LA061 - Land south of Heath Road, East Bergholt

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Comment

BMSDC Joint Local Plan Preferred Options (interactive)

Representation ID: 16243

Received: 08/08/2019

Respondent: Hills Residential Ltd

Agent: Phase 2 Planning & Development Ltd

Representation:

The allocation of Site LA061 for residential development through the Local Plan is supported. The suitability of the site for residential development has been thoroughly tested through the previous planning application, and the technical and environmental evidence submitted and assessed through that process supports the allocation of the site, whatever the outcome of the current judicial review process.

There are some specific corrections/updates that we consider should be made to the Sustainability Appraisal assessment in respect of the outcomes for this site, in the light of matters considered and addressed at the planning application stage.

Full text:

Background

On behalf of Hills Residential, the promoters of site LA061, we support the allocation of the site for residential development within the emerging Local Plan.

The Council will be aware that planning permission for the same form of development as proposed by Policy LA061 has previously been granted, under reference B/16/01092/OUT. Although the site is the subject of a current challenge under the judicial review process (alongside the permissions granted for sites LA059 and LA060), that challenge effectively relates to a point of procedure in the determination of the application, and not to the technical or environmental merits of the development.

Site Suitability

The documentation provided in support of the previous grant of planning permission provides evidence that supports the allocation of the site through the Local Plan. That evidence demonstrates that the site is eminently suitable for development in principle, and with no technical or environmental constraints, and that it is in a sustainable location adjoining the boundary of one of the District’s Core Villages (and lies adjacent to key local education and health facilities).

The previous assessment of the site through the planning application process has, in particular, confirmed:
• No objection to the proposed development on highway grounds (taking in to account the cumulative impact of LA059 and LA060 as well), both from the Highway Authority and from Highways England;
• No objections on the grounds of archaeology, the site having been subject to field evaluation;
• No objections to development on landscape grounds from the Council’s external consultant, Places Services;
• No objections to the development on ecological grounds, following a review of the site specific ecological assessment and mitigation proposals, by Place Services;
• No objections from Anglian Water or the Lead Local Flood Authority in respect of either foul or surface water drainage;
• No objections from NHS England (subject to the usual financial contribution for enhancing the adjoining medical practice);
• Support from the Council’s Strategic Housing Manager for the on-site delivery of 26 affordable housing units, including 3 key worker units connected to the East Bergholt Academy.

The scrutiny of the site through the previous planning application process, and the evidence provided as part of that process, demonstrates that the site is justifiably allocated for development in the Local Plan to meet the future housing needs of the area, regardless of what the outcome of the judicial review process is.

Comments on the Sustainability Appraisal

We generally support the findings of the Sustainability Appraisal in respect of site LA061, but having regard to the comments above and previous assessment of the site through the planning application process, we offer the following comments:
• For criterion 1.1, not only does the proposed development not lose open space, the site specific proposals provide new open space, that will be accessible to existing as well as new residents, and it makes provision for a new footpath connection to the south to link to the Donkey Path which in turn opens up access to existing rights of way to the north for existing residents, who will have more opportunities for local walking routes as a result of that connectivity. Accordingly, we consider that the outcome for criterion 1.1 should be “+” rather than “0”.
• Similarly for criterion 1.2, given the fact that the site is actually adjacent to the secondary school, is adjacent to a bus route, is adjacent to the medical centre, and the site proposals include the additional link to the Donkey Path to the south which provides a direct walking route to the heart of the village, we would suggest the outcome on this criteria should be “+” rather than “0”;
• In Table 11 on page 94, the outcome given for the site against criteria 3.1 is “?”, whereas the correct result from the Table 10 Site Assessment is “+”;
• With regard to criterion 11.1, Natural England raised no objection to the proposed development of the site in respect of the previous application, taking in to account its location and proximity to European protected sites, and through the application process, evidence on the ability of the site to deliver local mitigation through links and improvements to local walking routes to enhance local recreational opportunities was provided. Alongside any off-site RAMS contribution (which the supporting text to the allocation notes will be required), there is therefore already evidence, accepted by Natural England, that there is effective mitigation available in respect of off-site ecological impacts. In respect of on-site ecological impacts, the authors of the SA Report, Place Services, have already assessed the site in their role as advisor to the District Council on ecology matters, and as noted above, Place Services raised no objection to the scheme. Indeed, in the light of the on-site ecological assessment and mitigation package presented with the application, Places Services went further, and noted that the ecological enhancements proposed for the site would contribute to the aim of biodiversity net gain. Therefore on the basis of the evidence available from the previous planning application, the outcome for criterion 11.1 should be “+”, or at least “0”;
• In respect of Criterion 11.4, in all other cases where the SA concludes an absence of impact on geological sites, the SA records an outcome of “+”. As Table 11 clearly illustrates, the outcome of “0” for site LA061 alone in respect of this criterion, when the effects are no different to any other site, is clearly an anomaly that should be corrected;
• In respect of criterion 13.1, Place Service’s own assessment of the site through the planning application process, as evidenced in its consultation response to the District Council, raised no objection on landscape grounds. The impact of the development on local landscape was accepted by Place Services as being capable of being addressed at the detailed design stage. The outcome can therefore reasonably be changed to “+” or “0” on the basis of that previous assessment work.

