Q1

Showing comments 151 to 174 of 174

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11641

Received: 10/11/2017

Respondent: Lady Valerie Hart

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:

Q1: Object & Comment
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.
Q.2: Object
Environment: The Environment definition should include heritage assets.
Healthy communities: "Supporting communities to deliver plans and projects:" CPC's
experience unfortunately has been that the views of parish councils are not welcomed nor
taken account of by BDC and opportunities to involve us as a parish council are resisted.
9 "To work with the communities of Sudbury" ... account needs to be taken of the views
of nearby communities which are affected e.g. Chilton. With regard to Chilton Woods
insufficient account has been taken of the impact upon Chilton parish, Sudbury and
surrounding communities.
Q.3: Comment
Yes. I consider that Babergh DC ("BDC") needs to work much more closely with the parish
councils. Lip service is paid to the Statement of Community Involvement.
1
The protection and enhancement of heritage assets which are an attraction to tourism should
be added as an objective.
Q.4
That housing and employment areas are allocated in areas where there is a proper need
rather than being allocated when land is offered or a planning application made. In the last
local plan the plan was 'jobs led'. Recognition needs to be given by BDC that not all the
housing and employment areas can be lumped around Sudbury. There is already a
substantial excess of employment land over forecast growth needs. These areas need to be
allocated in the Ipswich area.
Q.5: Comment
That our parish of Chilton be given proper recognition as a parish in this JLP. Further, that
BDC comply with its duty to cooperate as set out in Policy CS4 and consult and work
cooperatively with CPC with regard to the planning obligations and Section 106 provisions for
Chilton Woods. Despite our requests for such involvement they are ignored or rebuffed.
DUTY TO COOPERATE
Q.5 and Q.6
Environment protection section needs to include another statutory consultee namely Historic
Gardens Trust which is statutory consultee for historic parks and gardens as well as Heritage
England.
I consider also that it is very important for BDC to cooperate closely with parish councils
where the parish council has expressed a wish to be involved on development proposals in
its parish, especially with regard to planning obligations and Section 106 provisions.
HOUSING REQUIREMENT
I support Option HD2.
REVIEW OF THE SETTLEMENT HIERARCHY
Q.11: Object: See answer to Q12.
Q.12: Object
I refer to Chilton Parish Council's letter dated 10 November dealing with the inclusion of part
of the Parish of Chilton is included within Sudbury. I disagree. Chilton needs to have
separate recognition as a parish and I consider it should be included as a core village with
Great Waldingfield, Long Melford and Acton. The hierarchy should be amended to reflect the
above. It is totally unclear from JLP what is intended to occur to the remainder of the Parish
of Chilton which is not included in Sudbury.
SPATIAL DISTRIBUTION
Q.13: Support
The best option is BHD1. This is because the Ipswich fringe area is the area which can
contribute most to the economy and will provide opportunities for employment services and
facilities. There is too much development already coming forward on sites which are not
allocated.
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Q.14: Comment
Option BHD3 - transport corridor focused could be considered although I consider the
allocation of 25% to the Ipswich fringe area is too low and should be increased to 50% and
allocation of 30% to the urban areas and market towns and to core villages is too high and
should be decreased. Settlement needs to be around the A12 and A14 routes.
Q.15: Object
No suitable area: Chilton Woods was originally planned as a standalone new "garden town"
in past Local Plans. However, with the Illustrative Master plan it is clear that it falls far short
of a garden town. Too much development is being allocated already to the Sudbury area
and the infrastructure to support such large developments is lacking and not provided for
sufficiently in proposed developments. Any new settlement should be in the Ipswich fringe
areas but I consider option BHD4 needs a much higher percentage for the Ipswich fringe
area.
Housing Types and Affordable Housing
I support options HM2 and HM3.
Q.16: Support: Yes
Q.17
I agree no alternative planning policy is necessary for self-build and custom-build properties.
Q.18: Comment
I support requiring a certain proportion of Starter Homes on strategic housing allocations.
Q.19: Comment
Given the identified increase in the older population i.e. that the number of people aged over
65 is expected to rise by 59% by 2036, I suggest BDC should be prioritising the provision of
housing that would help enable people to live in their homes for longer and/or live in their
homes more easily.
Q.21: Comment
The Council could promote or facilitate development of homes for private rental by using land
owned by the county council or other councils which could be provided at a lower than
market price in order to benefit local residents.
Q.22: Obect and Comment
No, I consider the requirement for affordable homes should remain at the current 35%.
Q.23
My experience has been that BDC do not prioritise affordable housing over the provision of
other infrastructure where viability is an issue e.g. the acceptance of 20% - 25% affordable
housing element at Chilton Woods rather than an insistence on 35% where the county
council could have made less profit.
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Q.24
Yes, keyworkers should be given priority.
ECONOMIC NEEDS
Q.33: Comment
I prefer option EC0N1. To have a forecast jobs growth need of 2.9 hectares of employment
land in Babergh during the JLP period, whereas as at 1 April 2015, there was already 86.06
hectares in Babergh, including 20 hectares at Chilton Woods, allocated for employment
uses, there is clearly a substantial excess of employment land over forecast needs.
Accordingly, I support option EC0N1. Given the surplus, any employment land allocations
which have adverse impacts on the environment or heritage assets should be re-evaluated.
Q.34: Comment
Areas which do not have constraints on development or which, if developed, would not have
adverse impacts on the environment and/or heritage assets.
Q.35: Yes.
Consideration should be given to professional services, computing and technology,
hospitality and leisure and advanced manufacturing and engineering rather than the existing
focus on B2 and B8 uses.
Q.36: Support: Yes.
I would support non B use classes being, located away from town centres, residential areas
and rural villages.
Q.38: Object:
Given the substantial excess of employment land already available over the forecast needs, I
consider that further land does not need to be allocated.
Q.39: Support: Yes.
There are, for example, clusters of specialised professional services such as acoustic sound
engineers in Babergh.
Q.40: Comment
Any allocation of additional employment land should be in the Ipswich fringe area where
there is a demand.
BIODIVERSITY
Q.51: Support
I support option BIO 2 over option BIO 1.
LANDSCAPE, HERITAGE and DESIGN
Q.55: Support: Yes. I support Option L2.
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Q.57: Comment
LPAs have already a statutory duty to protect and enhance heritage assets. Evidence
suggests that 9 out of 10 people agree that when improving local places it is worth saving
their historic features.^ The historic environment has an important role to play in providing an
attractive, safe and sustainable place and should be regarded as a vital contributor to
improving the quality of place and quality of life. Insufficient recognition is given to this in
past local plans. Further, the JLP could pay more attention to the wishes of the local
community and also to the views of regional heritage bodies such as Suffolk Preservation
Society, The Sudbury Society and Suffolk Garden Trust. In my experience, advice from
English Heritage is not given sufficient weight and the in-house heritage advisers at BDC
should be consulted more often. A well cared for historic environment is one of the keys to
making a locality attractive to people and to encourage the retention of workers and
attracting inward investment.
Councillors sitting on the planning committee should be given more training about heritage
issues.
Q.58
A policy approach consistent with the weight afforded to non-designated assets in the NPPF
should be applied.
Q.59: Support: Yes.
Q.60: Object and Comment
There should be a design code applied to Master Plans for large developments. Master
plans need to conform to the criteria and so called "illustrative master plans" should not be
acceptable as they have no commitment to future design or layout. Therefore Master Plans
as properly defined in past Local Plans must be required.
Q.61: Comment
Yes. The Suffolk Design guide for residential areas is 16 years old now. It should be
reviewed and updated. A Design Code or design requirements should be added to the
Council's policies.
Q.62
Yes: by way of example, it was resolved to grant the Chilton Woods development outline
planning permission when in my view it fails to conform to its specific governing policy CS4 in
that a master plan has not been provided only an "illustrative master plan" which provides no
commitment as to the future design. An integrated standalone development was required.
As the Parish Council most affected I and others fear that what will happen is a piecemeal
development of some 500 houses with none of the required community facilities.
INFRASTRUCTURE
Q.63: Comment
The draft policy for managing infrastructure provision is well meaning. However, actual
experience during the period of consultation is that BDC's actions do not accord with this
intent. At the Chilton Woods proposed development where clearly a new access road into
^ Taking part: national survey of culture, leisure and sport.
5
this site at the Western Employment area needed to be provided so to avoid construction
traffic going through residential areas. I hope in the consideration of planning conditions and
SI 06 obligations it will be so imposed.
Q.64
» Traffic congestion due to the inadequate road structures and the requirement in
Sudbury to cross Ballingdon Bridge.
® Traffic frequently tails back from the bridge to the top of Ballingdon Hill causing delays.
^ HGV vehicles using B1115 which is a narrow road where there have been fatal road
traffic accidents.
® Need for new permanent school buildings rather than temporary porta-cabins.
® General lack of investment in infrastructure required when planning permissions are
granted.
® The need for SI06 provision of green open spaces and community woodland in
particular, the green buffer zone.
Q.65
Transport and traffic congestion. Increased usage of the rail line between Sudbury and
Marks Tey. More schools as there is already a shortage in the area. Given the ageing
population in Babergh increased demands on medical care and healthcare services are to be
expected.
Q.66
I consider BDC should recognise that substantial improvements to roads and transport are
needed. The housing in an area cannot keep expanding without there being equal
investment in infrastructure to support housing and economic growth.
Q.67: Comment
I regard the policy as well intentioned but Chilton Parish Council have already experienced a
complete disregard for this requirement with regard to the resolution to grant the recent
outline application for Chilton Woods.
Q.68: No
HEALTHY COMMUNITIES
Q.71
I support option NR0S2. Babergh has insufficient green open space. I also support option
CF2. I prefer Option 0S1. The weakness in 0S2 is that it will be described otherwise as an
aspiration rather than a requirement. I am concerned, in the Chilton Woods development;
insufficient protection is being effected through Section 106 and planning obligations to
protect open space, sports' facilities and the community facilities. Policies must be followed
rather than ignored when a proposed development pleads that the provision of those facilities
affects the viability of the proposed development. If not viable it should not go ahead.
Q.72: Yes, please see Chilton Parish Church letter dated 9 November.
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Q.73: Comment
i suggest village hall, community playing fields, sports' facilities and allotments.
SETTLEMENT BOUNDARIES
Q.75
I refer to Chilton Parish Council's letter of 9 November regarding the failure to classify Chilton
Parish as an independent settlement within pages 25 to 27 of this document. It has only
been referenced within the Sudbury settlement "(including part of Chilton and part of
Great Cornard)". Parishioners and other parties seeking to comment on Chilton will fail to
find Chilton listed as a Parish which is misleading. It is noted that Great Cornard does not
suffer the same fate as Chilton.
I object to the proposed new settlement boundaries as shown on the Sudbury (including part
of Chilton and part of Great Cornard - map shown in Appendix 2 on page 179).
POTENTIAL LAND FOR DEVELOPMENT
Q.78: Object
Within the document two SHELAA sites are attributed to Sudbury:
® SS0590 - Land to the east of Waldingfield Road and North of Church Field Road,
Sudbury
» SS0933* - Land to the east of Waldingfield Road and North of Church Field Road,
Sudbury
This is incorrect. Both these sites are in the Parish of Chilton. The comments about
mitigation fail to include Chilton Church, a grade I listed building or the historic park and
gardens at Chilton Hall.
Generally, I consider that allocating all the land between Chilton airfield and the beginning of
Great Waldingfield along the B1115 roadside is unsuitable, in particular, the allocation
SS0948. What in effect will happen is that Great Waldingfield loses its distinctiveness and
becomes in effect part of the Chilton Woods' development. This land should form part of the
green buffer zone.
The B1115 is a narrow winding road. It has been subject to a number of road traffic
accidents some causing fatalities. It is unsuitable for heavy goods vehicles of which there
are already a number traveling to and from Chilton Grain. Adequate road structures will
need to be constructed within the airfield to cope with the increased traffic.
As to SS0590 and SS0933, as stated, both these sites are in the parish of Chilton. Site
reference SS0590 indicates that the part of the site owned by the NHS which is currently
allocated to C2 usage would be developed for residential use. Given the ageing population
and the need for nursing and/or care homes, I consider the existing C2 use allocation should
be maintained. I regard the suggested density of 40 houses as far too high.
Given the substantial excess of already allocated employment land being 83 hectares of
which 20 is at Chilton Woods and the constraints of this site, if development is to be allowed
on this site, which I submit should not occur, that only the part of the site fronting Church
Field Road should be developed in accordance with BDC's heritage officer's report. The
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description of employment use refers in SS05902 to B1 only, whereas on SS0933 the
reference to the proposed land use description is B1/B2/B8. I consider B2 and B8 uses are
incompatible with the nearby heritage assets and other residential properties.
However, careful consideration would need to be given to the adverse impacts of
development and whether appropriate mitigation was possible with regard to nearby heritage
assets including Chilton Church (Grade I) listed building, Chilton Hall (Grade IT), the walled
garden (Grade II) and the historic park and gardens. Any development on this site needs to
protect and enhance the heritage assets. There are alternative employment sites allocated
nearby.
There is an existing cycle way - footpath on the site which is in very poor repair and needs to
be designated for public use.
Overall, the lack of attention to detail and consideration of Chilton Parish in the JLP is very
disappointing. The defects should be remedied as soon as possible.

