MM54.

Showing comments and forms 1 to 3 of 3

Object

Joint Local Plan Main Modifications

Representation ID: 22436

Received: 19/04/2023

Respondent: C E Davidson Ltd

Legally compliant? No

Sound? No

Representation Summary:

It is not a sound policy as it contradicts NPPF 84 & 188.

Change suggested by respondent:

Delete this policy and implement AM66 as you propose it

Full text:

This is just an attempt at creating a loophole to oppose agricultural (livestock in particular) buildings by hacking an existing policy about one thing to pieces and rewriting it to address another. It contradicts NPPF 84 & 188.

This modification to the JLP is not ‘sound’ as it is not:
a) Positively prepared – the modification provides a strategy to prevent development of any and all agricultural development in Babergh and Mid Suffolk and is inconsistent with achieving sustainable development.
b) Justified – The strategy is inappropriate and provides no reasonable alternatives.
c) Effective –it is effective in that it would allow scope for all new livestock farming” proposals to be refused or held up in the planning process due to the ambiguous wording and is weighted heavily against the agricultural sector.
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.

Object

Joint Local Plan Main Modifications

Representation ID: 22489

Received: 27/03/2023

Respondent: Sproughton Parish Council

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

LP20 queries are being made to the removal of sections.
We would point out that similar conditions have been applied in Policy LP14 Poultry and Livestock so fail to understand why they have been removed here.

Full text:

p135 LP20 1Why has text in the first section restricting buildings and equipment to those for equestrian use been removed?
LP20 1 a Why has text requiring justification for equestrian use been removed and replaced with a vague demonstration that applicant has prioritised use of existing buildings in place of old text in LP20c which was more definitive?
LP20 1 b Why has text requiring justification scale of site been removed and replaced with a vague requirement to place new buildings close to existing buildings to minimise impact on landscape in place of old text in LP20c which stated there should be minimal impact which is more specific?
LP20 1 d Why has text requiring there be no significant detriment been removed and replaced with text where any significant adverse impact caused can be demonstrated to be mitigated? This is a lesser standard and unlikely to be enforceable or enforced once applicant and their livestock is ‘on the ground’ if mitigations proposed are inadequate or not properly applied or installed.
LP20 1 f (old#) Why has section requiring proof of satisfactory waste management been removed
LP20 1 e Why has text been changed from an inference that proposal must integrate into landscape into a requirement to mitigate for impact on the landscape.
LP20 1 h (old#) Why has section requiring preservation of heritage assets and their settings been removed.
LP20 1 i (old#) Why has section requiring preservation of hedgerows and trees in rural location been removed. This is important for the preservation and future use of farmland if food demand necessitates the land should revert back to agricultural use in the future.
LP20 1 j (old#) Why has section requiring avoidance of and detriment to biodiversity and geodiversity been removed.
LP20 1 l (old#) Why has section requiring avoidance of any adverse highways impact been removed.
LP20 2l(old#)Why has this section been removed. Use of agricultural land to provide an equine service should not be a loophole into provision of residential accommodation on farmland in an area that would otherwise be unacceptable. There are many reasons these sites may return to agricultural use and therefore construction of residential accommodation on such a site needs significant justification and the removed section set such standards.
LP20 3 (old#)Why has this section been removed. It would appear appropriate that the boundary treatments in a rural setting should retain the hedgerows etc and the rural setting. Allowing the boundaries to be altered to a garden or urban character would be an adverse impact on the landscape beyond the normal provision of a equestrian facility. We also believe that any approval for residential or equestrian buildings on an equestrian site in a rural setting or farmland should automatically have development rights removed otherwise a simple building which might be at the limit of acceptable development could be progressively extended beyond what would otherwise be acceptable on a sensitive site.
We would point out that similar conditions have been applied in Policy LP14 Poultry and Livestock so fail to understand why they have been removed here.

Attachments:

Support

Joint Local Plan Main Modifications

Representation ID: 22902

Received: 03/05/2023

Respondent: Suffolk County Council

Representation Summary:

It is noted that reference to impacts on highway safety have been removed from this policy following our comments at the Regulation 19 consultation. This is welcome as it is noted that our requested wording has been incorporated into Policy LP32 (now LP29). SCC is therefore satisfied that this policy is now sound.

Full text:

MM54: Policy LP22 (now LP20)
It is noted that reference to impacts on highway safety have been removed from this policy following our comments at the Regulation 19 consultation. This is welcome as it is noted that our requested wording has been incorporated into Policy LP32 (now LP29). SCC is therefore satisfied that this policy is now sound.

Attachments: