Q1

Showing comments 61 to 90 of 174

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 4466

Received: 10/11/2017

Respondent: Barking Parish Council

Representation:

Barking Parish Council has the same vision as MSDC

Full text:

Barking Parish Council has the same vision as MSDC

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 4528

Received: 10/11/2017

Respondent: Woolverstone Parish Council

Representation:

There is simply no real vision in this Joint Local Plan

Full text:

There is simply no real vision in this Joint Local Plan Consultation Document. The vision for the area should be made much clearer. The Local Plan needs to be visionary. What is precious in Babergh now and how can this be preserved or enhanced by 2036? Woolverstone Parish Council doesn't see any vision of the sort of District Babergh wants to be? For example, how is it best to enhance our network of villages and market towns so they retain their special qualities without becoming a sprawling, increasingly urban landscape? It would be reassuring to see a commitment to eliciting how this could best be achieved. Is the best way forward to expand all the villages? We don't see in the vision any alternatives to the current mindset.

It seems to us that this approach is fundamentally flawed and that the absence of an initial vision is then all too apparent throughout the remainder of the document. Consequently, the draft comes across as an exercise driven predominately by an academic calculation of future housing numbers, rather than a real world vision of what should be delivered for the people and communities in Babergh and Mid Suffolk by the end of the plan period.

We therefore strongly suggest that the consultation is currently "putting the cart before the horse" and that a vision with wide community support should have been developed first. This vision should then have been a golden thread, evident throughout any subsequent consultation drafts on the joint local plan.

Notwithstanding that, we suggest that any vision should include the following through the plan period to 2036:
* Babergh and Mid Suffolk will remain attractive largely rural areas with thriving towns and villages and an attractive, varied landscape.
* Towns and villages will each retain their distinct characters. Coalescence of settlements will be avoided.
* Effective use will be made of previously developed land to minimise the need to build on green field sites.
* Wherever new housing is provided, it will respond to identified local needs including in relation to type, size, and tenure.
* All new housing will be to the highest design standards both visually, in the context of local character, and in environmental performance.
* The adverse impact of new housing developments on areas such as traffic congestion, air pollution and social cohesion will be minimised through the scale and location of developments and the enhancement wherever needed of physical, social and environmental infrastructure.
* Natural, built and heritage assets will be protected and, wherever possible, enhanced.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 4533

Received: 06/11/2017

Respondent: Lavenham Parish Council

Representation:

The vision of the plan must be to enhance the wellbeing of the inhabitants of Babergh and Mid-Suffolk Districts, now and in the future. The JLP covers 20 years and this timeframe needs to be recognized. This should follow a holistic approach to the challenges and opportunities the residents of the two districts face today and in the future. Any growth should build upon the aspirations and needs of its residents.
The Districts are largely open countryside and the economy has a rural base - agriculture, tourism and now more and more people are working from the home and any plan must recognise this. The plan must be the property of the people of the two districts.

Full text:

See attachments

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 4878

Received: 06/11/2017

Respondent: Nedging with Naughton Parish Council

Representation:

The Vision should be to achieve sustainable development, but is should preserve the character and natural beauty of the Suffolk Countryside.

Full text:

See attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 4902

Received: 08/11/2017

Respondent: Pinewood Parish Council

Representation:

We support the vision as long as it is adhered to!

Full text:

We support the vision as long as it is adhered to!

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 4920

Received: 08/11/2017

Respondent: Brantham Parish Council

Representation:

In broad principles.

Full text:

In broad principles.

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 4949

Received: 08/11/2017

Respondent: Mr Michael Smith

Representation:

The vision should encompass a sense of identity and focus. At present the overwhelming feeling is of disengagement.

Full text:

The vision should encompass a sense of identity and focus. At present the overwhelming feeling is of disengagement.

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5039

Received: 08/11/2017

Respondent: Long Melford Parish Council

Representation:

A place that works well for as many people as possible, including future generations.

Full text:

A place that works well for as many people as possible, including future generations.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5080

Received: 08/11/2017

Respondent: Mrs Rosemary Jones

Representation:

To respond to population growth, housing and infrastructure should grow organically, protecting the environment for the long term.

Full text:

To respond to population growth, housing and infrastructure should grow organically, protecting the environment for the long term.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5091

Received: 08/11/2017

Respondent: Stradbroke Parish Council

Representation:

MSDC should meet the needs and aspirations and potential talents of its population, particularly young people re equal opportunity, fair and just housing, employment, etc. At the same time preserving the countryside with its rich natural resources as it is a source of our success as a village and county and a tourist attraction.

