MM66.

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Object

Joint Local Plan Main Modifications

Representation ID: 22443

Received: 24/04/2023

Respondent: Suffolk Preservation Society

Legally compliant? Yes

Sound? Yes

Representation Summary:

This REP will also appear in AM64

This paragraph is unclear:
1) The wording in the following sentence is currently unclear: - Development of and improvements to services and facilities would include for example through expansion, upgrading and diversification with or without enabling development

2) It is unclear what constitutes 'enabling development'. 'Enabling development' is defined in para 15.33 as relating to designated heritage assets.

Change suggested by respondent:

1) The wording in the following sentence needs to be revised, its meaning is currently unclear: - Development of and improvements to services and facilities would include for example through expansion, upgrading and diversification with or without enabling development

2) An explanation/ definition of 'enabling development' in this instance is required - either here or in a glossary. Currently 'enabling development' is defined in para 15.33 where it is strictly in relation to designated heritage assets.

Full text:

This paragraph is unclear:
1) The wording in the following sentence is currently unclear: - Development of and improvements to services and facilities would include for example through expansion, upgrading and diversification with or without enabling development

2) It is unclear what constitutes 'enabling development'. 'Enabling development' is defined in para 15.33 as relating to designated heritage assets.

Object

Joint Local Plan Main Modifications

Representation ID: 22599

Received: 02/05/2023

Respondent: Sudbury Area Green Belt Group

Legally compliant? Yes

Sound? No

Representation Summary:

The Plan should be amended so that no longer is the suitability of developments only considered in terms of their internal arrangements (eg the proportion of grass on site), the loss to existing communities will be considered, of the open space on which building is proposed.
Applications to build on private land within or adjoining towns and core villages, which is open green space, should be accompanied by evidence that land of equivalent quantity and natural quality exists, within the walking distance (actual, not "as the crow flies") laid down in Natural England’s Accessible natural green space Standard.

Change suggested by respondent:

After "Accessible natural green space which covers a variety of partly or wholly accessible spaces" add "such land, whether or not hitherto mapped as Open Space, should not be built on, unless land of equivalent quantity and natural quality exists, within the walking distance laid down in Natural England’s Accessible natural green space Standard. This should take precedence over existing "zoning" in towns."

Full text:

The phrase "Accessible natural green space which covers a variety of partly or wholly accessible spaces" leaves uncertainty as to how accessible private land is to be regarded, which doesn't feature on the Council's maps of Open Space.
Such "private green space" potentially faces being built on, we recommend that such land should not be closed off, made unusable, or built on, unless land of equivalent quantity and natural quality exists, within the walking distance defined in Natural England’s Accessible natural green space Standard. We do not believe such a rule would deprive any town of a necessary supply of building land. Towns have a history of building over such land until access is diminished to spaces too far to readily access, as any of us may recall, and MM66 must be amended so this historic wrong is not compounded any further.
MM66 should be amended so that no longer is the suitability of developments only considered in terms of their internal arrangements (eg the proportion of grass), and without reference to exterior considerations eg whether existing communities will be hemmed in, or whether it will be cumulative to any adjacent planning permissions. To address this enduring weaknesses, the Plan needs the Council's open plan maps to become a blueprint for conserving natural spaces in populated areas, comparable to the existing practice of zoning.