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11747

Received: 27/11/2017

Respondent: Mr & Mrs Heather & Michael Earey

Representation:

Vision
*Development to be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need.

Full text:

See Attached

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11911

Received: 10/11/2017

Respondent: Pigeon Investmenrt Management

Agent: Beacon Planning Ltd

Representation:

Vision and Objectives
As an initial vision and set of objectives, Pigeon considers that these are appropriate to the two Districts and reflect the requirements of the NPPF.
However, as a general point, Pigeon would query the extent to which this is a joint Local Plan when for example each local planning authority has separate housing targets.

Full text:

See Attached

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11931

Received: 10/11/2017

Respondent: The Trustees of the Tollemache 1965 Settlement

Agent: Strutt & Parker

Representation:

The National Planning Policy Framework (NPPF) makes clear (paragraph 14) that plan-making should entail the Local Planning Authority positively seeking opportunities to meet the development needs of their area. It goes on to state (paragraph 17) that core planning principles include the need to proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Of particular relevance to Mid Suffolk and Babergh Districts, the core planning principles include the requirement to support thriving rural communities within the countryside. It is considered important that the vision set out in the JLP reflects the aforementioned. In particular, we feel that the JLP's vision could be more specific to Babergh and Mid Suffolk Districts; and would benefit from being more positive in relation to supporting thriving rural communities. We are of the view that, having regard to the NPPF, the vision should make express reference to ensure existing rural communities are supported and sustained.

Full text:

See attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11956

Received: 10/11/2017

Respondent: The Trustees of the Tollemache 1965 Settlement

Agent: Strutt & Parker

Representation:

National policy is clear, as set out at paragraph 14 of the NPPF, that plan-making should involve the Local Planning Authority positively seeking opportunities to meet the development needs of their area.

NPPF further states (paragraph 17) that core planning principles include the need to proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Further, the NPPF calls for planning to supporting thriving local communities.

We suggest that the vision in the JLP includes express reference to supporting and enhancing the vitality of the Districts' rural communities.

Full text:

See attached full representation

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11987

Received: 10/11/2017

Respondent: Endurance Estates

Agent: Pegasus Group

Representation:

The vision for the Joint Local Plan should be reflective of the important role Mid Suffolk and Babergh districts have to play in the wider East Anglian region. Although predominantly rural, the districts (particularly Mid Suffolk) are crossed by major strategic transport routes including the A14 and mainline railways, which mean the districts are well-placed to drive forward and share in the economic prosperity of East Anglia. This means the Councils must plan positively to secure economic growth and, crucially, deliver enough new homes in a timely fashion to meet housing need and to tackle the existing poor affordability of housing in the district.

Full text:

See attachments

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12008

Received: 10/11/2017

Respondent: Endurance Estates

Agent: Pegasus Group

Representation:

The vision for the Joint Local Plan should be reflective of the important role Mid Suffolk and Babergh districts have to play in the wider East Anglian region. Although predominantly rural, the districts (particularly Mid Suffolk) are crossed by major strategic transport routes including the A14 and mainline railways, which mean the districts are well-placed to drive forward and share in the economic prosperity of East Anglia. This means the Councils must plan positively to secure economic growth and, crucially, deliver enough new homes in a timely fashion to meet housing need and to tackle the existing poor affordability of housing in the district.

Full text:

See attachments

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12024

Received: 10/11/2017

Respondent: Bloor Homes Eastern

Agent: JB Planning Associates

Representation:

The new vision must provide clarity in relation to how Babergh and Mid Suffolk will
grow and change over the period up to 2036. It will need to set out how, and where,
new development will be focused. Clearly identifying opportunities and aspirations
throughout the two Local Authority areas. It should reflect the settlement hierarchy.

Full text:

See attachments

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12048

Received: 10/11/2017

Respondent: Montague Asset Management

Agent: Strutt & Parker

Representation:

In terms of housing, the new Joint Local Plan needs to address the history of under supply in the mid Suffolk area. The Department for Communities and Local Government 'Planning for the right homes in the right places: consultation proposals' document outlines that the National Planning Policy Framework (NPPF) is clear that, to enable effective planning of new homes, local planning authorities should start the plan making process with a clear understanding of the number of new homes they need in their area.

Increased OAN clearly sets out a direction of travel that suggests that Babergh should be planning for a greater increase in housing to meet projected needs. Modest small scale sites should therefore be considered favourable such as Taylor's Garage, Bildeston. Any approach must allow an understanding of the minimum number of homes that are needed across England.

Full text:

See attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12131

Received: 10/11/2017

Respondent: APT Philpot Ltd

Agent: Strutt & Parker LLP

Representation:

We recommend that any Vision includes the ambition to deliver consistent rates of housing delivery throughout the plan period in order to meet objectively assessed housing need and to ensure that housing development can consistently contribute towards the economic stability and growth of the districts.

Full text:

See attachments

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12184

Received: 10/11/2017

Respondent: The Greenwich Hospital

Agent: Strutt & Parker

Representation:

It is considered that both the vision and objectives outlined in the consultation document have considered national planning policy and include specific reference to key paragraphs of the NPPF relevant to housing delivery, the economy, communities and the environment. For these reasons we generally support the overall vision and objectives. However, the housing objective should include a more specific reference to overall housing needs, in order to ensure that the plan is seeking to provide sustainable levels of growth right from the outset.

Full text:

See attached full representation (two documents attached).

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12212

Received: 10/11/2017

Respondent: Marden Homes

Agent: Strutt & Parker

Representation:

We support the vision and objectives that the Joint Local Plan will set an ambitious yet sustainable growth agenda to deliver the necessary housing, employment and recreational growth and development. We therefore suggest the housing vision/ objective includes the council's commitment to maintain a good housing delivery rate over the plan period to meet objectively assessed housing need. As per paragraph 182 of the NPPF, it is essential that the Local Plan includes a deliverable and justified strategy that will enable objectively assessed housing need to be met. In order for the Local Plan to be compliant with the NPPF, it should not only seek to meet objectively assessed development needs of the District in full, but also unmet needs of its neighbours where it is sustainable and reasonable to do so.

Full text:

See full representation attached (three documents).

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12243

Received: 10/11/2017

Respondent: R G Williams Ltd

Agent: Gardner Planning

Representation:

This should give a much higher priority to substantially increase housing supply to help fix the 'broken market' - to reflect the Government's priority to 'build many more houses' as widely identified in the Housing White Paper and elsewhere.

Full text:

See attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12281

Received: 10/11/2017

Respondent: Anthony Villar

Agent: Strutt & Parker

Representation:

The new Joint Local Plan should actively address the historic under-supply of housing in Mid Suffolk. The Department for Communities and Local Government 'Planning for the right homes in the right places: consultation proposals' document outlines that the National Planning Policy Framework (NPPF) is clear that, to enable effective planning of new homes, local planning authorities should start the plan making process with a clear understanding of the number of new homes they need in their area. Consultation sets out assessment of housing need based on a proposed new formula of 439 dwellings per annum, compared to current local assessment of 573 dwellings per annum, increase of 121 dwellings per annum. Clearly sets out a direction of travel that suggests Mid Suffolk should be planning for an increase in housing to meet projected needs. Numbers must be a minimum.

Full text:

See attachment

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12315

Received: 10/11/2017

Respondent: Strutt & Parker Farm Ltd.

Agent: Strutt & Parker

Representation:

We support the vision and objectives that the Joint Local Plan will set an ambitious yet sustainable growth agenda to deliver the necessary housing, employment and recreational growth and development. We agree that the vision should be growth-orientated but also focus on the strengthening and enhancement of existing assets to ensure that they continue to support the District.

Full text:

See full representation attached (three documents).

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12444

Received: 10/11/2017

Respondent: Ms C Ciechomski

Agent: Strutt & Parker

Representation:

The Issues & Options Document, states that the vision and objectives are to set an ambitious, yet sustainable growth agenda to deliver the necessary housing, employment and recreational growth and development. The draft plan, however does not presently go far enough to promote the delivery of housing to meet the objectively assessed housing need. We therefore suggest that the housing vision/objective includes the Council's commitment to maintain a good housing delivery rate over the plan period to meet objectively assessed housing need. As per Paragraph 182 of the NPPF, it should not only seek to meet objectively assessed development needs of the District in full, but also unmet needs of its neighbours, where it is sustainable and reasonable to do so.

Full text:

See full representation attached (four documents).

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12447

Received: 10/11/2017

Respondent: Taylor Wimpey

Agent: Boyer Planning

Representation:

We agree with the Councils' Vision and Objectives, set out on page 19 of their consultation document, especially with regards to their recognition that housing is identified as a key priority area.

Full text:

See attachments

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12573

Received: 10/11/2017

Respondent: Mr Alastair Powell

Representation:

* The vision should be to leave our Grandchildren with the world they will want, to build what they will want and protect what they would want to keep.

* This JLP talks of growth as an aspiration but the evidence is fundamentally flawed failing to take account of Brexit and relying on historic data that is dependent on the authors choice. Wishing for growth and basing development on a wish is dangerous for our communities.

Full text:

SECTION 1 - STRATEGIC
Vision
* The vision should be to leave our Grandchildren with the world they will want, to build what they will want and protect what they would want to keep.
* This JLP talks of growth as an aspiration but the evidence is fundamentally flawed failing to take account of Brexit and relying on historic data that is dependent on the authors choice. Wishing for growth and basing development on a wish is dangerous for our communities.

Objectives
* Development balanced between homes and employment.
* Encourage inward investment,
* Protect and enhance environmental assets,
* Provision of necessary infrastructure and services
* Provision of the right housing that local residents need and can afford.
* Radically improve the already strained local road networks especially the "Ipswich Northern Route" and improvements to the A1071 at B1113 and Hadleigh Road junction to include an access onto the A14.
* Ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) by being more robust.
* Adoption of new NPPF proposals to transparently display expected/avaerage costings and policy expectations of planning applicants on LPA web site so that viability is a matter for developers to consider themselves from the start, not an issue to be argued over during the application process.
Priorities
* Development shouldn't lead to communities losing their identities by swamping and creeping coalescence (merging of communities).
* Location of growth to be spread more pragmatically across Babergh rather than fewer large sites
* MOST IMPORTANT FOR SPROUGHTON - transport infrastructure, school places, accessible healthcare services, enhance environmental assets.
Duty to Cooperate
* Ipswich say they have insufficient land to meet their projected housing numbers which means under the 'Duty to Cooperate' surrounding district councils must assist in finding land to accommodate Ipswich housing overspill. In this case around 4000 dwellings - how are Babergh proposing to help meet this requirement? Babergh should NOT be picking up all 4000.
* Why have Fringe Parishes been excluded from the Ipswich Fringe Policy Forum. Duty to Cooperate is under NPPF supposed to go down through the government hierarchy not just sideways and up. This surely is a massive failing the imposition of the consiquences unacceptable.
SECTION 2 - DELIVERY

Housing Requirement, Settlement Hierarchy and Housing Distribution

Housing Requirement 2014 to 2036 - Option HR1 - 7,820 new houses based on population growth.
* Effects of BREXIT on domestic and overseas migration have been completely ignored and yet as the main element of any population growth shown in the historic data any migration changes due to Brexit will have he biggest effect.
* Brexit and HS2 will also effect the direction of any Migration potentially reversing growth.
* Relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability is unsound because house and wage Medians do not account for increasing cash ritch migration from city against City commuters not showing a local wage.
* Housing need derived from population growth appears to be based almost entirely on single occupancy which is absurd and probably needs reconsideration to about half of that for average occupancy rates.
Contingency and Delivery
* Current 'stuck' sites with permissions and no building suggests need for contingency going forward - replace 'stuck' sites with others.
* Contingency sites to be replacement and not additional, original sites to be taken out of plan. Regular review of demand required checking the guiding principles of type, tenure, place and need (local) - should trigger need for reserve sites.

Hierarchy
* Scoring criteria is completely arbitrary as is the special distribution. There is no real scince here and it convieniently promotes areas with the biggest site allocations which is viewed with some suspicion.
* There has been no transparent cooperation or consultation on these arbitrary critieria's and scorring sytems that have then been imposed.
* It is unacceptable that the most significant process adopted to designate the spread of development has been an untransparent, arbitrary, unconsulted concocted formula.
* Sproughton classed as CORE and also HINTERLAND village, can't be both.
* DON'T AGREE WITH APPROACH TAKEN - scoring based on distance to services and facilities; should be based on travel time as accessibility overstated.
* No account taken of capacity of a service in scoring (eg Primary School/shops (Sproughton identified as having a P.O.!)
* Positive scoring factors in this Hierarchy assessment are actually negative factors against Creeping Coalescence (i.e. the erosion of as communities' individuality) they therefore fly in the face of the NPPF and unfairly place Sproughton into the main settlement types.
* We would support reconsideration of the scoring criteria adopted to include fairly balanced negative scores for the threat of Creeping Coalescence.

Spatial Distribution
* I object to all four options due to the Ipswich fringe element which has been arbitrarily imposed presumably arising from the secretive Ipswich Fringe Policy Forum which has excluded fringe parish participation from its discussions.
* Of the Four options offered: 1) County Town Focused, 2) Market Town/Rural balance, 3) Transport Corridor Focused. 4) New Settlement Focused. Only 4 offers an not in my backyard option and due to the imposition of the Ipswich Fringe element this is the only one that is acceptable
* The combined arbitrary criteria for scoring of both Hierarchy and Spatial Distribution chosen by BMSDC for the JLP just appears to promote the site availability that has come forward, effectively a mechanism to justify the sites.
* JLP to 2036 gives opportunity for bold, innovative and creative thinking but continuing the urban sprawl / welding / merging communities not the answer.
* Creating well planned, self-sufficient purpose built settlements with their own identities is and thereby preserving the qualities of existing communities.

Other Distribution Options
* We would support an option for proportional distribution
* Propose carefully planned 'organic growth' of existing communities.
* The expected Babergh population growth of 8000 by 2036 (9%) could be applied to each community - Sproughton grow by 120 (50 or so new houses). Low impact on community infrastructure, encourage small scale employment enterprises, reduce the need to travel, enhance and grow the desirable aspects of communities and provided opportunities for local developers and labour to be part of the growth agenda - inward investment/wealth retained locally.
* The concept that in one house out of ten a grown up child might want their own home in the community close to their parents over a 20 year period is not just conceivable, it must be for most parents a welcomed opportunity; this matches a district wide 9% proportional distribution.
New Settlement
* This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally situated where it least effects existing communities but with ready access to Road and Rail links.
* Some suggestions: Near Gt Blakenham, South of Sudbury close to rail link,
* But probably the most practical would be somewhere between Belstead/Bentley and A12/Main Railway where a new railway station could also be built to serve Ipswich. This is mainly flat farmland and close to railway and A12. I understand that if this was developed by BMSDC Satarter homes, affordable homes, bungalows could be at the top of the agenda and the land could be compulsorily purchased.

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

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

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

Gypsies and travellers
* The Cromer incident occurred when travellers gathered in large numbers therefore, limiting sites to short stay and small number of vehicles (say 3 days/3 plots) with sites well spread apart (say 20 miles) is safer for communities.

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

Retail
* Call for sites did not actually bring forward any retail sites however there is a massive oversupply of Commercial sites that could accommodate Retail/Leisure parks if growth projections realised.
* Restricting all retail growth to town centres may be too restrictive as some growth may need to be accommodated away from town centres where sites become available.
* Retail policy inclined towards town centre growth, however as a rural community this is impractical without improved parking or an efficient transport network.
* Option to protect retail facilities in smaller towns/villages which would appear to be an appropriate policy. However how or what that might amount to is unclear.
* We would support the use of the considerable oversupply of commercial sites coming forward as retail/leisure parks or even housing, especially where those sites are brownfield and have little community/environmental impact.

Environment
* Local area/spot designations like Special Landscape areas, cherished view points, wildlife, flora and fauna reserves etc. have evolved from many years' experience and often considerable efforts by communities, sometimes based on fleeting observations of rare secretive species. They preserve the best of our environment & any policy that introduces a subjective opinion has the risk of overlooking years of experience and effort in favour of financial considerations.
* A point overlooked is the sequence of Landscape Character designations that run down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB).
* We even have a famour artist with a painting of Red House at the V&A meuseum? Chantry Vale and th Gipping Valley is so much like Dedham Vale that possibly a landscape Project area designation should be approptiate to ensure any development in the area conforms to a plan to preserve the important aspect of the landscape.

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 when they potentially will overflow from sustained rainfall.
* We would recommend much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk downhill/downstream from developments.
* In relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.

Sustainability standards
If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.
Issues to consider:
* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.

Landscape, heritage and design
* Relevant to Sproughton are SLA's (Special landscape Areas) which not only cover Chantry Vale but most of the area surrounding the village. Other local designations that relate to views, recreational and open spaces either do, or may also, relate to Sproughton.
* We support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
* It then suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance" which is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of experience in favour of Public / Economic Need.
* The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. Comment on any aspect of development in landscape areas is pointless when we don't know what is being proposed.
* Therfore the only acceptable option is the continued use of the SLA and other visual local landscape designations to be robustly applied, which has not been the case during the last LP.
* 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, apparently the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale , this designation might be appropriate for Sproughton and the River Valley.
Design
* The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character.
* That lends itself to small developments not estates which change the character of the county.
* All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.

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

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

Healthy Communities
* Whilst we agree with the policies outlined here, we are concerned that any existing individual communities should not lose their community identity and cohesion as a result of 'creeping coalescence 'arising from the inappropriate location of new developments.
* We consider greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. We suggest that more emphasis is given to ensuring that any necessary development is spread more evenly over the District as a whole, rather than being concentrated disproportionately in particular communities.
SECTION 3 - PLACE
Functional Clusters
* 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
* Whereas some factors considered are appropriate the new boundaries have been drawn to include development sites that have not been delivered. Further thought needs to be given to planning consents that have been granted but not yet delivered.
* Extensions to a settlement boundary are inappropriate if existing permissions have not been delivered.
* We also feel that the determination of settlement on the basis purely of numbers is over-simplistic. The setting and historical purpose of any collection of houses is important; for example, a collection of farm workers cottages located in the countryside should not necessarily establish a basis for a larger settlement. The existence of 'community' is also important.

Potential Land for Development
* With respect to Sproughton, 8 sites have been identified in total (6 for housing and 2 for employment). These essentially cover most of the Chantry Vale (Wolsey Grange to the River Gipping), the old Sugar Beet site, and developments along the Loraine Way meeting up with Bramford.
* The number of houses proposed for Sproughton is 2,310 ,(This is a disproportionate amount of housing for Sproughton. If the net OAN is 4,210 then Sproughton has 55% of the house required allocated to it.
* A better approach would be to pro-rata the allocation across all parishes -This would allow settlements to grow in a more organic way without penalising Sproughton to the extent that it would be abosrobed into Ipswich and merge with Bramford.
* The sites identified are not appropriate for allocation within the settlement boundary. As a general principle, planning policy should ensure a proportional allocation of housing and employment land across the Districts, sympathetic to and in support of the characteristics and needs of existing communities. A total of 9,446 dwellings are proposed (sum of dwellings across all sites specified within the SHLAA). However, once the net number of dwellings is calculated having taken into account planning applications granted, in progress etc, the Objectively Assessed Need (OAN) is reduced to 4,210. It appears that 2,320 of these dwellings i.e. 55.11% of the total development proposed in Babergh is designated for Sproughton. This is a significant over development of Sproughton which currently has around 581 dwellings - this would be an increase of 397% in parish size. It is completely disproportionate and would result in Bramford joining with Sproughton and Sproughton being absorbed by Ipswich in the same way that Kesgrave and Rushmere-St- Andrew has been. Not so much 'creeping coalescence' as 'complete digestion'. A much fairer basis for development would be a pro-rated approach

Withn Respect to Specific Sites

SS1024: Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
* The setting and the views into and from Chantry Vale, which are almost unique and subject to SLA.
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley) and Green wildlife links with the Chantry Park
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0721: Site appropriate for development, subject to the scheme proposal.
However, why - given the size of the site was some not allocated to housing.
SS1023: Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
* The setting and the views into and from Chantry Vale, which are almost unique and subject to SLA.
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley) and Green wildlife links with the Chantry Park
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0191
Some of the site (specifically, in the south-west corner / adjacent to the existing settlement on London Road) may be appropriate for development, subject to the development of an appropriate scheme, the considerations already identified (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats), and further considerations comprising:
* The setting and the views into and from Chantry Vale, which are almost unique and subject to SLA.
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley) and Green wildlife links with the Chantry Park
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0711: Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, environmental and heritage), additional key considerations include:
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley) and the views to and from the river-side walks that would be impacted by the proposed site
* 'Creeping coalescence' between Bramford and Sproughton.
SS0299
Site is appropriate subject to the development of an appropriate scheme.
With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is our view, however, that the scheme as set out in the application is not appropriate and we support any challenge Sproughton Parish Council may make to any decision approving that application.
SS0223: Site not appropriate for development.
The site assessment summary notes appropriate considerations to factor into any decision (highways, landscape, heritage and allotment relocation). However, the District Councils should be in no doubt that any proposed development of a special landscape area, which also results in a loss of amenity and potentially significant negative social and economic impacts on the existing local community, is deeply objectionable.
SS1026
Site is appropriate subject to the development of an appropriate scheme.
With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is our view, however, that the scheme as set out in the application is not appropriate and we support any challenge Sproughton Parish Council may make to any decision approving that application.
SS0121: Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, environmental and heritage), additional key considerations include:
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley) and the views to and from the river-side walks that would be impacted by the proposed site
* Creeping coalescence' between Bramford and Sproughton.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12645

Received: 10/11/2017

Respondent: Mr Bryan Fawcett

Representation:

* Development to be sustainable and this needs to take into account economic, social and environmental factors. Development needs to be in the right place, of the right type and which meets the local need. Whilst the proposed objectives appear to be sound there is a lack of clarity for their application. The vision needs to be based on the identified needs of the individual communities and villages within the Babergh district. Development must be sustainable and evidence provided as to how this be measured and applied. This must also into consideration the rights and needs of the existing residents of the district as well as the current social and economic concerns in the light of Brexit. The issue of infrastructure requires and its application across the whole of the district. Babergh is a rural district, there must not be a loss of the identity of the villages, of village life and the communities within them.
* There is a lack of clarification in how objectives will be determined and applied. Without specifics as to how the need for areas development will be measured and managed the objectives are meaningless.

Full text:

Hello, I am writing to you regarding the new joint local plan for the development of the Babergh District. I have tried to make comments on the web based consultation portal but found it so un-user friendly that have reverted to making comments by email. I am concerned that the web based consultation is designed to deter people from making comments or even objections as they will find it too difficult or confusing to respond. Please find below my comments and objections on the various areas of the plan to be taken into consideration as part of the consultation process.