Object

BMSDC Joint Local Plan Preferred Options (interactive)

Representation ID: 17162

Received: 25/09/2019

Respondent: AONB Team

Representation:

It is not clear how potential impacts on the setting of Dedham Vale AONB and the Suffolk Coast & Heaths AONB proposed extension area have been assessed to support this allocation in the emerging Local Plan. There is no criteria in the SA to assess impacts on nationally designated landscapes.
The SA needs to be revised to include a criteria to enable impacts on nationally designated landscapes and their setting to be assessed.
This allocation along with the other proposed allocations in the Local Plan needs further justification as they exceed the East Bergholt Neighbourhood Plan housing numbers.

Full text:

This proposed allocation of 75 dwellings represents major development within the setting to the Dedham Vale AONB The site is also located within the setting of the proposed extension area to the Suffolk Coast & Heaths AONB which has reached sign off stage with the SOS and therefore carries weight in the planning system.
It is not clear how potential impacts on the AONBs have been assessed to support this allocation in the emerging Local Plan as there is no criteria in the SA to assess impacts on nationally designated landscapes.
The policy text should be altered to acknowledge that the site is located within the setting of the proposed Suffolk Coast & Heaths AONB extension area which has reached sign off stage with the SOS. As set out above in our response to the SA, further justification should be provided to support the allocation given the site’s location in the setting of the 2 nationally designated landscapes.
Following re-assessment, if the LPA continue to support the allocation of this site, LA061, should be amended to require the completion of a Landscape and Visual Impact Assessment at planning application stage given the location of site relative to the 2 AONB areas to ensure that the natural beauty is conserved an enhanced. The LVIA should consider the cumulative impacts of the three proposed allocations on the 2 AONBs.
Criteria ii of LA061 should be amended to read’ Design, layout and landscaping sympathetic to the close setting of heritage assets, conservation area, the setting to the Dedham Vale AONB and extension area to the Suffolk Coast & Heaths AONB
The East Bergholt Neighbourhood Plan recommends the delivery of 86 new homes between 2015 to 2030. The total proposed allocation in the Local Plan for East Bergholt is 229 dwellings spread across 3 sites which exceeds the Neighbourhood Plan proposal. While this allocation on its own does not exceed the Neighbourhood Plan housing numbers, it does along with the other proposed allocations. As set out above in our response to the SA, further justification to support the allocation is necessary.

Comment

BMSDC Joint Local Plan Preferred Options (interactive)

Representation ID: 18318

Received: 30/09/2019

Respondent: Suffolk County Council

Representation:

policy should require the developer to test the potential resources on the site to identify if prior extraction or use of the mineral on site is appropriate.

Full text:

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Attachments:

Comment

BMSDC Joint Local Plan Preferred Options (interactive)

Representation ID: 18545

Received: 30/09/2019

Respondent: Historic England

Representation:

There are no known heritage assets within site LA061 itself however the Grade II listed Old Mill House is located to the south of the site. Any development of the site has the potential to impact upon this heritage asset.
The presence of these heritage assets should be considered carefully as part of the site allocation process.

Full text:

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Object

BMSDC Joint Local Plan Preferred Options (interactive)

Representation ID: 19116

Received: 30/09/2019

Respondent: Suffolk Constabulary

Agent: Lawson Planning Partnership Ltd.

Representation:

Insert a new paragraph (below healthcare provision) as follows:
VI. Contributions, to the satisfaction of the LPA, towards police facilities provision.

Full text:

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Attachments: