Q1

Showing comments 91 to 120 of 174

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6847

Received: 09/11/2017

Respondent: Mrs Linda Rushton

Representation:

My vision for Babergh is sustainable growth that maintains the identity of South Suffolk in Farming, Tourism, Heritage, Employment, Infrastructure and Appropriate Housing.

Full text:

My vision for Babergh is sustainable growth that maintains the identity of South Suffolk in Farming, Tourism, Heritage, Employment, Infrastructure and Appropriate Housing.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6929

Received: 10/11/2017

Respondent: Brome and Oakley Parish Council

Representation:

If a balanced development of housing need over the 2 districts, but in particular Mid Suffolk is to be achieved, I believe that dispersed growth should be the objective, with infrastructure being a conditional part of the larger developments and in smaller villages and hamlets a preference for smaller developments, with each individual case being assessed on its own merits.

Full text:

If a balanced development of housing need over the 2 districts, but in particular Mid Suffolk is to be achieved, I believe that dispersed growth should be the objective, with infrastructure being a conditional part of the larger developments and in smaller villages and hamlets a preference for smaller developments, with each individual case being assessed on its own merits.

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 6940

Received: 09/11/2017

Respondent: Great Waldingfield PC

Representation:

should develop and improve the village aesthetics and environs for all residents living within the catchment area.

Full text:

should develop and improve the village aesthetics and environs for all residents living within the catchment area.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7082

Received: 09/11/2017

Respondent: Mr David Marsh

Representation:

The vision should include Heritage and how you propose to protect it.

Full text:

The vision should include Heritage and how you propose to protect it.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7192

Received: 09/11/2017

Respondent: Mr Andrew Sterling

Representation:

The two main developmental pressures are housing and road builidng. The vision should be concerned to accord these pressures with the absolutes of environmental health and survival re global heating, huge species depletion, and the increasing dangers of air pollution due to increasing traffic.

Actual housing need is for social housing and for communities within cycling, walking and public transport distance of work, with the emphasis on encouraging local business and shopping and discouraging car-dependent distances to facilities, such as out-of-town commercial developments. The trend therefore would be an onward process of genuine localism, economically and socially.

Full text:

The two main developmental pressures are housing and road builidng. The vision should be concerned to accord these pressures with the absolutes of environmental health and survival re global heating, huge species depletion, and the increasing dangers of air pollution due to increasing traffic.

Actual housing need is for social housing and for communities within cycling, walking and public transport distance of work, with the emphasis on encouraging local business and shopping and discouraging car-dependent distances to facilities, such as out-of-town commercial developments. The trend therefore would be an onward process of genuine localism, economically and socially.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7204

Received: 09/11/2017

Respondent: Dr DAVID Brennand

Representation:

Generally supportive subject to comment in respect of each of the key priority areas identified as further detailed at response to Q2, below.

Full text:

Generally supportive subject to comment in respect of each of the key priority areas identified as further detailed at response to Q2, below.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7234

Received: 09/11/2017

Respondent: Mr Mark Blackwell

Representation:

Should include a vision to improve the quality of life of existing residents, provide a fair and equitable plan for existing and new residents, young and old, and from all parts of society. It should include a clear determination to make any development as enviromentally friendly as possible, with communiity energy and heat generation.

Full text:

Should include a vision to improve the quality of life of existing residents, provide a fair and equitable plan for existing and new residents, young and old, and from all parts of society. It should include a clear determination to make any development as enviromentally friendly as possible, with communiity energy and heat generation.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7396

Received: 09/11/2017

Respondent: Mr Mark Blackwell

Representation:

To build communities not housing, by ensuring all new houses are within walking distance of a park, school, pub, medical centre, library, shop, bus stop etc. No new house should require a car to live there.

Full text:

To build communities not housing, by ensuring all new houses are within walking distance of a park, school, pub, medical centre, library, shop, bus stop etc. No new house should require a car to live there.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7584

Received: 10/11/2017

Respondent: Mrs Annette Brennand

Representation:

Generally supportive subject to comment in respect of each of the key priority areas identified as further detailed at response to Q2, below

Full text:

Generally supportive subject to comment in respect of each of the key priority areas identified as further detailed at response to Q2, below

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7655

Received: 10/11/2017

Respondent: Chilton Parish Council

Representation:

The vision should more directly reflect the economic sectors identified on page 10 of JLP as achieving growth namely tourism, hospitality, leisure and creative industries. Unfortunately, frequently, B8 uses are widely allocated which are not suitable for the area and create little employment.

Full text:

The vision should more directly reflect the economic sectors identified on page 10 of JLP as achieving growth namely tourism, hospitality, leisure and creative industries. Unfortunately, frequently, B8 uses are widely allocated which are not suitable for the area and create little employment.

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7820

Received: 10/11/2017

Respondent: mr michael hammond

Representation:

Vision needs to be stronger in terms of protecting and enhancing the special nature of our towns and villages .
Vision needs to be stronger on protecting and enhancing the landscape settings , the built and natural environment of our Core villages .

Full text:

Vision needs to be stronger in terms of protecting and enhancing the special nature of our towns and villages .
Vision needs to be stronger on protecting and enhancing the landscape settings , the built and natural environment of our Core villages .

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7836

Received: 10/11/2017

Respondent: Essex County Council

Representation:

It is noted that 'Key environmental issues' include 'Climate change'. Climate change will also have an impact on the amount of rainfall across both districts and this should be accounted for when considering the impact of surface water flood risk.

Full text:

It is noted that 'Key environmental issues' include 'Climate change'. Climate change will also have an impact on the amount of rainfall across both districts and this should be accounted for when considering the impact of surface water flood risk.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7883

Received: 10/11/2017

Respondent: Mrs Sarah Knibbs

Representation:

The vision should be a concise and well worded statement, without any ambiguity, that provides the foundation for the rest of the plan, to give a statement of intent for the development of our districts over the next 20 years.
All the plans for housing, economic development, environment and healthy communities and infrastructure should comply with this vision.

Full text:

The vision should be a concise and well worded statement, without any ambiguity, that provides the foundation for the rest of the plan, to give a statement of intent for the development of our districts over the next 20 years.
All the plans for housing, economic development, environment and healthy communities and infrastructure should comply with this vision.

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 7886

Received: 10/11/2017

Respondent: Hadleigh Town Council

Representation:

HTC supports the vison

Full text:

HTC supports the vison

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8285

Received: 10/11/2017

Respondent: Tattingstone Parish Council

Representation:

The vision as laid out is fine but it could go much further. Tattingstone Parish Council would place more emphasis on the Environment and on Healthy Communities and Infrastructure before considering Housing and Economy. These are both the cornerstones of why people want to live, work or visit this area of Suffolk. Without the necessary infrastructure to support transport, education, health and commerce and the protection of this beautiful area is unlikely to thrive and grow.

Full text:

The vision as laid out is fine but it could go much further. Tattingstone Parish Council would place more emphasis on the Environment and on Healthy Communities and Infrastructure before considering Housing and Economy. These are both the cornerstones of why people want to live, work or visit this area of Suffolk. Without the necessary infrastructure to support transport, education, health and commerce and the protection of this beautiful area is unlikely to thrive and grow.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8329

Received: 10/11/2017

Respondent: Essex County Council

Representation:

Page 7, left column, third paragraph under 'The Plan'. It is recommended that this paragraph include cross-boundary consultation where proposals may impact adjoining County or Local Councils located outside of Suffolk.

Full text:

Page 7, left column, third paragraph under 'The Plan'. It is recommended that this paragraph include cross-boundary consultation where proposals may impact adjoining County or Local Councils located outside of Suffolk.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8453

Received: 10/11/2017

Respondent: Redlingfield parish meeting

Representation:

Agree with vision.
However needs to recognise the impact of technology. Electric cars, carbon neutral hosing, home based working, distance learning and the availability of all manner of services delivered to the door and via the internet, means that small villages and hamlets are fast becoming fully sustainable and this needs to be recognised within the plan.
The contribution strong and healthy communities makes towards sustainability and cohesion needs to be recognised more fully with in the plan.
Economic development within rural areas needs to be provided for and encouraged to develop small rural businesses, both farm and village/hamlet based.

Full text:

Agree with vision.
However needs to recognise the impact of technology. Electric cars, carbon neutral hosing, home based working, distance learning and the availability of all manner of services delivered to the door and via the internet, means that small villages and hamlets are fast becoming fully sustainable and this needs to be recognised within the plan.
The contribution strong and healthy communities makes towards sustainability and cohesion needs to be recognised more fully with in the plan.
Economic development within rural areas needs to be provided for and encouraged to develop small rural businesses, both farm and village/hamlet based.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8608

Received: 10/11/2017

Respondent: David Black & Sons Ltd.

Representation:

Given that this consultation sets out to determine what and where development will take place up to 2036. It seems that there should be a little more emphasis on the economic development, but the focus seems targeted towards the housing needs. Where ever people live they will require employment opportunities and unless we propogate local employment opportunities too, any further rural housing will only be of a dormitory nature.
Our aspiration should be for a vibrant diversity of rural employment that allows for more of the population to live in the district in more even spatially based communities.

Full text:

Given that this consultation sets out to determine what and where development will take place up to 2036. It seems that there should be a little more emphasis on the economic development, but the focus seems targeted towards the housing needs. Where ever people live they will require employment opportunities and unless we propogate local employment opportunities too, any further rural housing will only be of a dormitory nature.
Our aspiration should be for a vibrant diversity of rural employment that allows for more of the population to live in the district in more even spatially based communities.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8697

Received: 10/11/2017

Respondent: Mrs Hannah Lord-Vince

Representation:

Development should be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. e.g. which areas in Babergh need additional housing and proportion of housing should be distributed according to this, rather than just based on what land has been offered up.

Full text:

Development should be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. e.g. which areas in Babergh need additional housing and proportion of housing should be distributed according to this, rather than just based on what land has been offered up.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8722

Received: 10/11/2017

Respondent: Mr Philip Schofield

Representation:

a collection of distributed work/play/nurture hubs interconnected by public transport that conveys both people and goods

Full text:

a collection of distributed work/play/nurture hubs interconnected by public transport that conveys both people and goods

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8744

Received: 10/11/2017

Respondent: Simon Bell

Representation:

There is insufficient focus within the Vision reflecting the high quality agricultural land within the district. Some attention to the development of agri-focused businesses and appropriate employment growth within this sector should be provided. At present, there is none.

Full text:

There is insufficient focus within the Vision reflecting the high quality agricultural land within the district. Some attention to the development of agri-focused businesses and appropriate employment growth within this sector should be provided. At present, there is none.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8830

Received: 10/11/2017

Respondent: Mr Simon Pearce

Representation:

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? 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.

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.

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8964

Received: 10/11/2017

Respondent: Mr John Smith

Representation:

The vision should be to guide the community to a zero carbon lifestyle, which involves conserving resources rather than consuming them as quickly as practicable to achieve economic growth. Going for growth or 'business as usual' is not a sustainable policy in the long or short term.
For example in housing
Why build even a single new house that has not the very smallest energy footprint that technology can currently offer?
Or in air quality management discourage the use of fossil fuels generally by applying disincentives to their use and divesting financial support via SCC pension funds?

Full text:

The vision should be to guide the community to a zero carbon lifestyle, which involves conserving resources rather than consuming them as quickly as practicable to achieve economic growth. Going for growth or 'business as usual' is not a sustainable policy in the long or short term.
For example in housing
Why build even a single new house that has not the very smallest energy footprint that technology can currently offer?
Or in air quality management discourage the use of fossil fuels generally by applying disincentives to their use and divesting financial support via SCC pension funds?

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8966

Received: 10/11/2017

Respondent: Onehouse Parish Council

Representation:

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

Full text:

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

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9162

Received: 07/11/2017

Respondent: J D Pickett

Representation:

The vision needs to be sustainable in all aspects, needs to be in the right place and of the right type and needs to meet local needs. There should be a balanced development between houses and proven employment opportunities. It needs to protect and enhance where possible the environment and it needs to provide necessary infrastructure and services. In depth the housing needs to be what the local residents need and can afford, the already strained roads need to be radically improved and delivery of the necessary infrastructure needs to be in place in good time, not promised and then not delivered.

Full text:

Dear Sir

Please send confirmation of receipt of this email.

I am a resident of Sproughton and would like to give my opinions and concerns over some of the elements of the local plan which I have issue with.

Questions 1 - 5 - Vision, Objectives and Priorities

The vision needs to be sustainable in all aspects, needs to be in the right place and of the right type and needs to meet local needs. There should be a balanced development between houses and proven employment opportunities. It needs to protect and enhance where possible the environment and it needs to provide necessary infrastructure and services. In depth the housing needs to be what the local residents need and can afford, the already strained roads need to be radically improved and delivery of the necessary infrastructure needs to be in place in good time, not promised and then not delivered.

Development needs to be sympathetic to the surroundings and not overwhelm existing villages and end up with a sprawling Ipswich which absorbs the surrounding villages.

The number of houses currently under consideration would completely overwhelm both Sproughton and Bramford, the number of houses built needs to be in proportion to the number of homes already in place.

Sproughton is already used as a "rat run" and when the Orwell Bridge is closed comes to a standstill as vehicles try to find ways around the traffic jam, the road infrastructure is already inadequate and will not cope with a large number of additional houses.

Questions 7 - 15 - Housing Requirement, Settlement Hierarchy and Housing Distribution.

The number of houses required seems to be overstated and takes little or no account of the effects of amongst other things, BREXIT and the relocation of major industries, etc.

I also have an issue with the designation of Sproughton as both CORE and HINTERLAND, I do not believe it can be both, and just to be clear, Sproughton does not have a P.O. as stated in your documentation.

I believe a more organic growth would be best for existing communities. Smaller housing developments would also encourage the use of local builders rather than the national companies who do not employ many local people.

Questions 16 - 25 - Housing Types and Affordable Housing

There has been an erosion of the 35% Affordable housing requirement, I understand that Babergh is currently running at 23%, this must not continue. Developers must be made to build the right amount of affordable housing, the right amount of infrastructure and provide the right services from the start of the build, not leave it until the last and then not do it.

Questions 26 - 28 - Rural Growth and Development

Predicted homes growth need across Babergh is 9%, equivalent to 1 or 2 new houses in a small hamlet or village including ribbon development. If this is propagated across the whole District you have the growth combined with more sympathetic organic community growth.

Questions 33 - 41 Economic Needs

There is currently an oversupply of 187 hectares of existing employment areas and land. These are mostly brownfield and should be used in preference to Greenfield sites.

Questions 51 - 62 Biodiversity, Climate Change, Landscape, Heritage and Design

Designated sites, habitats and species need to protected and enhanced as per Option BIO2.

Communities should have more input into landscape impacts of any developments at a stage early enough to make a difference. There needs to be a better balance of decisions over landscape impacts vv growth objectives

Lessons need to be learned from design mistakes of the past, development should blend with the landscape not overwhelm it.

Questions 63 - 68 infrastructure

I would like to support Option INF2 - to have a local strategic infrastructure policy to manage local provision to supplement the NPPF.

Questions 74 -79 - Place

Finally I consider the amount of development proposed for Sproughton is disproportionate at 55.11% of all development proprosed for Babergh. It would increase the size of Sproughton by 397% and mean that Sproughton merges with Bramford and Ipswich.

Planning policy should ensure a proportional allocation of housing and employment land across the District in support of the characteristics and needs of existing communities. This would be perceived as fairer.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9178

Received: 08/11/2017

Respondent: Mr Ken Seager

Representation:

Developments must be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. This must be more than a sound bite: it must be used as a test at every stage of development, and the four tests (sustainable, place, type, need) applied objectively.

Full text:

My comments broadly follow the order of the questions posed in the consultation document. There is an enormous amount of information in the document itself, and more particularly in the appendices. Whilst I appreciate the council would want to provide adequate supporting evidence for its views and preferred options, the overall effect has been to bewilder and overwhelm many people I've spoken to, and I'd include myself in that. A significant number have also been put off replying to the consultation document using the online response proforma because of its complexity.

My comments are as follows:

Q1 and 2: Vision and Objectives

Vision
Developments must be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. This must be more than a sound bite: it must be used as a test at every stage of development, and the four tests (sustainable, place, type, need) applied objectively.

Objectives

Development must be balanced between homes and employment. Encourage inward investment, protect and enhance environmental assets, provision of necessary infrastructure and services. Provision of housing must be what local residents need and can afford.
Q3: Other objectives
The plan should achieve radically improved local road networks 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.
The plan must 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.
Q4: 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.
Q5: Most important for Sproughton
Local services must be improved: transport infrastructure, school places, accessible healthcare services; and enhanced environmental assets.
Q7: Option HR1
Do NOT agree. The housing need identified in the Strategic Housing Market Assessment 2017 (SHMA) may well be overstated for the District during the life of the JLP. The report methodology uses historic patterns of migration, extrapolated forwards to arrive at a projected population growth, but no regard seems to be have been had for the likely effects on both domestic and overseas migration of the UK leaving the EU in 2019. This, and the intended tightening of immigration controls, is likely to quickly and significantly reduce the amount of inward migration and significantly increase the amount of outward migration in the District further, almost at the same time as the JLP itself is adopted. These effects are likely to reduce the forecast need for new housing during the life on the JLP.
Additionally, the potential relocation of major industries to continental Europe if a "hard" Brexit is the outcome of current negotiations is likely to further reduce demand for housing in the District and surrounding areas. Projected employment growth in the District is in the Professional and Business services sectors which may be especially vulnerable to relocation. Given the uncertainty on Brexit and levels of overseas migration, and with emphasis on the "Northern Powerhouse" and HS2, outward domestic migration could increase significantly with employment opportunities being created along the HS2 corridor rather than in East Anglia. This would reduce demand for housing in the District still further.
These potential impacts are real and significant. The JLP must take the most likely possibilities into account and be based on revised data.
The application of a "market signals uplift" is discussed in the SHMA (pp53-64). The consultants are clear that in the absence of any guidance other than an uplift should be "reasonable", a "judgement" is required. Their judgement (para 6.54 on page 63) in the case of Babergh is that a 15% uplift should be applied. Comparing the narrative summary of the case in Babergh with that of Suffolk Coastal on p64 (also judged at 15% uplift) the judgements do not seem to be equal and the uplift seems excessive in Babergh by comparison with Suffolk Coastal. All other Districts are judged at 10%.
The consultation document does not explain in simple enough detail how a projected population increase over the period of the JLP in Babergh of 8086 persons translates into an OAN of 7820 dwellings. In order to be able to comment effectively, it is important that the council's case is clearly stated in ways people can readily understand. The total dwelling figure seems incongruent with other evidence in the SHMA: the fact that over the period 2001-2015, both overseas migration and natural change were negative, and a past average occupancy of 2.3 persons per dwelling.
The JLP should also have an in-built flexibility so that the housing need can be regularly reviewed against forecasts during the life of the plan to 2036 and adjusted to take account of significant changes in demand which affect the amount, type and location of housing during that time.
Q8: Contingency
It makes sense in a plan that is expected to span such a considerable period of time for there to be some contingency provision against identified sites that cannot, for whatever reason, be developed within the specified time. In such circumstances, the activation of a contingency site should permanently remove the original intended site from the plan. In other words, each contingency activated should be a replacement within the plan for an original site that could not be developed as planned, NOT an additional site for development.

Q9: Specific measures to include

There should be a clear commitment to a regular review of the actual demand for housing against the forecasts for housing need and the JLP should be adjusted accordingly in light of this evidence.
The stated objective of delivering "the right type of homes, of the right tenure and in the right place meeting need" must be a guiding principle for every decision made by the council before and during the life of the plan. These words must be translated into action at every stage of the preparation and implementation of the plan, and used as a test at each stage of development. All four elements of the objective: type, tenure, place and need must be satisfied if the council is to hold true to its stated objective.
Regarding need, the council must be totally committed to providing only housing that meets the genuine needs of the residents of Babergh, not the needs of the housebuilders and their desire for profit.

Q10: Trigger factors

Replacement, not addition! Reserve sites should be considered when something prevents an originally-identified site from being developed within the intended time scale. If there is a need to bring reserve site(s) forward, these should be instead of, not as well as, the originally-intended site(s).

Q11: Proposed criteria approach

Do NOT agree. In principle, the approach seems appropriate. However, it is unclear from the evidence whether account has been taken of the capacity of each Key and Supporting Service to deliver services in a community, or whether it is simply the presence of such services that has been scored when compiling the hierarchy. An example would be primary schools: the mere presence of a primary school in a community does not give any guarantees regarding availability of places at that school, as it may already be at capacity (medical services would be the same). This factor is especially important in the case of Sproughton which has few Key Services of its own. Here the assumption is that services located in Ipswich and elsewhere within 5 km are available to Sproughton residents, and a score of 2 and 1 is given for being within 5km of a Town and Core Village respectively.
Scoring for the hierarchy based purely on measured distance (i.e. 5 km) does not make sense. In many places, the time it would take to actually travel that distance would preclude the use of the services and facilities that might be there. A measurement based on time to access neighbouring facilities would be a more realistic measurement of how accessible such facilities were in practice.
Furthermore, accessing neighbouring facilities in the case of Sproughton would nearly always require the use of a car due to the lack of sustainable alternatives: safe cycle lanes, pedestrian footpaths and the frequency of public transport.
Note: Sproughton is classed as a "Core Village" in Table 2 (p6) of BMSDC Topic Paper: Settlement Hierarchy Review - August 2017, but as a "Hinterland Village" in the Appendix (Services and Facilities Matrix) to the same document.
There is no post office in Sproughton, yet it scores 1 for having a post office! How much care has been taken in the review, and how recent it the data in it?
Overall the status of Sproughton is unclear and the actual facilities located within it and genuinely accessible in neighbouring settlements are overstated, casting doubt on the scoring in the hierarchy.

Q12: Joint Settlement Hierarchy

See the answer above for doubts about its validity

Q13: Spatial Distribution Options

Of the options proposed in the document, BHD4

However, the production of a JLP covering over 25 years of planning and development presents the Council with an opportunity to be bold, innovative and creative in its thinking. The consultation document acknowledges that national planning policy "encourages councils to consider whether growth could be accommodated through the planning of new settlements - either garden towns of villages.", and that "opportunities are available to bring in enhanced government investment funds to help plan and support these areas".
Simply continuing the urban sprawl, and relying on shoring up already overstretched local services in the hope that they can cope with increased demands lacks imagination. The creation of a new purpose built settlement or settlements, carefully planned with adequate and modern services and infrastructure, allows that community to establish its own unique identity rather than adopting someone else's, adding to diversity of the District's communities. It also adds greater value and attractiveness to those seeking new homes in Babergh. The creation of new settlements may not, of itself, lead to improvement of services, infrastructure, environment, biodiversity, etc. elsewhere in Babergh, but it is less likely to damage it whilst at the same time preserving as much as possible of what is already here and valued for what it is.

Q14: Other options

Carefully-planned organic growth of existing communities across the District - By far the best option, despite being ruled out early on as "too simplistic"

This approach would provide the necessary additional housing without impacting so heavily or disproportionately on existing communities, preserving rather than destroying their unique identities. It could act as a catalyst to improve and update existing services, infrastructure and facilities for all Babergh's residents, on a scale that would be both acceptable and sustainable. It could accommodate new employment opportunities through small local enterprises, reducing the need for people to travel long distances to work, encouraging cycling and walking and reducing emissions. Such an approach, carefully managed, would enhance all those things which make Babergh a desirable place to live and work
Having more but smaller development projects would also impact positively on local employment, providing opportunities for local developers and associated construction tradespeople to bid for contracts to build.