Objectives
* Development needs to be balanced between homes and employment. There needs to be protection and enhancement of environmental assets that provide the villages with their rural identity. The identification and provision of necessary infrastructure and services needs to measured and appropriate resources allocated for their implementation before housing allocations can be made to induvial areas. There needs to be considered foresight to the plan. The provision of housing must be of the type that local residents need and can afford.
* There needs to be a radically improvement to the already strained local road networks. In Sproughton, where I live, the main through roads are severely congested every morning and evening with the village used as a cut through to the A14. At the times the Orwell Bridge is closed I cannot even pull off my own driveway. To travel to the end of my road, a distance of 50 m, can take an hour or more. There needs to be improvements to the A1071 at B1113 and Hadleigh Road junctions, and an access onto the A14.
Vision
* Development to be sustainable and this needs to take into account economic, social and environmental factors. Development needs to be in the right place, of the right type and which meets the local need. Whilst the proposed objectives appear to be sound there is a lack of clarity for their application. The vision needs to be based on the identified needs of the individual communities and villages within the Babergh district. Development must be sustainable and evidence provided as to how this be measured and applied. This must also into consideration the rights and needs of the existing residents of the district as well as the current social and economic concerns in the light of Brexit. The issue of infrastructure requires and its application across the whole of the district. Babergh is a rural district, there must not be a loss of the identity of the villages, of village life and the communities within them.
* There is a lack of clarification in how objectives will be determined and applied. Without specifics as to how the need for areas development will be measured and managed the objectives are meaningless.
Priorities
* The protection of the rural identity of the district, the protection of the villages and their lifestyle, protection or rural amenities and recreational space are objectives that all need to be defined within the plan. Development shouldn't lead to communities losing their identities by swamping and creeping coalescence.
* Location of growth to needs to be spread more pragmatically across Babergh rather than fewer large sites which will minimise the impact on individual communities and villages maintaining the rural lifestyle chosen by those who lives there.
* MOST IMPORTANT FOR MY VILLAGE SPROUGHTON - maintenance of the rural identity of the village, enhancement of environmental assets, transport infrastructure and roads , school places and accessible healthcare services.
*
Duty to Cooperate
* Ipswich say they have insufficient land to meet their projected housing numbers which means under the 'Duty to Cooperate' surrounding district councils must assist in finding land to accommodate Ipswich housing overspill. In this case around 4000 dwellings - how are Babergh proposing to help meet this requirement? Babergh should NOT be picking up all 4000.
* Housing Requirement, Settlement Hierarchy and Housing Distribution


Housing Requirement 2014 to 2036 - Option HR1 - 7,820 new houses based on population growth.

The numbers appear over inflated, what account taken of effects of BREXIT on domestic and overseas migration?
What about the impact of relocation of major industries, effects of 'Northern Powerhouse and HS2?
The housing need has been calculated on a projected 1.03 persons per dwelling but in the past the average has been 2.3. Therefore by this calculated the figure of 7,820 is over-stated
Contingency and Delivery

Contingency sites need to be replacement and not additional, original sites need to be taken out of plan. There needs to be a regular review of demand required checking the guiding principles of type, tenure, place and local need.

Hierarchy

Sproughton is classed as CORE and also HINTERLAND village, it can't be both? Scoring is based on distance to services and facilities; it should be based on travel time as accessibility overstated. There is no account taken of capacity of a service in scoring for example capacity of the local primary school, number and nature of local shops. Sproughton has been identified as having a post office! Positive scoring factors in this Hierarchy assessment are actually negative factors against Creeping Coalescence (i.e. the erosion of as communities' individuality) they therefore fly in the face of the NPPF and unfairly place Sproughton into the main settlement types. I would support reconsideration of the scoring criteria adopted to include fairly balanced negative scores for the threat of Creeping Coalescence.

Spatial Distribution

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


Other Distribution Options

I would support an option for proportional distribution and careful planned 'organic growth' of existing communities.
The expected Babergh population growth of 8000 by 2036 (9%) could be applied to each community - Sproughton to grow by 120 and therefore approx. 50 new houses to be built in the area to manage this. This will then have a low impact on community infrastructure, encourage small scale employment enterprises, reduce the need to travel, enhance and grow the desirable aspects of communities and provided opportunities for local developers and labour to be part of the growth agenda. The concept that in one house out of ten a grown up child might want their own home in the community close to their parents over a 20 year period is not just conceivable, it must be for most parents a welcomed opportunity; this matches a district wide 9% proportional distribution.

The proposition to create a new or garden town, a separate and distinct community in a new location can have minimal local impact but have the potential to improve/create improved county infrastructure/services. Obviously no one wants something like this in their back yard. So ideally situated where it least effects existing communities but with ready access to Road and Rail links. Possible locations could include near to Gt Blakenham, South of Sudbury close to rail link, Somewhere between Belstead/Bentley and A12/Main Railway.

Housing Types

National space standards should apply with provision for storage. There is a requirement for provision of accessible homes and bungalows. Self Builds support local economy and rural outlook so should be encouraged. Provision is needed for affordable homes to include starter homes which are more appropriate to support growth of local community. With the ageing population in Babergh there needs to be policies that increase the provision of Bungalows and Accessible housing. It should be acknowledged 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.

Rural growth and development: Delivering growth, services and facilities in rural towns and villages.

Sustainable development needs to be at the heart of planning. This is not a recommendation to build but to build wisely. There has to be a realistic prospect that houses are needed and suitable for a given location and it would appear from the surveys done that Rural housing is needed by the expanding local resident population
It is interesting that small and individual developments which complement the county character have come forward successfully whereas the larger strategic site's drag on. Surely an indication that individual development is for need, and therefore gets done. Whereas national developers build for profit and will hold off until they feel they can get the maximum return with no consideration for need. Smaller developments also assimilate into the rural, scattered hamlet, market town character of the county.
The present policies are too restrictive on small and individual development, in that what appears to be perfectly acceptable infills and small extensions to village boarders which complement their character without oppressive change have been blocked by planning policies when large estate developments that are oppressive, change the character and destroy the individuality of local communities have been supported.
Proportionality is key; The JLP proposes a 9% Housing need over 20 years. This equates to one new home in a ten house hamlet, but why stop there. Such growth is potentially desirable naturally matching the growth of any micro community. Generally children grow older and want their own homes within their community, why shouldn't the provision and burden be spread evenly at 9%, by hamlet, village and town. 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.


Economy

A clear oversight in the JLP is that the effects of Brexit has not been considered, either in trade, employment or migration calculations. The 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 this. 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.

