B&MSDC Supplementary Planning Documents Consultation

Comment

Representation ID: 23591

Received: 19/06/2024

Respondent: East Suffolk Council

Overall, this is a useful and relevant document about intensive livestock and poultry farming, which
is increasing in both the Babergh and Mid Suffolk areas. East Suffolk Council supports Babergh and
Mid Suffolk District Councils in providing clear guidance about how intensive livestock and poultry
farming should be developed. However, East Suffolk Council is also keen to ensure that the
following issues are dealt with adequately by the draft Intensive Livestock and Poultry SPD.
• Water pollution: East Suffolk is downstream of Mid Suffolk and therefore is vulnerable to
water pollution from intensive livestock and poultry farming taking place in Mid Suffolk,
and we therefore welcome inclusion of guidance on this matter (paragraphs 5.2; 5.3).
• Transport: as East Suffolk has the potential to be adversely impacted by HGV movements
generated by intensive farming we support the inclusion of this topic in the guidance.
• Other activities: A few sentences could be added to state that intensive farming should be
sensitive to other rural activities and should be located away from those that could be
adversely affected. This could include tourist activities and accommodation (paragraph
5.2).
• Water supply: It is acknowledged that the Babergh and Mid Suffolk Water Cycle Study (Oct
2020) identifies Babergh and Mid Suffolk districts as ‘an area of limited water resources’
and that the Hartismere Water Resource Zone (WRZ) has low water supply headroom until
at least 2032. This resulted in Essex and Suffolk Water placing a moratorium on new nonhousehold
development in the Hartismere WRZ. While the boundaries of the Hartismere,
Blyth and Northern Central WRZs closely follow the East Suffolk and Mid Suffolk boundary,
there are some areas of East Suffolk that fall within the Hartismere WRZ. Furthermore,
water supply issues do not necessarily respect administrative boundaries. East Suffolk is
downstream of Mid Suffolk and thus development in Mid Suffolk has potential to affect
water supply in East Suffolk. The Council supports the approach set out in the SPD, namely
that it is necessary to consider water supply early in the planning process with all the
information necessary to undertake a complete assessment of the water supply situation,
especially where new water infrastructure is required to serve the development. Clear
guidance is provided as to the intended process for preparing a Water Supply Management
Statement/Water Resource Assessment. However, further clarity could be provided as to
what might constitute “an acceptable level” of water demand (paragraph 5.4.4). The
second sentence of paragraph 5.4.5 states that “calculations should demonstrate water
neutrality… [and that] there is water headroom”. It is therefore assumed that the
‘acceptable level’ of water demand is a level that can be demonstrably supplied.