Full text:

See attached

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5181

Received: 08/11/2017

Respondent: Mr Terence Gray

Representation:

Sustainable development but first infrastructure and not to destry our environment and culture

Full text:

Sustainable development but first infrastructure and not to destry our environment and culture

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5362

Received: 08/11/2017

Respondent: Babergh Green Party

Representation:

To improve the quality of life and the health and well being of the citizens of Babergh and Mid Suffolk while ensuring the two districts contribute to carbon reductions targets agreed in international governments in Paris.

Full text:

To improve the quality of life and the health and well being of the citizens of Babergh and Mid Suffolk while ensuring the two districts contribute to carbon reductions targets agreed in international governments in Paris.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5428

Received: 08/11/2017

Respondent: Denham Parish Council

Representation:

Denham Parish Council agrees with the vision but is concerned to how it will be implemented

Full text:

Denham Parish Council agrees with the vision but is concerned to how it will be implemented

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5462

Received: 08/11/2017

Respondent: Mr Graham Moxon

Representation:

I support this vision but only if due consideration is given to the entire vision at all relevant times.

Full text:

I support this vision but only if due consideration is given to the entire vision at all relevant times.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5486

Received: 08/11/2017

Respondent: Mrs Louise Carman

Representation:

There should be a balance of sustainable development focusing on affordable housing for young families whilst maintaining the green space and identity of a village. Any development would clearly need adequate infrastructure of roads, schools, doctors and dentists which is already buckling under the current pressure.

Full text:

There should be a balance of sustainable development focusing on affordable housing for young families whilst maintaining the green space and identity of a village. Any development would clearly need adequate infrastructure of roads, schools, doctors and dentists which is already buckling under the current pressure.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5695

Received: 08/11/2017

Respondent: Ms Helen Davies

Representation:

It is essential that all necessary infrastructure services required to support proposed developments are delivered in good time and especially address the cumulative requirements arising from proposed developments in and around the Sproughton area. Sproughton is frequently grid locked - additional housing will exacerbate this. Health infrastructure neeeds to be carefully considered - the current lack of GPS and over-stretched surgeries does not bode well.

Full text:

* Economy
-In addition to supporting the "Ipswich Northern Route", steps must be taken to radically improve the road network in and around Sproughton, especially the junction of the A1071 and B1113, and the junction of the A1071 and Hadleigh Road. The designation of the B1113 as an Off Network Diversion Route serves to increase the importance of the need for these improvements.

-Any increase in the number of new homes and business premises in the locality, and indeed from further afield such as Hadleigh and Sudbury, will result in further increases in traffic volumes and delays at these junctions for both personal and business users especially at peak travel times.

* Environment
-Regarding the second bullet point; new development must avoid areas which are formal flood plains or have historically acted as flood plains. An example being the land between the A14 at Sproughton and the river Gipping, and the so called 'Island Site' behind the ex British Sugar site.

-We also believe the words "where possible" should be deleted to emphasize the importance of avoiding any increase to the flood risk that will undoubtedly arise if such areas are built on.

* Healthy communities & infrastructure

-It is essential that all necessary infrastructure services required to support proposed developments are delivered in good time and especially address the cumulative requirements arising from proposed developments in and around the Sproughton area.

-Whilst the District council themselves may not provide the infrastructure services, as the planning authority it should work pro-actively with providers to ensure that infrastructure needs are clearly understood and formal commitments are made to deliver them in good time.

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5793

Received: 09/11/2017

Respondent: Little Waldingfield Parish Council

Representation:

As JLP

Full text:

As JLP

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5805

Received: 09/11/2017

Respondent: Little Cornard Parish Council

Representation:

A need for additional housing is accepted, however, the priority for Babergh councillors is to produce a plan which prioritises the needs of existing residents and presents a delivery plan to achieve acceptable standards in the future. At this point new housing and the additional resources that are required can be considered.

Full text:

A need for additional housing is accepted, however, the priority for Babergh councillors is to produce a plan which prioritises the needs of existing residents and presents a delivery plan to achieve acceptable standards in the future. At this point new housing and the additional resources that are required can be considered.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5812

Received: 09/11/2017

Respondent: Mrs Nicky Willshere

Representation:

Housing
The Economy
The Environment
Healthy Communities & Infrastructure

The priorities identified do not appear to include anything about retaining and sustaining the character and environmental feel for the existing community.

Full text:

Housing
The Economy
The Environment
Healthy Communities & Infrastructure

The priorities identified do not appear to include anything about retaining and sustaining the character and environmental feel for the existing community.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5929

Received: 09/11/2017

Respondent: Stowmarket Society

Representation:

You give the impression that you are committed to both the northern Ipswich by-pass and the Sudbury western by-pass, but can you really say this at this stage? They are both hugely contentious in environmental terms, and could only be supported if the benefits outweighed the harm. Nobody knows yet what these benefits and dis-benefits will actually be. We suggest you need to be more circumspect at this stage - support investigation, but not yet commit the Councils to the projects.

Full text:

You give the impression that you are committed to both the northern Ipswich by-pass and the Sudbury western by-pass, but can you really say this at this stage? They are both hugely contentious in environmental terms, and could only be supported if the benefits outweighed the harm. Nobody knows yet what these benefits and dis-benefits will actually be. We suggest you need to be more circumspect at this stage - support investigation, but not yet commit the Councils to the projects.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5986

Received: 09/11/2017

Respondent: Endurance Estates

Agent: Savills

Representation:

Whilst reference is made to "delivery of the right types of homes" , the vision should acknowledge the need to accelerate that delivery. In circumstances where authorities have underdelivered in the past, it is only appropriate that those same Councils acknowledge past deficiencies and address such matters in reviews of their own development plans .

First bullet point should begin with the words "To accelerate delivery to address need"

Full text:

Whilst reference is made to "delivery of the right types of homes" , the vision should acknowledge the need to accelerate that delivery. In circumstances where authorities have underdelivered in the past, it is only appropriate that those same Councils acknowledge past deficiencies and address such matters in reviews of their own development plans .

First bullet point should begin with the words "To accelerate delivery to address need"

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5990

Received: 09/11/2017

Respondent: Endurance Estates

Agent: Savills

Representation:

The document begins by setting a vision for an 'ambitious yet sustainable growth agenda'. The first of four key priorities is housing. In terms of the associated objective to deliver 'the right homes, of the right tenure in the right place to meet need', the plan fails to express at the outset that an ambitious approach should be one that increases the number and rate of new houses being built to meet the needs of the community.

Full text:

The document begins by setting a vision for an 'ambitious yet sustainable growth agenda'. The first of four key priorities is housing. In terms of the associated objective to deliver 'the right homes, of the right tenure in the right place to meet need', the plan fails to express at the outset that an ambitious approach should be one that increases the number and rate of new houses being built to meet the needs of the community.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 5996

Received: 06/11/2017

Respondent: Neil Fuller

Representation:

* Development should be demonstrably sustainable (economic, social and environmental) in the right place, of the right type/quality and which meets the local need rather than being developer led.

Full text:

Please could you email confirm receipt of my submission and include me in the mailing list for updates on the progress of the Local Plan.

SECTION 1 - STRATEGIC
Vision
* Development should be demonstrably sustainable (economic, social and environmental) in the right place, of the right type/quality and which meets the local need rather than being developer led.
Objectives
* Environmental assets need to be protected and enhanced to meet biodiversity duties and quality of life objectives. The housing provision should seek to provide suitable housing that meet the needs of local residents.
* The section of B1113 that runs through the heart of the village is inadequate to function as an Off Network Diversion Route. It currently already struggles to accommodate the existing flows during peak traffic flow, with an adverse impact on pedestrian safety and local air quality. The local road networks are all under strain and require strategic enhancement to ensure the village experience is enhanced. piecemeal and opportunistic . This may include especially the "Ipswich Northern Route" and improvements to the A1071 at B1113 and Hadleigh Road junctions, and an access onto the A14. The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
* Ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time and without back paddling -Planning needs to be pro-active on this.
Priorities
* Development shouldn't lead to communities losing their identities by swamping and creeping coalescence (merging of communities).
* Location of growth to be spread more pragmatically across Babergh rather than fewer large sites
* MOST IMPORTANT FOR SPROUGHTON - transport infrastructure, school places, accessible healthcare services, enhance environmental assets.
Duty to Cooperate
* Ipswich say they have insufficient land to meet their projected housing numbers which means under the 'Duty to Cooperate' surrounding district councils must assist in finding land to accommodate Ipswich housing overspill. In this case around 4000 dwellings - how are Babergh proposing to help meet this requirement? Babergh should NOT be picking up all 4000.
SECTION 2 - DELIVERY
Housing Requirement, Settlement Hierarchy and Housing Distribution

Housing Requirement 2014 to 2036 - Option HR1 - 7,820 new houses based on population growth.
* DON'T AGREE WITH THIS - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
* Relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability.
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated
Contingency and Delivery
* Current 'stuck' sites with permissions and no building suggests need for contingency going forward - replace 'stuck' sites with others.

* Contingency sites to be replacement and not additional, original sites to be taken out of plan. Regular review of demand required checking the guiding principles of type, tenure, place and need (local) - should trigger need for reserve sites.

Hierarchy
* Village status distorted by scoring system, influences development location.
* Sproughton classed as CORE and also HINTERLAND village, can't be both.
* DON'T AGREE WITH APPROACH TAKEN - scoring based on distance to services and facilities; should be based on travel time as accessibility overstated.
* No account taken of capacity of a service in scoring (eg Primary School/shops (Sproughton identified as having a P.O.!)
* Positive scoring factors in this Hierarchy assessment are actually negative factors against Creeping Coalescence (i.e. the erosion of as communities' individuality) they therefore fly in the face of the NPPF and unfairly place Sproughton into the main settlement types.
* We would support reconsideration of the scoring criteria adopted to include fairly balanced negative scores for the threat of Creeping Coalescence.

Spatial Distribution
* Four options offered: 1) County Town Focused, 2) Market Town/Rural balance, 3) Transport Corridor Focused. 4) New Settlement Focused. Due to the settlement types designated to Sproughton in the Hierarchy scoring the first three options propose over 50% of growth in our designations, only the last option reduces this to 35%.
* The combined arbitrary criteria for scoring of both Hierarchy and Spatial Distribution chosen by BMSDC for the JLP just appears to promote the site availability that has come forward, effectively a mechanism to justify the sites.
* JLP to 2036 gives opportunity for bold, innovative and creative thinking but continuing the urban sprawl / welding / merging communities not the answer.
* Creating well planned, self-sufficient purpose built settlements with their own identities is and thereby preserving the qualities of existing communities.

Other Distribution Options
* We would support an option for proportional distribution
* Propose carefully planned 'organic growth' of existing communities.
* The expected Babergh population growth of 8000 by 2036 (9%) could be applied to each community - Sproughton grow by 120 (50 or so new houses). Low impact on community infrastructure, encourage small scale employment enterprises, reduce the need to travel, enhance and grow the desirable aspects of communities and provided opportunities for local developers and labour to be part of the growth agenda - inward investment/wealth retained locally.
* The concept that in one house out of ten a grown up child might want their own home in the community close to their parents over a 20 year period is not just conceivable, it must be for most parents a welcomed opportunity; this matches a district wide 9% proportional distribution.
New Settlement
* This question relates to Option 4 (New Settlement Focused) of Spatial Distribution
* It is the proposition to create a new or garden town, a separate and distinct community most probably in a new location with minimal local impact but the potential to improve/create improved county infrastructure/services.
* This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally situated where it least effects existing communities but with ready access to Road and Rail links.
* Some suggestions: Near Gt Blakenham, South of Sudbury close to rail link, Somewhere between Belstead/Bentley and A12/Main Railway.

Housing Types
* National space standards should apply with provision for storage.
* Requirements for provision of accessible homes and bungalows on 10+ developments are becoming a necessity.
* Self Builds support local economy and rural outlook so should be encouraged.
* Provisions for Affordable homes should also consider Starter homes which are more appropriate to support growth of local community.
* Housing mix should consider need not greatest developers profits.

Older persons
* We support policies that increase the provision of Bungalows and Accessible housing
* A factor apparently ignored is that we are living longer, and the number of retired people selling high value houses in city areas migrating to the area. The aging population is looking for bungalows but they will also need more care so there will be a need to increase health and care infrastructure.

Affordable housing
* We support the retention of a 35% affordable housing target, but it should be more robustly enforced.
* The total need for affordable house suggested is 19.4%. This is a drop from the previous policy of 35% in the face of a 71% local increase in private rentals (i.e. homes being bought up and rented to people who can't afford to buy a home), an increase in single parents looking for homes and an increase in local financial deprivation. That just doesn't stack up.
* BDC under the last Local Plan only achieved 23% affordable housing which probably was the consequence of viability arguments from developers. Perhaps the proposal to reduce this to a 20% requirement is intended to make the target achievable? But the outcome is likely to be developers making the same arguments for similar reductions bring the deliverable supply down to about 13%.
* There is not a reduction in affordable housing need, there is an increase, that is a nationally recognised fact, and BMSDC need to enforce the standing policy of 35% more robustly to achieve that. This could be improved by apply the policy to developments of three or more homes, or BMSDC engaging in the construction of council homes themselves that could all be affordable/starter homes.
* Starter homes should also be added into this mix. Sold at a discount of at least 20% below market value with a maximum sale cost of £250,000 exclusively to first time buyers these are the type of homes the local community needs.
Rural growth and development: Delivering growth, services and facilities in rural towns and villages.
* Sustainable development: at the heart of planning? This is not a recommendation to build but to build wisely. There has to be a realistic prospect that houses are needed and suitable for a given location and it would appear from the surveys done that Rural housing is needed by the expanding local resident population
* It is interesting that small and individual developments which complement the county character have come forward successfully whereas the larger strategic site's drag on. Surely an indication that individual development is for need, and therefore gets done. Whereas national developers build for profit and will hold off until they feel they can get the maximum return with no consideration for need.
* Smaller developments also assimilate into the rural, scattered hamlet, market town character of the county.
* The present policies are too restrictive on small and individual development, in that what appears to be perfectly acceptable infills and small extensions to village boarders which complement their character without oppressive change have been blocked by planning policies when large estate developments that are oppressive, change the character and destroy the individuality of local communities have been supported.
* Proportionality is key; The JLP proposes a 9% Housing need over 20 years. This equates to one new home in a ten house hamlet, but why stop there. Such growth is potentially desirable naturally matching the growth of any micro community. Generally children grow older and want their own homes within their community, why shouldn't the provision and burden be spread evenly at 9%, by hamlet, village and town.
* We would support a limit on development at a level that does not dramatically change any community. with every effort made to preserve the best of the local landscape, views and ecology.