Retail
The call for sites did not actually bring forward any retail sites however there is a massive oversupply of Commercial sites that could accommodate Retail/Leisure parks if growth projections realised. Restricting all retail growth to town centres may be too restrictive as some growth may need to be accommodated away from town centres where sites become available. Retail policy is inclined towards town centre growth, however as a rural community this is impractical without improved parking or an efficient transport network. I would support the use of the considerable oversupply of commercial sites coming forward as retail/leisure parks or even housing, especially where those sites are brownfield and have little community/environmental impact.

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


Sustainability standards

If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.
Issues to consider:
* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.

Landscape, heritage and design

Relevant to Sproughton are 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 would support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them. The JLP suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance" which is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of experience in favour of Public / Economic Need.
The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. This has the potential to be 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 could be appropriate for Sproughton and the River Valley.


Design

The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character.That lends itself to small developments not estates which change the character of the county. All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.

Infrastructure
* Overall I agree with the Infrastructure provision policy as set out. However, any developments MUST (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. 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 therefore fully support Option INF 2 that provides a strategic approach over and above the NPPF for cumulative growth, but with the caveat that infrastructure policies are adhered to.


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

Healthy Communities

Whilst I agree with the policies outlined here, 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. Greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments and more emphasis given to ensuring that any necessary developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities. I broadly support Policy OS2 but are concerned that this does not result in the 'watering down' of existing open space provision existing within communities. I support Policies NROS2 and POS2 in the protection of our Open Spaces. In the case of Policy CF2 whilst 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.


Functional Clusters

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

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.
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.
In relation to the identified sites and the appropriateness for allocation or inclusion within the settlement boundary- the sites identified are not appropriate for allocation within the settlement boundary. As a general principle, planning policy should ensure a proportional allocation of housing and employment land across the Districts, sympathetic to and in support of the characteristics and needs of existing communities. A total of 9,446 dwellings are proposed however, once the net number of dwellings is calculated having taken into account planning applications granted, in progress etc. the OAN is reduced to 4,210. It appears that 2,320 of these dwellings i.e. 55.11% of the total development proposed in Babergh is designated for Sproughton. This is a significant over development of Sproughton which currently has around 581 dwellings - this would be an increase of 397% in parish size. It is completely disproportionate and would result in Bramford joining with Sproughton and Sproughton being absorbed by Ipswich in the same way that Kesgrave and Rushmere-St- Andrew has been. A much fairer basis for development would be a pro-rated approach with some tweaking for those settlements that are very small in size.
SS1024: Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0721: Site appropriate for development, subject to the scheme proposal.
It is not clear to local residents, however, why - given the size of the site - a portion may not be allocated to housing.
SS1023: Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0191
Some of the site (specifically, in the south-west corner / adjacent to the existing settlement on London Road) may be appropriate for development, subject to the development of an appropriate scheme, the considerations already identified (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats), and further considerations comprising:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0711: Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, environmental and heritage), additional key considerations include:
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley) and the views to and from the river-side walks that would be impacted by the proposed site
* 'Creeping coalescence' between Bramford and Sproughton.
SS0299
Site is appropriate subject to the development of an appropriate scheme.
With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is our view, however, that the scheme as set out in the application is not appropriate and we support any challenge Sproughton Parish Council may make to any decision approving that application.
SS0223:
Site not appropriate for development.
Any proposed development of a special landscape area, which also results in a loss of amenity and potentially significant negative social and economic impacts on the existing local community, is deeply objectionable. This site sits on one of the busiest junctions in Suffolk and in an area of high air pollution due to the over use of the roads in the village as a means to cut through to Hadleigh and the A14.. It is a proposed development on a site of the village allotments, an amenity used by the village for recreational purposes, key in bringing together a diverse range of community for a joint purpose. Loss of this valuable area will be to the detriment of the village as a whole in terms of the loss of sense of community, the loss of a landscape key to the character of the village and loss of the rural identity of the location.
SS1026
Site is appropriate subject to the development of an appropriate scheme.
With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is my view, however, that the scheme as set out in the application is not appropriate and I support any challenge Sproughton Parish Council may make to any decision approving that application.


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


Regards
Bryan Fawcett




Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12788

Received: 10/11/2017

Respondent: Great Waldingfield Parish Council

Representation:

The draft Joint Local Plan does not set out any large-scale vision for the District. It is largely driven by the housing numbers that the District is required by government to build rather than setting out a picture of how those houses can be built to fit into and enhance the life of the communities in the District.

Full text:

See attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12793

Received: 10/11/2017

Respondent: Great Waldingfield Parish Council

Representation:

Build the Vision on the findings of a SWOT analysis. Must incorporate an analysis of the potential impacts of Brexit, as this historic event will have an huge impact one way or another on the potential for growth and housing need in the District. It must also include an analysis of the impact of technology changes.
The eventual Vision might be along the lines "ensure the Districts are in the best possible position to prosper in a post Brexit world through economic and housing strategies that promote growth, focus resources and proactively balance the need to adapt and change whilst ensuring the attractions of the area for inward investment and tourism are not prejudiced".

Full text:

See attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 12842

Received: 10/11/2017

Respondent: Tidal Hill Limited

Agent: Armstrong Rigg Planning

Representation:

The vision should be suitably ambitious and aspirational to meet the governments growth agenda. It should seek to tum around years of under-delivery of housing, low economic growth rates and the high levels of out­commuting of the resident population in Babergh which currently takes place to access the employment market.
'To boost significantly the supply of housing and proactively support economic development to deliver the homes, and meet the commercial and employment needs of the people and businesses in the area'

Full text:

See attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 13108

Received: 09/11/2017

Respondent: Suffolk Coastal District Council

Representation:

Suggest there is greater reference to how the BMSDC vision relates to the wider Housing Market Area such as delivering the number of houses required and meeting any unmet need from neighbouring authorities.

Full text:

See attached full representation.

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 13150

Received: 09/11/2017

Respondent: Taylor Wimpey

Agent: Boyer Planning

Representation:

We agree with the Councils' Vision and Objectives, set out on page 19 of their consultation document, especially with regards to their recognition that housing is identified as a key priority area.

Full text:

See attached