
MM66.
Object
Joint Local Plan Main Modifications
Representation ID: 22443
Received: 24/04/2023
Respondent: Suffolk Preservation Society
Legally compliant? Yes
Sound? Yes
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.
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.
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
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.
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."
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.