Gypsies and travellers
* Although policy relates to both BDC and Mid Suffolk the report suggests that need is M.S. The Cromer incident occurred when travellers gathered in large numbers therefore, limiting sites to short stay and small number of vehicles (say 3 days/3 plots) with sites well spread apart (say 20 miles) is safer for communities.

Economy
* A fundamental oversight is that the effects of Brexit has not been considered, either in trade, employment or migration calculations.
* JLP 20 year projections based on historic data, all pre Brexit Vote, and the bulk of growth came from migration, so are likely to be very over optimistic.
* Council finances dependent on growth but projections appear optimistic. The finances of every council depend on attracting growth so this is nationally competitive and yet there is no policy to achieve that, just wishful thinking. The Sugar Beet Factory site alone is already more land than the projected requirement for employment land with a total oversupply of 187 hectares (identified need is 12.3 hectares).
* Commercial brownfield sites should be considered in preference to greenfield for all types of development.
* Need for Northern Ipswich Bypass
* Improvements to A1071 junctions through Sproughton
* A1071 link directly with A14 to improve access into developing BDC area.
* Better Railway Service (expensive service and Ipswich station has limited access)
* Private sector building has been constant for decades, its Council building that has dropped off.
* We would support a policy for the Council to start building themselves.

Retail
* Call for sites did not actually bring forward any retail sites however there is a massive oversupply of Commercial sites that could accommodate Retail/Leisure parks if growth projections realised.
* Restricting all retail growth to town centres may be too restrictive as some growth may need to be accommodated away from town centres where sites become available.
* Retail policy inclined towards town centre growth, however as a rural community this is impractical without improved parking or an efficient transport network.


* Option to protect retail facilities in smaller towns/villages which would appear to be an appropriate policy. However how or what that might amount to is unclear.
* We would support the use of the considerable oversupply of commercial sites coming forward as retail/leisure parks or even housing, especially where those sites are brownfield and have little community/environmental impact.



Environment

* Local area/spot designations like Special Landscape areas, cherished view points, wildlife, flora and fauna reserves etc. have evolved from many years' experience and often considerable efforts by communities, sometimes based on fleeting observations of rare species. They preserve the best of our environment & any policy that introduces a subjective opinion has the risk of overlooking years of experience and effort in favour of financial considerations.
* A point overlooked is the sequence of Landscape Character designations that run down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB). Does anyone know of a famous local artist?



Climate change

* Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS (Sustainable Drainage Systems) are not adequate for sustained (several day) rainfall events especially in flood zones.

* We would recommend much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk.

* In relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.



Sustainability standards

If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.

Issues to consider:

* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.

Landscape, heritage and design

* Relevant to Sproughton are SLA's (Special landscape Areas) which not only cover Chantry Vale but most of the area surrounding the village. Other local designations that relate to views, recreational and open spaces either do, or may also, relate to Sproughton.
* We support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.

* It then suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance" which is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of experience in favour of Public / Economic Need.
* The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. It is a ticking rural development time bomb.
* Important Note:
* In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.
* A Landscape Project Area is mentioned, this appears to be the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale, so a bit like the Gipping valley/Sproughton as it extends from Chantry Vale. Accordingly, this designation might be appropriate for Sproughton and the River Valley.
Design
* The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character.
* That lends itself to small developments not estates which change the character of the county.
* All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.

Infrastructure
* Overall we agree with the Infrastructure provision policy as set out. However, we believe that any developments MUST (not should) have good access to all necessary infrastructure needs that have been identified.
* Planning permission should only be granted if there is some legally binding agreement that any identified infrastructure services WILL BE delivered as will the timing of its delivery. Guarantees should be structured such that they cannot be cancelled or avoided. Planning permission should only to be granted if there is a robust and effective legal agreement in place to ensure delivery.
* We fully support and indeed, consider it essential that each scheme considers both the existing infrastructure commitments and cumulative impacts from other developments in a locality.
* It is considered essential that any new infrastructure requirements identified with a development are phased and delivered as the development progresses. Past experience has shown this has not always been the case.
* We therefore fully support Option INF 2 that provides a strategic approach over and above the NPPF for cumulative growth, but with the caveat that infrastructure policies are adhered to.
* Option INF2 specifically mentions education but this policy needs to apply to all necessary infrastructure ie from Health to Transport.

