MM52.

2.a has a small typo. Should read 'conserving' not 'conversing'

p128 LP18 2c Again question change to qualify landscape and ‘natural and build’
MM52 p128 LP18 2e Again question change from protect to conserve in relation to landscape.
MM52 p129 LP18 2 (old#) Section removed defining appropriate tourist and visitor development which seems to leave policy without specific guidance.
MM52 p128 LP18 3 Again question why direction regarding identified Valued Landscape in the Stour Project area, but outside the AONB is inserted specifically here. If it is applicable here for identified valued landscape it should be applicable anywhere identified as valued landscape. The limits of AONB are defined and anything outside them are not AONB. So Valued Landscape policy should be district wide and there should be no need for special insertion into this policy.

Criteria C and d of policy LP18 should be amended to read:
(c ) - Is sensitive in terms of landscape and visual impacts (including on dark skies and tranquil areas) on the natural beauty of the AONBs.
(d) - Supports the provision and maintenance of local services, and facilities and assets (including affordable housing), so long as it is commensurate with meeting the primary purpose of designating the AONBs;

The AONB team is broadly supportive of the changes being proposed to policy LP18 ( formerly LP20). However, we consider that Criteria C is unclear and should be re written. We also consider that Criteria d should be written to ensure compliancy with the Countryside and Rights of Way Act 2000.

The AONB team supports the removal of paragraph 2 from policy LP18 and the insertion of paragraph 3

Therefore, Pigeon continues to advocate that a more objective way of assessing any impacts, would be to require planning applications to be accompanied by a Landscape and Visual Impact Assessment (LVIA), which using an adopted, prescribed methodology, will identify any impact on the wider landscape and also identify whether selected parts of the AONBs are able accommodate appropriate development, in accordance with the remaining criteria of the Policy. Pigeon also suggests that an additional criterion (f) is inserted at part ‘1’ of the Policy to this effect:

F: Any planning application should be supported by a Landscape and Visual Impact Assessment that identifies the impact of the development on the wider landscape and the Area of Outstanding Natural Beauty.

Pigeon is broadly supportive of a Policy which seeks to conserve and enhance the AONBs within the District, in line with Paragraph 172 of the NPPF (2021).

As set out in the Regulation 19 representations, submitted by Pigeon, and articulated at the EiP, the Policy, as worded, continues to fail to differentiate between different parts of the AONBs, notably, in terms of their respective visual and landscape quality. As an example, taking the AONB around the Orwell Crossing, the landscape qualities of this area were somewhat different, when it was first originally designated, compared to the present day, given the subsequent construction of the strategic road bridge in recent decades.

As such, this particular section of the AONB may now be less susceptible to certain types of development than other areas of the same designation. The visual and landscape quality of the AONB should accordingly be considered as part of the Policy.

The Parish Council therefore objects to this revised wording and, instead, proposes that this policy should be reworded as follows;
'The scale and extent of development within the AONBs should be limited. Applications for non-major development within the AONBs and within the setting of the AONBs will need to demonstrate that they:
a) give.....
b) integrate.....
c) are sensitive.....
d) support....
e) demonstrate....
f) conserve.....'

Mod Ref; MM52
Page 9
Policy/Para; LP20, para 2 (which now becomes LP18)
'' Harkstead Parish Council objects to the revised wording of this policy as set out in the proposed Modifications to the JLP. It is of the opinion that the proposed wording complies with neither the wording nor the intent of the Government's policy on Areas of Outstanding Natural Beauty as set out in paragraph 176 of the National Planning Policy Framework.
In particular, the wording in the new policy LP18, para 2, commencing 'The Councils will support non-major development within the AONBs.....'is too positive and presents the reader, particularly one not familiar with the planning system, with an inaccurate and potentially misleading impression of the likelihood of new development being approved in AONBs. Government policy states that 'great weight should be given to conserving and enhancing landscape and scenic beauty in......and AONBs which have the highest status of protection....., (and where) the scale and extent of development within all these designated areas should be limited'
The Parish Council therefore objects to this revised wording and, instead, proposes that this policy should be reworded as follows;
'The scale and extent of development within the AONBs should be limited. Applications for non-major development within the AONBs and within the setting of the AONBs will need to demonstrate that they:
a) give.....
b) integrate.....
c) are sensitive.....
d) support....
e) demonstrate....
f) conserve.....'
(Continue on a separate sheet if necessary. Please remember to include on any separate sheets the name/organisation and details of which Modifications your representation relates.)

In summary, whilst a number of main modifications are welcomed and should be taken forward
to ensure Policy LP18 is sound, further changes are also necessary to ensure consistency with
national policy. This includes revising the wording from ‘supporting’ non-major proposals, to
‘restricting’ these to those which meet all of the criteria, along with requiring the submission of
an LVIA for any proposal within or affecting an AONB to ensure proposals are thoroughly
assessed. Amendments are also required to Policy LP07 to ensure that any tourism development
within the AONB is also directed to the requirements of Policy LP18.