Comment

Representation ID: 23592

Received: 19/06/2024

Respondent: East Suffolk Council

With regards to the sections that discuss matters related to trees, there is no current cross
reference to the Suffolk Design: Streets Guide (2022) in the SPD to direct the reader to guidance
on trees in a streetscape context. If a cross reference to the Suffolk Design: Streets Guide is not
provided, we would recommend consideration is given to adding guidance that helps ensure that
trees in these environments are appropriately located in highways safety terms, that the species is
correct for the environmental context (TDAG guidance on trees in hard landscapes1 reference is
recommended), and that tree pits are appropriately designed and of a size and shape that will
support the tree’s needs over its full lifecycle.
The following comments relate to specific sections:
Chapter 1 Introduction:
1.1. Has a typographical error – this should be ‘breathe’ not ‘breath’.
Chapter 3 Designated areas (including Suffolk Coast RAMS):
1 Available at: https://www.tdag.org.uk/trees-in-hard-landscapes.html
The inclusion of RAMS within this chapter is supported, and the consistency between this SPD and
the equivalent SPDs produced by East Suffolk Council and Ipswich Borough Council is welcomed.
Within this chapter there are a number of references to specific elements of the current RAMS
strategy. As of June 2024, the RAMS partnership authorities have begun a review of the RAMS.
This review may result in amendments to some of these elements. To avoid the SPD becoming
outdated when the new RAMS is published, it may be beneficial to remove some of these specific
references and/ or simply include cross references to ‘the latest version of the RAMS strategy’.
Examples of these references include:
• Refence to the 13km Zone of Influence at paragraph 3.6.8
• Reference to the Zone A and Zone B at paragraph 3.6.9
Furthermore, the SPD could include specific reference to the strategy review.
Paragraphs 3.6.5 and 3.6.6 list the Habitats sites likely to be affected by development. It may be
helpful if SPD also included clarification around the spend of RAMS funds and set out clearly that
funds from both zones will be combined and spent across the strategy area.
The list of sites in paragraph 3.6.5 should be amended to include reference to the Minsmere-
Walberswick Heaths and Marshes SAC. The correct title of the SPA and Ramsar site is ‘Minsmere-
Walberswick SPA and Ramsar Site’ – reference to heaths and marshes only applies to the SAC.
Paragraphs 3.6.14, 3.6.15, and 3.6.16 include information on the types of application the RAMS
applies to. There is no mention here of reserved matters applications. It would be helpful to clarify
the approach for such cases. For information, the East Suffolk RAMS SPD states:
“26. The Suffolk Coast RAMS tariff applies to all full applications, outline applications, permitted
development, permission in principle, variation of condition applications and reserved matters
applications where no contribution was made at the outline stage.”
Chapter 4 Biodiversity Mitigation Hierarchy and Biodiversity Net Gain:
4.7 to 4.11 These sections seem to mix the terminology a bit which may be confusing to nontechnical
readers. For example, 4.10 refers to an “impact assessment for ecology” and 4.11 refers
to an “ecological assessment”, where both seem to be meaning a “biodiversity net gain
assessment”. It should be ensured that consistent terminology is used throughout the SPD to
make it clear to applicants and their ecological consultants what is required.
4.8 may read better in a bullet point format, like 4.9/4.11. Current format makes it easier to miss
this key information.
4.9 – It’s not clear where the requirement to provide a GIS layer originates from – it’s not in the
government guidance and is not in Part 1 of the Joint Local Plan, which suggests it is only
recognised as a requirement in this SPD.
The requirement to provide a GIS layer may be prohibitive for some applications, and will mean
the use of private consultants is likely to be essential for all applications where BNG is required –
though this would be likely to be required more generally due to the highly technical area of
planning, the additional need for a GIS layer will make this unavoidable for most. It’s not clear
from the SPD whether this is for larger and smaller sites incurring BNG requirements, or only
larger sites. Will consultants be needed for all BNG-incurring development?
4.12 You may wish to remove strimming as an example of habitat degradation (but keep
ploughing), depending on the grassland type a strimmed/mowed site may still achieve a ‘Good’
condition score for the purposes of BNG.
4.15-4.19 You may wish to consider placing this background text at the beginning of section 4 or to
earlier in the SPD so that section 4 is focused on giving clear instructions on the process and
expectations the Council has for applications.
4.22, bullet 3 The applicant doesn’t have the ability to refuse to accept the standard BNG precommencement
condition, it is applied by law not by the LPA on issuing the decision notice.
4.25 – This paragraph should also refer to off-site locations within the same National Character
Area (NCA) as the development site, as this is also a criterion included in the spatial risk multiplier
of the Statutory Biodiversity Metric.
4.32 Typographical error – “Integrated” not “Integral”.
Chapter 5 What the Councils expect in developments:
5.1 – The landscape-first approach is supported; the outlined approach is similar to the approach
set out in East Suffolk’s recently adopted Healthy Environments SPD.
5.7.7 There would be value in this or one of the following paragraphs emphasising that the IACPC
(signed by the applicant and Natural England) is required to be submitted to the LPA prior to a
planning application being determined.
5.10-5.11 – This paragraph could be more clearly written. Missing word ‘the NPPF’.

Comment

Representation ID: 23593

Received: 19/06/2024

Respondent: East Suffolk Council

We have no comments on the Draft Housing SPD.

General comments:-
General comments are that the Supplementary Planning Documents would benefit from a
contents page that is interactive, allowing the reader to click on a listed section and jump to the
appropriate page number. Hyperlinking policies to the area of the Local Plan where those policies
are explained in full would also be useful. More images throughout the document would also help
to support the text and create more visual separation between sections.
We hope that these comments are of use but please get in touch if you have any questions.