KEY ISSUES FOR SPROUGHTON: highway / transport, education, health and flood risk
KEY ISSUES FOR FUTURE: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
KEY FOR GROWTH: Ipswich northern route, A12/A14 improvements, A1071/B1113 commuter routes improvement and mitigation of effects on community, rail upgrades, flood management, recycling provision, Broadband improvements, school places & accessible healthcare (need specific policy).

Healthy Communities
* Whilst we agree with the policies outlined here, we are concerned that any existing individual communities should not lose their community identity and cohesion as a result of 'creeping coalescence 'arising from the inappropriate location of new developments.
* We consider greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. We suggest that more emphasis is given to ensuring that any necessary developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities.
* We broadly support Policy OS2 but are concerned that this does not result in the 'watering down' of existing open space provision existing within communities.
* We support Policies NROS2 and POS2 in the protection of our Open Spaces.
* -In the case of Policy CF2 whilst fully supporting this, it is considered essential that any proposals to remove existing community facilities is supported by an appropriate formal assessment carried out in conjunction with the local community.
SECTION 3 - PLACE
Functional Clusters
* Functional clusters is a way of looking at the existing spatial geography based on how communities interconnect. The functional clusters then inform the settlement hierarchy. Classification for these purposes is relevant to determining the approach to planning.
* The approach is not appropriate. Planning policy should not be based on artificial constructs, which over emphasise the role of larger settlements. Planning policy should ensure a proportional allocation of housing and employment land across the Districts in support of the characteristics and needs of existing communities.

Settlement Boundaries
* Settlement boundaries are used to identify where the principle of development has been established, a threshold of ten related dwellings is applied. land outside of this settlement boundaries is countryside.
* The JLP view is that they need redrawing to allow rural growth opportunities.
* Whereas some factors considered are appropriate the new boundaries have been drawn to include development sites that have not been delivered. Further thought needs to be given to planning consents that have been granted but not yet delivered.
* Extensions to a settlement boundary are inappropriate if existing permissions have not been delivered.
* We also feel that the determination of settlement on the basis purely of numbers is over-simplistic. The setting and historical purpose of any collection of houses is important; for example, a collection of farm workers cottages located in the countryside should not necessarily establish a basis for a larger settlement. The existence of 'community' is also important.

Potential Land for Development
The JLP proposes sites across the district which have come forward for development and which they provisionally assess as being technically acceptable. There is significantly more proposed than is needed for the 20 year supply so clearly some will be eliminated based on the strength of arguments and opinion both on validity and quantity.
*
* The consultation effectively offers an adversarial process to support or object to sites in different locations so the number of responses from Sproughton will affect the outcome.
* With respect to Sproughton, 8 sites have been identified in total (6 for housing and 2 for employment). These essentially cover most of the Chantry Vale (Wolsey Grange to the River Gipping), the old Sugar Beet site, and developments along the Loraine Way meeting up with Bramford.
* The reference numbers for the various sites identified as technically suitable in and around Sproughton are:



Site Number Description
SS1024 Land north of Hadleigh Road and west of Church Lane
SS0721* Former Sugar Beet Factory site (employment)
SS1023 Land north of Hadleigh Road and East of Church Lane
SS0191 Land west of London Road (A1214) and east of Hadleigh Road
SS0711 Land east of Loraine Way
SS0299 Land at Poplar Lane
SS0223 Land north of Burstall Lane and west of B1113
SS1026* Poplar Lane (mixed - some employment)



* The number of houses proposed for Sproughton is 2,310 (total obtained by adding up the number of house per site as per the 'Sites Submitted' document. This is a disproportionate amount of housing for Sproughton. If the net OAN is 4,210 then Sproughton has 55% of the house required allocated to it. A better approach would be to pro-rata the allocation across all parishes - this is more simplisitic as the JLP states but some tweaking could be done where appropriate. This would allow settlements to grow in a more organic way without penalising one parish in particular to the extent that it would be abosrobed into Ipswich and merge with Bramford.
Consultation question 78 asks:
Do you consider the sites identified to be appropriate for allocation or inclusion within the settlement boundary? (please explain why and quote the settlement and site reference numbers).