Q15: Where?

This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally, it should be 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.

Q16-25 Housing Types and Affordable Housing

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.
I 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 ageing population is looking for bungalows but they will also need more care so there will be a need to increase health and care infrastructure.
I 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.
Q26-28 Rural Growth and Development

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 sites drag on. Surely an indication that individual development is best 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.
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.
Q33-41 Economic Needs
A fundamental oversight is that the effects of Brexit have 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.
There is an overwhelming case for a Northern Ipswich Bypass
Improvements to A1071 junctions through Sproughton are urgently required
A1071 link directly with A14 to improve access into developing BDC area and to reduce traffic congestion in Sproughton
Better Railway Service (expensive service and Ipswich station has limited access)
Private sector building has been constant for decades, it's Council building that has dropped off.
I strongly support a policy for the Council to start building themselves.
Q51: Biodiversity
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 Holiday 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).
Q52-54: 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.
 would want to see 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.
n 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.
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.
Q55-62: Landscape, Heritage and Region
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.
I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
I am concerned that the JLP suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance". 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.
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.
Q63-68: Infrastructure

Overall I agree with the Infrastructure provision policy as set out. However, I 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.
 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 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.
 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 i.e. from Health to Transport.
KEY ISSUES FOR SPROUGHTON are: highway / transport, education, health and flood risk
KEY ISSUES FOR FUTURE are: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
KEY FOR GROWTH are: 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.

Q69-73: Healthy Communities

Whilst I agree with the policies outlined in the consultation document, I am 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.
think 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.
broadly support Policy OS2 but are concerned that this does not result in the 'watering down' of existing open space provision existing within communities.
 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.
Q74-78: 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

The JLP view is that settlement boundaries 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.
 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.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9219

Received: 08/11/2017

Respondent: Mrs Mel Seager

Representation:

Vision
Developments must be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. This must be more than a sound bite: it must be used as a test at every stage of development, and the four tests (sustainable, place, type, need) applied objectively.

Full text:

My comments are as follows:

Q1 and 2: Vision and Objectives

Vision
Developments must be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. This must be more than a sound bite: it must be used as a test at every stage of development, and the four tests (sustainable, place, type, need) applied objectively.

Objectives

Development must be balanced between homes and employment. Encourage inward investment, protect and enhance environmental assets, provision of necessary infrastructure and services. Provision of housing must be what local residents need and can afford.
Q3: Other objectives
The plan should achieve radically improved local road networks 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.
The plan must 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.
Q4: 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.
Q5: Most important for Sproughton
Local services must be improved: transport infrastructure, school places, accessible healthcare services; and enhanced environmental assets.
Q7: Option HR1
Do NOT agree. The housing need identified in the Strategic Housing Market Assessment 2017 (SHMA) may well be overstated for the District during the life of the JLP. The report methodology uses historic patterns of migration, extrapolated forwards to arrive at a projected population growth, but no regard seems to be have been had for the likely effects on both domestic and overseas migration of the UK leaving the EU in 2019. This, and the intended tightening of immigration controls, is likely to quickly and significantly reduce the amount of inward migration and significantly increase the amount of outward migration in the District further, almost at the same time as the JLP itself is adopted. These effects are likely to reduce the forecast need for new housing during the life on the JLP.
Additionally, the potential relocation of major industries to continental Europe if a "hard" Brexit is the outcome of current negotiations is likely to further reduce demand for housing in the District and surrounding areas. Projected employment growth in the District is in the Professional and Business services sectors which may be especially vulnerable to relocation. Given the uncertainty on Brexit and levels of overseas migration, and with emphasis on the "Northern Powerhouse" and HS2, outward domestic migration could increase significantly with employment opportunities being created along the HS2 corridor rather than in East Anglia. This would reduce demand for housing in the District still further.
These potential impacts are real and significant. The JLP must take the most likely possibilities into account and be based on revised data.
The application of a "market signals uplift" is discussed in the SHMA (pp53-64). The consultants are clear that in the absence of any guidance other than an uplift should be "reasonable", a "judgement" is required. Their judgement (para 6.54 on page 63) in the case of Babergh is that a 15% uplift should be applied. Comparing the narrative summary of the case in Babergh with that of Suffolk Coastal on p64 (also judged at 15% uplift) the judgements do not seem to be equal and the uplift seems excessive in Babergh by comparison with Suffolk Coastal. All other Districts are judged at 10%.
The consultation document does not explain in simple enough detail how a projected population increase over the period of the JLP in Babergh of 8086 persons translates into an OAN of 7820 dwellings. In order to be able to comment effectively, it is important that the council's case is clearly stated in ways people can readily understand. The total dwelling figure seems incongruent with other evidence in the SHMA: the fact that over the period 2001-2015, both overseas migration and natural change were negative, and a past average occupancy of 2.3 persons per dwelling.
The JLP should also have an in-built flexibility so that the housing need can be regularly reviewed against forecasts during the life of the plan to 2036 and adjusted to take account of significant changes in demand which affect the amount, type and location of housing during that time.
Q8: Contingency
It makes sense in a plan that is expected to span such a considerable period of time for there to be some contingency provision against identified sites that cannot, for whatever reason, be developed within the specified time. In such circumstances, the activation of a contingency site should permanently remove the original intended site from the plan. In other words, each contingency activated should be a replacement within the plan for an original site that could not be developed as planned, NOT an additional site for development.

Q9: Specific measures to include

There should be a clear commitment to a regular review of the actual demand for housing against the forecasts for housing need and the JLP should be adjusted accordingly in light of this evidence.
The stated objective of delivering "the right type of homes, of the right tenure and in the right place meeting need" must be a guiding principle for every decision made by the council before and during the life of the plan. These words must be translated into action at every stage of the preparation and implementation of the plan, and used as a test at each stage of development. All four elements of the objective: type, tenure, place and need must be satisfied if the council is to hold true to its stated objective.
Regarding need, the council must be totally committed to providing only housing that meets the genuine needs of the residents of Babergh, not the needs of the house builders and their desire for profit.

Q10: Trigger factors

Replacement, not addition! Reserve sites should be considered when something prevents an originally-identified site from being developed within the intended time scale. If there is a need to bring reserve site(s) forward, these should be instead of, not as well as, the originally-intended site(s).

Q11: Proposed criteria approach

Do NOT agree. In principle, the approach seems appropriate. However, it is unclear from the evidence whether account has been taken of the capacity of each Key and Supporting Service to deliver services in a community, or whether it is simply the presence of such services that has been scored when compiling the hierarchy. An example would be primary schools: the mere presence of a primary school in a community does not give any guarantees regarding availability of places at that school, as it may already be at capacity (medical services would be the same). This factor is especially important in the case of Sproughton which has few Key Services of its own. Here the assumption is that services located in Ipswich and elsewhere within 5 km are available to Sproughton residents, and a score of 2 and 1 is given for being within 5km of a Town and Core Village respectively.
Scoring for the hierarchy based purely on measured distance (i.e. 5 km) does not make sense. In many places, the time it would take to actually travel that distance would preclude the use of the services and facilities that might be there. A measurement based on time to access neighbouring facilities would be a more realistic measurement of how accessible such facilities were in practice.
Furthermore, accessing neighbouring facilities in the case of Sproughton would nearly always require the use of a car due to the lack of sustainable alternatives: safe cycle lanes, pedestrian footpaths and the frequency of public transport.
Note: Sproughton is classed as a "Core Village" in Table 2 (p6) of BMSDC Topic Paper: Settlement Hierarchy Review - August 2017, but as a "Hinterland Village" in the Appendix (Services and Facilities Matrix) to the same document.
There is no post office in Sproughton, yet it scores 1 for having a post office! How much care has been taken in the review, and how recent it the data in it?
Overall the status of Sproughton is unclear and the actual facilities located within it and genuinely accessible in neighbouring settlements are overstated, casting doubt on the scoring in the hierarchy.

Q12: Joint Settlement Hierarchy

See the answer above for doubts about its validity

Q13: Spatial Distribution Options

Of the options proposed in the document, BHD4

However, the production of a JLP covering over 25 years of planning and development presents the Council with an opportunity to be bold, innovative and creative in its thinking. The consultation document acknowledges that national planning policy "encourages councils to consider whether growth could be accommodated through the planning of new settlements - either garden towns of villages.", and that "opportunities are available to bring in enhanced government investment funds to help plan and support these areas".
Simply continuing the urban sprawl, and relying on shoring up already overstretched local services in the hope that they can cope with increased demands lacks imagination. The creation of a new purpose built settlement or settlements, carefully planned with adequate and modern services and infrastructure, allows that community to establish its own unique identity rather than adopting someone else's, adding to diversity of the District's communities. It also adds greater value and attractiveness to those seeking new homes in Babergh. The creation of new settlements may not, of itself, lead to improvement of services, infrastructure, environment, biodiversity, etc. elsewhere in Babergh, but it is less likely to damage it whilst at the same time preserving as much as possible of what is already here and valued for what it is.

Q14: Other options

Carefully-planned organic growth of existing communities across the District - By far the best option, despite being ruled out early on as "too simplistic"

This approach would provide the necessary additional housing without impacting so heavily or disproportionately on existing communities, preserving rather than destroying their unique identities. It could act as a catalyst to improve and update existing services, infrastructure and facilities for all Babergh's residents, on a scale that would be both acceptable and sustainable. It could accommodate new employment opportunities through small local enterprises, reducing the need for people to travel long distances to work, encouraging cycling and walking and reducing emissions. Such an approach, carefully managed, would enhance all those things which make Babergh a desirable place to live and work
Having more but smaller development projects would also impact positively on local employment, providing opportunities for local developers and associated construction tradespeople to bid for contracts to build.

Q15: Where?

This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally, it should be 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.

Q16-25 Housing Types and Affordable Housing

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.
I 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 ageing population is looking for bungalows but they will also need more care so there will be a need to increase health and care infrastructure.
I 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.
Q26-28 Rural Growth and Development

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 sites drag on. Surely an indication that individual development is best 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.
I 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.
Q33-41 Economic Needs
A fundamental oversight is that the effects of Brexit have 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.
There is an overwhelming case for a Northern Ipswich Bypass
Improvements to A1071 junctions through Sproughton are urgently required
A1071 link directly with A14 to improve access into developing BDC area and to reduce traffic congestion in Sproughton
Better Railway Service (expensive service and Ipswich station has limited access)
Private sector building has been constant for decades, it's Council building that has dropped off.
I strongly support a policy for the Council to start building themselves.
Q51: Biodiversity
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 Holiday 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).
Q52-54: 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.
I would want to see 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.
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.
Q55-62: Landscape, Heritage and Region
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.
I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
I am concerned that the JLP suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance". 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.
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 Gippingvalley/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.
Q63-68: Infrastructure

Overall I agree with the Infrastructure provision policy as set out. However, I 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.
I 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 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.
I 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 i.e. from Health to Transport.
KEY ISSUES FOR SPROUGHTON are: highway / transport, education, health and flood risk
KEY ISSUES FOR FUTURE are: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
KEY FOR GROWTH are: 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.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9268

Received: 08/11/2017

Respondent: Elmsett Parish Council

Representation:

In respect of the plan our vision for the future is to have sustainable growth with facilities for life such as resilient power, water, waste, transport and broadband. In particular we look for good schooling, convenience shopping and some employment in the village. The plan needs to take account of changes such as increased home working and home deliveries.

Full text:

Dear sirs

BABERGH AND MID SUFFOLK JOINT LOCAL PLAN CONSULTATION

Set out below are the comments of Elmsett Parish Council on the Consultation Document of August 2017

Settlement Hierarchy

Firstly we would like to correct a factual mistake in the plan. On page 25 of the Plan Elmsett is wrongly recorded as a Core Village. When you examine APPENDIX 1 - Services and Facilities Matrix of the Joint Local Plan Regulation 18 Consultation Topic Paper - Settlement Hierarchy Review August 2017 it shows that Elmsett has a total of 18 points. However, under the Recreation category Elmsett does not have Allotments (deduct 1 point) and under the Public Transport Category Elmsett does not have daily peak time services to/from a higher order settlement (deduct 2 points). When these 3 points are taken from the assessment Elmsett totals 15 points and correctly ranks as a Hinterland Village. We will be pleased for you to recognise this fact and inform us that you will correct the classification of Elmsett as a Hinterland Village.

Vision and Objectives P13

In respect of the plan our vision for the future is to have sustainable growth with facilities for life such as resilient power, water, waste, transport and broadband. In particular we look for good schooling, convenience shopping and some employment in the village. The plan needs to take account of changes such as increased home working and home deliveries.

Housing Requirement Page 19

We find it difficult to understand the so called objectively assessed need for 7820 new homes from 2014 to 2036 and do not believe it is a proven need.


Spatial Distribution Page 29

In terms of spatial distribution we believe that the path you should follow is county town focused and our concern is how you then allocate the percentage of new homes in the Hinterland Village category as we believe there should be a roughly even proportion of the total for that category spread across all of the Hinterland Villages. Employment allocations should have a different criteria, based on the ability of the transport network.

Retail P54

We think it is important to protect A1-A5 land uses in Core and Hinterland villages as local shopping is very important to rural life (Q50).

Infrastructure P65

With respect to infrastructure we consider all categories on page 65 are important but our sub-standard road access in particular is problematic and we believe telecommunications and Foul sewerage are stretched or at capacity

We do agree that functional clusters for villages work (Q74)

Potential Land for Development P77

We do not believe that all the sites identified for Elmsett are needed as this would lead to a gross overdevelopment for the village (Q78). Site SS0212 has just been approved for 41 dwellings and part of SS0232 was approved for 7 dwellings in June this year. That is at least 48 new dwellings, 15% more than existing and we believe this may well be enough for the village for the plan period.

Experience has shown us that development and particularly in small villages does need to be controlled and kept to a level that allows an assimilation of the new growth into the social fabric of the village. Too much development delivered too quickly will tend to produce 'social ghetto's' within the existing community.

We trust our comments will be reflected in the next draft of the document and look forward to your early confirmation of Elmsett as a Hinterland Village.

Yours faithfully





Alan Newman
Chairman, Elmsett PC

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9304

Received: 08/11/2017

Respondent: Mrs Mel Seager

Representation:

Vision
Developments must be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. This must be more than a sound bite: it must be used as a test at every stage of development, and the four tests (sustainable, place, type, need) applied objectively.

Full text:

My comments are as follows:

Q1 and 2: Vision and Objectives

Vision
Developments must be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. This must be more than a sound bite: it must be used as a test at every stage of development, and the four tests (sustainable, place, type, need) applied objectively.

Objectives

Development must be balanced between homes and employment. Encourage inward investment, protect and enhance environmental assets, provision of necessary infrastructure and services. Provision of housing must be what local residents need and can afford.
Q3: Other objectives
The plan should achieve radically improved local road networks 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.
The plan must 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.
Q4: 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.
Q5: Most important for Sproughton
Local services must be improved: transport infrastructure, school places, accessible healthcare services; and enhanced environmental assets.
Q7: Option HR1
Do NOT agree. The housing need identified in the Strategic Housing Market Assessment 2017 (SHMA) may well be overstated for the District during the life of the JLP. The report methodology uses historic patterns of migration, extrapolated forwards to arrive at a projected population growth, but no regard seems to be have been had for the likely effects on both domestic and overseas migration of the UK leaving the EU in 2019. This, and the intended tightening of immigration controls, is likely to quickly and significantly reduce the amount of inward migration and significantly increase the amount of outward migration in the District further, almost at the same time as the JLP itself is adopted. These effects are likely to reduce the forecast need for new housing during the life on the JLP.
Additionally, the potential relocation of major industries to continental Europe if a "hard" Brexit is the outcome of current negotiations is likely to further reduce demand for housing in the District and surrounding areas. Projected employment growth in the District is in the Professional and Business services sectors which may be especially vulnerable to relocation. Given the uncertainty on Brexit and levels of overseas migration, and with emphasis on the "Northern Powerhouse" and HS2, outward domestic migration could increase significantly with employment opportunities being created along the HS2 corridor rather than in East Anglia. This would reduce demand for housing in the District still further.
These potential impacts are real and significant. The JLP must take the most likely possibilities into account and be based on revised data.
The application of a "market signals uplift" is discussed in the SHMA (pp53-64). The consultants are clear that in the absence of any guidance other than an uplift should be "reasonable", a "judgement" is required. Their judgement (para 6.54 on page 63) in the case of Babergh is that a 15% uplift should be applied. Comparing the narrative summary of the case in Babergh with that of Suffolk Coastal on p64 (also judged at 15% uplift) the judgements do not seem to be equal and the uplift seems excessive in Babergh by comparison with Suffolk Coastal. All other Districts are judged at 10%.
The consultation document does not explain in simple enough detail how a projected population increase over the period of the JLP in Babergh of 8086 persons translates into an OAN of 7820 dwellings. In order to be able to comment effectively, it is important that the council's case is clearly stated in ways people can readily understand. The total dwelling figure seems incongruent with other evidence in the SHMA: the fact that over the period 2001-2015, both overseas migration and natural change were negative, and a past average occupancy of 2.3 persons per dwelling.
The JLP should also have an in-built flexibility so that the housing need can be regularly reviewed against forecasts during the life of the plan to 2036 and adjusted to take account of significant changes in demand which affect the amount, type and location of housing during that time.
Q8: Contingency
It makes sense in a plan that is expected to span such a considerable period of time for there to be some contingency provision against identified sites that cannot, for whatever reason, be developed within the specified time. In such circumstances, the activation of a contingency site should permanently remove the original intended site from the plan. In other words, each contingency activated should be a replacement within the plan for an original site that could not be developed as planned, NOT an additional site for development.

Q9: Specific measures to include

There should be a clear commitment to a regular review of the actual demand for housing against the forecasts for housing need and the JLP should be adjusted accordingly in light of this evidence.
The stated objective of delivering "the right type of homes, of the right tenure and in the right place meeting need" must be a guiding principle for every decision made by the council before and during the life of the plan. These words must be translated into action at every stage of the preparation and implementation of the plan, and used as a test at each stage of development. All four elements of the objective: type, tenure, place and need must be satisfied if the council is to hold true to its stated objective.
Regarding need, the council must be totally committed to providing only housing that meets the genuine needs of the residents of Babergh, not the needs of the house builders and their desire for profit.

Q10: Trigger factors

Replacement, not addition! Reserve sites should be considered when something prevents an originally-identified site from being developed within the intended time scale. If there is a need to bring reserve site(s) forward, these should be instead of, not as well as, the originally-intended site(s).

Q11: Proposed criteria approach

Do NOT agree. In principle, the approach seems appropriate. However, it is unclear from the evidence whether account has been taken of the capacity of each Key and Supporting Service to deliver services in a community, or whether it is simply the presence of such services that has been scored when compiling the hierarchy. An example would be primary schools: the mere presence of a primary school in a community does not give any guarantees regarding availability of places at that school, as it may already be at capacity (medical services would be the same). This factor is especially important in the case of Sproughton which has few Key Services of its own. Here the assumption is that services located in Ipswich and elsewhere within 5 km are available to Sproughton residents, and a score of 2 and 1 is given for being within 5km of a Town and Core Village respectively.
Scoring for the hierarchy based purely on measured distance (i.e. 5 km) does not make sense. In many places, the time it would take to actually travel that distance would preclude the use of the services and facilities that might be there. A measurement based on time to access neighbouring facilities would be a more realistic measurement of how accessible such facilities were in practice.
Furthermore, accessing neighbouring facilities in the case of Sproughton would nearly always require the use of a car due to the lack of sustainable alternatives: safe cycle lanes, pedestrian footpaths and the frequency of public transport.
Note: Sproughton is classed as a "Core Village" in Table 2 (p6) of BMSDC Topic Paper: Settlement Hierarchy Review - August 2017, but as a "Hinterland Village" in the Appendix (Services and Facilities Matrix) to the same document.
There is no post office in Sproughton, yet it scores 1 for having a post office! How much care has been taken in the review, and how recent it the data in it?
Overall the status of Sproughton is unclear and the actual facilities located within it and genuinely accessible in neighbouring settlements are overstated, casting doubt on the scoring in the hierarchy.

Q12: Joint Settlement Hierarchy

See the answer above for doubts about its validity

Q13: Spatial Distribution Options

Of the options proposed in the document, BHD4

However, the production of a JLP covering over 25 years of planning and development presents the Council with an opportunity to be bold, innovative and creative in its thinking. The consultation document acknowledges that national planning policy "encourages councils to consider whether growth could be accommodated through the planning of new settlements - either garden towns of villages.", and that "opportunities are available to bring in enhanced government investment funds to help plan and support these areas".
Simply continuing the urban sprawl, and relying on shoring up already overstretched local services in the hope that they can cope with increased demands lacks imagination. The creation of a new purpose built settlement or settlements, carefully planned with adequate and modern services and infrastructure, allows that community to establish its own unique identity rather than adopting someone else's, adding to diversity of the District's communities. It also adds greater value and attractiveness to those seeking new homes in Babergh. The creation of new settlements may not, of itself, lead to improvement of services, infrastructure, environment, biodiversity, etc. elsewhere in Babergh, but it is less likely to damage it whilst at the same time preserving as much as possible of what is already here and valued for what it is.

Q14: Other options

Carefully-planned organic growth of existing communities across the District - By far the best option, despite being ruled out early on as "too simplistic"

This approach would provide the necessary additional housing without impacting so heavily or disproportionately on existing communities, preserving rather than destroying their unique identities. It could act as a catalyst to improve and update existing services, infrastructure and facilities for all Babergh's residents, on a scale that would be both acceptable and sustainable. It could accommodate new employment opportunities through small local enterprises, reducing the need for people to travel long distances to work, encouraging cycling and walking and reducing emissions. Such an approach, carefully managed, would enhance all those things which make Babergh a desirable place to live and work
Having more but smaller development projects would also impact positively on local employment, providing opportunities for local developers and associated construction tradespeople to bid for contracts to build.

Q15: Where?

This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally, it should be 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.

Q16-25 Housing Types and Affordable Housing

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.
I 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 ageing population is looking for bungalows but they will also need more care so there will be a need to increase health and care infrastructure.
I 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.
Q26-28 Rural Growth and Development

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 sites drag on. Surely an indication that individual development is best 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.
I 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.
Q33-41 Economic Needs
A fundamental oversight is that the effects of Brexit have 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.
There is an overwhelming case for a Northern Ipswich Bypass
Improvements to A1071 junctions through Sproughton are urgently required
A1071 link directly with A14 to improve access into developing BDC area and to reduce traffic congestion in Sproughton
Better Railway Service (expensive service and Ipswich station has limited access)
Private sector building has been constant for decades, it's Council building that has dropped off.
I strongly support a policy for the Council to start building themselves.
Q51: Biodiversity
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 Holiday 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).
Q52-54: 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.
I would want to see 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.
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.
Q55-62: Landscape, Heritage and Region
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.
I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
I am concerned that the JLP suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance". 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.
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 Gippingvalley/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.
Q63-68: Infrastructure

Overall I agree with the Infrastructure provision policy as set out. However, I 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.
I 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 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.
I 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 i.e. from Health to Transport.
KEY ISSUES FOR SPROUGHTON are: highway / transport, education, health and flood risk
KEY ISSUES FOR FUTURE are: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
KEY FOR GROWTH are: 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.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9369

Received: 09/11/2017

Respondent: Beyton Parish Council

Representation:

There is currently a lack of vision but we hope this will develop. The Vision should take into account the objectives. From a Beyton point of view the Vision includes securing a good quality of life through high quality housing, supporting the local economy and village culture.

Full text:

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