MM51.

The councils documents above need to go back into policy otherwise...... quote from one of the planning managers, "Guidence is just that, we only really pay attention to policy because that is all that can be enforced"

Reference to the 'Council’s Joint Landscape Guidance, the Suffolk Landscape Character Assessment and Settlement Sensitivity Assessment' has been removed from the policy and put into guidence.

p127 LP17 1 b We question why the qualification of ‘natural and build’ has been added to the definition of landscape. Whereas we accept that existing buildings like villages, churches and modern buildings are assimilated and become part of a landscape, some enhance the attractiveness of a landscape and some are simply ugly and the presence of ugly buildings in an otherwise attractive landscape should not be used as an excuse to build more ugly buildings to make the otherwise attractive landscape ugly. Otherwise a poor decision to allow one ugly building into a landscape would open the door to destroy all that remains with more ugly buildings. Therefore we feel that the added qualification ‘natural and build’ should be balanced by a qualification that ‘inappropriate build forms and proposed build forms adversely impacting on a natural landscape should judged for their cumulative adverse impact’.

MM51 p127 LP17 1b We feel it will be harmful to remove the requirement for design impact on landscape to be sensitive to siting, lighting design, lighting, materials and colour.

MM51 p127 LP17 1c (old#)We feel it will be harmful to remove the requirement of the removed section LP17 1c which are the basic issues of adverse landscape impact.

MM51 p127 LP17 2 This paragraph conflicts with the comments made at AM61 (p126) Para15.23 and supports our comments we made on that paragraph.
We also object to the subtle change in emphasis of the purpose of a LVA or LVIA as the original wording indicated that this ‘should’ identify ways of mitigating, avoiding or reducing adverse impact. That wording does not limit the purpose but only states that the LVA or LVIA should include these options. However, the change now states ‘to’ identify ways of…’ and that wording indicates that the purpose of the report are those options. The change is limiting or at least provides a legal excuse for the report to be limited removing any legal planning requirement for an expert to consider any other options other than an approval or qualified approval. This is directing the expert towards a biased outcome when they should be directed to provide an unbiased assessment ‘to include any options and advice including if appropriate a professional opinion that an application in a given landscape is simply unacceptable’.

Criteria 1B should be amended as follows:

Be sensitive to landscape and visual amenity impacts ( including on dark skies and tranquil areas) on the natural environment and built character and;

Criteria 1b is unclear and should be amended.

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.

Please see attached document.

Main Modification 51 proposes to amend the wording of Policy LP17 Landscape. Support
is given to the proposed amendments in so far as the policy is now more consistent with
the requirements of the National Planning Policy Framework.