any of those areas should be avoided.
Also, as evidenced in the Sustainability Appraisal Table 1 Key Sustainability Issues
(p 4) as follows:
“Due to Babergh and Mid Suffolk having numerous rivers running through their areas
(eg the River Gipping and River Brett), there is a need to ensure that not only the
rivers are protected but that all water sources including groundwater are too. Many
areas in BMSDC are covered by Source Protection Zones.”
“Anglian Water provides for Babergh District and much of Mid Suffolk, whilst Essex
and Suffolk Water provides for parts of Mid Suffolk – both districts are prone to
drought. Due to water being imported from elsewhere in the country, there must be
effective and reliable water systems in place to reduce any harm associated with
droughts. There are particular areas under significant water stress, such as within
the Hartismere Water Resource Zone in north east Mid Suffolk. Here, there are
short- and medium- term potable water capacity issues resulting in restrictions upon
new non-domestic water supply until 2032. The likelihood of droughts may increase
as a result of climate change, and it should be noted that there is significant crossover between water resource availability and water quality.”
To be more effective, MM49 should include an additional sub-paragraph, such as:
c. Demonstrate in a Water Supply Management Statement, in liaison with the
relevant water supply company, that ground water abstraction (licenced or
otherwise), does not lead to a deterioration in the quality of the environment, taking
into account the cumulative impacts resulting from similar developments in the
district(s) … (or similar)
2.5 MM57 Page 104 Policy Paragraph LP25
Sustainable construction and design – this modification needs to include ‘non residential development’ in point 4 to be of relevance to new intensive livestock and
poultry building development, specifically to include plans to decommission and
demolish buildings when redundant and return the land to agricultural use in order to
minimise the potential for residential development in the countryside and to protect,
conserve and enhance the landscape and the environment.
Appendices A & B attached.

Please see attached full document.

Please see attached full document.

Please see attached full document