MM56.

This policy should not exist.

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. Delete this policy and implement AM66 as you propose it.

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 agricultual revelopment 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.

p139 LP22 b We consider the removal of Landscape amenity as a consideration to be inappropriate for agricultural buildings which are predominantly large buildings in areas considered landscape of public amenity value. This is not necessarily a limiting factor but should be given consideration.
p139 LP22 3 (old#) We question the removal of section 3 when an almost identical section has been added to LP14 for Poultry and Livestock farming. It may be that the building or type of farming will have a low traffic impact and be irrelevant, but then again, the traffic impact may be as significant as Poultry and Livestock farming. The section removed simply asks that question which is as appropriate in LP22 as it is in LP14.

Stradbroke Parish Council supports the revised wording in this policy.

See full representation

For a rural District, Pigeon considers that the need to justify the need for new agricultural buildings outside settlement boundaries is not reasonable and ‘not consistent with national policy’. The development of new agricultural buildings should be supported in principle, subject to compliance with relevant policies within the Plan such as design, landscaping and visual appearance. The NPPF requires planning policies to enable the rural economy to ‘grow and expand in a sustainable way both through the conversion of existing buildings and well-designed new buildings’. Pigeon therefore considers that Part ‘1’ of the policy should be worded more positively to assist the farming industry to achieve the needs of their business in an ever challenging environment.

Either it should be removed, or amended to remove the need to justify through evidence. We would also argue that the criteria should be amended to accord with the GPDO.

This policy requires 'demonstrable evidence' of the need for any new agricultural building outside of a settlement boundary, setting out onerous criteria with which proposals should comply. This seems very odd given that agricultural permitted development rights allow large farms to erect significant buildings with no permission or prior approval, and this policy will therefore unfairly affect smaller farms. In this heavily agricultural area, we should support our farmers with flexible policies to allow them to expand and improve their businesses. We cannot see any support for the restrictions of this policy within the NPPF

It could better reflect the wording of paragraph 110 of the NPPF if part a) was amended as follows:
a. The provision of safe and suitable access for all users, including the mitigation of any significant impacts on the transport network and highway safety to an acceptable degree;
This would also ensure consistency with the above amendment suggested to new policy LP14.

MM56: Policy LP24 (now LP22)
SCC largely accepts the changes to this policy. However, it could better reflect the wording of paragraph 110 of the NPPF if part a) was amended as follows:
a. The provision of safe and suitable access for all users, including the mitigation of any significant impacts on the transport network and highway safety to an acceptable degree;
This would also ensure consistency with the above amendment suggested to new policy LP14.