As a general response
On an aggregate basis, no - the sites identified are not appropriate for allocation within the settlement boundary. As a general principle, planning policy should ensure a proportional allocation of housing and employment land across the Districts, sympathetic to and in support of the characteristics and needs of existing communities. A total of 9,446 dwellings are proposed (sum of dwellings across all sites specified within the SHLAA). However, once the net number of dwellings is calculated having taken into account planning applications granted, in progress etc, the Objectively Assessed Need (OAN) is reduced to 4,210. It appears that 2,320 of these dwellings i.e. 55.11% of the total development proposed in Babergh is designated for Sproughton. This is a significant over development of Sproughton which currently has around 581 dwellings - this would be an increase of 397% in parish size. It is completely disproportionate and would result in Bramford joining with Sproughton and Sproughton being absorbed by Ipswich in the same way that Kesgrave and Rushmere-St- Andrew has been. Not so much 'creeping coalescence' as 'complete digestion'. A much fairer basis for development would be a pro-rated approach with some tweaking for those settlements that are very small in size.On an individual basis, please see below specific comments in respect of sites allocated in and around Sproughton village:
*

* Some observations to help inform any responses to individual sites in Sproughton.
SS1024: Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0721: Site appropriate for development, subject to the scheme proposal.
It is not clear to local residents, however, why - given the size of the site - a portion may not be allocated to housing.
SS1023: Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
The setting and the views into and from Chantry Vale, which are almost unique
*
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.

SS0191

Some of the site (specifically, in the south-west corner / adjacent to the existing settlement on London Road) may be appropriate for development, subject to the development of an appropriate scheme, the considerations already identified (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats), and further considerations comprising:

* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.

SS0711: Site not appropriate for development.

In addition to those matters identified as requiring further investigation in the site assessment summary (highways, environmental and heritage), additional key considerations include:

* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley) and the views to and from the river-side walks that would be impacted by the proposed site
* 'Creeping coalescence' between Bramford and Sproughton.

SS0299

Site is appropriate subject to the development of an appropriate scheme.

With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is our view, however, that the scheme as set out in the application is not appropriate and we support any challenge Sproughton Parish Council may make to any decision approving that application.

SS0223: Site not appropriate for development.

The site assessment summary notes appropriate considerations to factor into any decision (highways, landscape, heritage and allotment relocation). However, the District Councils should be in no doubt that any proposed development of a special landscape area, which also results in a loss of amenity and potentially significant negative social and economic impacts on the existing local community, is deeply objectionable.

SS1026

Site is appropriate subject to the development of an appropriate scheme.
With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is our view, however, that the scheme as set out in the application is not appropriate and we support any challenge Sproughton Parish Council may make to any decision approving that application.
Some Other issues to consider

5 Year housing supply
It is recognised that a primary reason for creating a new JLP is that the councils are failing to provide the 5 year supply of development sites. This failure may result in government taking over administration of planning applications. However this in itself throws up a multitude of questions not addressed in this JLP.
* This is becoming a problem nationwide, it is possible that the Government could set up a department to deal with all the planning applications from the massive number of councils that are failing?
* What is the main problem here? Would application based on NPPF be such a hardship when BDC is proposing policies to circumvent the environmental and social policies of the NPPF and rarely abides by their own policies if it disadvantages developers. The basic NPPF may be better.
* Councils are no longer public services, they are businesses, only the elected councillors are there to represent the community. Their primary interest is profit and loss.
* The electorate are bound by law to pay their council tax, nothing done good or bad by the council effects that income other than that by increasing the electorate they increase their income.
* On the other hand, interaction with commercial interest can generate income so for housing that will include new homes bonuses, planning fees, 106 payments, CIL etc. These are the areas they can generate extra income.
* If they loose their authority over planning, they will loose a large chunk of income.
* But if the council is failing to achieve the 5 year supply now and builders are failing to build (over 2000 approved home applications laying dormant in BDC area) why are they not setting an achievable Housing Need objective? If they can't achieve what they need now how can they expect to achieve even more? Why have they accepted data that is unreliable because it makes no consideration for Brexit when a more up to date analysis would almost certainly provide a smaller growth figure that might be achievable.
* Perhaps the answer is that the bigger the numbers the bigger the opportunity to generate income regardless of what the electorate wants.

Growth
* The data used to forecast growth is too historic as it makes no consideration for the effects of the Brexit vote, it is therefore unreliable and potentially over ambitious.
* On the back of this data the JLP proposes significant home building to accommodate significant migration into the area to fulfil the employment needs of significant growth in business/employment.
* But the JLP does little or nothing to promote growth in Business other than bring in more potential employees by building more housing.
* The government is pushing growth in the Midlands and Northern Powerhouse and they have much better business infrastructures. Suffolk cannot compete with this to attract new business unless councils introduce competitive incentives and improve the business infrastructure of the county. But this JLP proposes nothing constructive to achieve that.
* This JLP is good for business as more housing will increase the unemployed pool making it easier and often cheaper to run a business, but that doesn't mean growth.
* But if house building is not matched by business growth it will not be good for the bulk of the resident population as there will be no increase in overall wealth in the community, but the community will be supporting a bigger population.
* Developers and Councils promote growth as the ultimate objective, but for who? Take a look at London and compare it with your present lifestyle. Businesses and Councils do well in Cities, but what is the quality of life of those that live there?

New NPPF white paper imminent
* The latest consultation paper on the NPPF is proposing a cap of 40% above any LP created prior to their new proposals.
* Therefore it is entirely possible that the unrealistic housing needs proposals being proposed in our JLP could be increased by another 40% making an unrealistic growth plan impossible.

*

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6002

Received: 10/11/2017

Respondent: Sproughton Parish Council

Representation:

Identify correct priority areas but sustainable development is required in the right place, of the right type and which meets the local need.

Full text:

Identify correct priority areas but sustainable development is required in the right place, of the right type and which meets the local need.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6010

Received: 09/11/2017

Respondent: Freston Parish Council

Representation:

The vision should include the following:
* Babergh and Mid Suffolk will remain attractive largely rural areas with thriving towns and villages and an attractive, varied landscape.

* Towns and villages will each retain their distinct characters. Coalescence of settlements will be avoided.

* Effective use will be made of previously developed land to minimise the need to build on green field sites.

* Wherever new housing is provided, it will respond to identified local needs.

* All new housing will be to the highest design. .

* Natural, built and heritage assets will be protected and, wherever possible, enhanced.

Full text:

The vision should include the following:
* Babergh and Mid Suffolk will remain attractive largely rural areas with thriving towns and villages and an attractive, varied landscape.

* Towns and villages will each retain their distinct characters. Coalescence of settlements will be avoided.

* Effective use will be made of previously developed land to minimise the need to build on green field sites.

* Wherever new housing is provided, it will respond to identified local needs.

* All new housing will be to the highest design. .

* Natural, built and heritage assets will be protected and, wherever possible, enhanced.

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6302

Received: 09/11/2017

Respondent: MSDC Green Group

Representation:

There needs to be a clear vision for each district and this needs to be in context of the wider county of Suffolk especially in relation to Suffolk's aspiration to be "the Greenest County".

See our full submission for an alternative text

Full text:

There needs to be a clear vision for each district and this needs to be in context of the wider county of Suffolk especially in relation to Suffolk's aspiration to be "the Greenest County".

See our full submission for an alternative text

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6347

Received: 09/11/2017

Respondent: Mr Robin Coates

Representation:

Part of the Vision should be: 'To enhance and improve the environment for the benefit of existing residents.'

Full text:

Part of the Vision should be: 'To enhance and improve the environment for the benefit of existing residents.'

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6668

Received: 10/11/2017

Respondent: Mr Peter Powell

Representation:

The JLP vision should be to ensure houses are built where our decedents would want them built and to ensure anything our decedents would want preserved for them is preserved.
I disagree with the projected growth because if migration/immigration data is removed, which is possible post Brexit, the growth in the resident community has been negligible, virtually flat lining. But if we have to dance to the governments tune to build to keep our world credit rating up at least build them where they will do least harm as they sit there waiting for the population to catch up.

Full text:

The JLP vision should be to ensure houses are built where our decedents would want them built and to ensure anything our decedents would want preserved for them is preserved.
I disagree with the projected growth because if migration/immigration data is removed, which is possible post Brexit, the growth in the resident community has been negligible, virtually flat lining. But if we have to dance to the governments tune to build to keep our world credit rating up at least build them where they will do least harm as they sit there waiting for the population to catch up.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6795

Received: 09/11/2017

Respondent: Botesdale & Rickinghall CAP Group

Representation:

1 Vision - to develop the infrastructure for sustainable growth to promote diverse and healthy communities, whilst continuing to safeguard legacy assets, our unique County identity and our protect our conservation areas.

Full text:

1 Vision - to develop the infrastructure for sustainable growth to promote diverse and healthy communities, whilst continuing to safeguard legacy assets, our unique County identity and our protect our conservation areas.

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6846

Received: 09/11/2017

Respondent: Thurston Parish Council

Representation:

The Parish Council supports the vision as outlined in the introduction and agrees that the local plan should follow objectives covering
Housing
The Economy
The Environment
Healthy Communities & Infrastructure.

Full text:

The Parish Council supports the vision as outlined in the introduction and agrees that the local plan should follow objectives covering
Housing
The Economy
The Environment
Healthy Communities & Infrastructure.