Q5 (p13)

Showing comments and forms 121 to 150 of 160

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8484

Received: 10/11/2017

Respondent: Mr Michael Beiley

Representation:

Preservation of the pre-existing rural way of life ; the pace of housing growth must be in proportion and not result in fundamentally undermining the character of the hamlet e.g. if a hamlet has 50 houses,growth of 10 % over a number of years is probably sustainable but 25% almost certainly not.

Full text:

Preservation of the pre-existing rural way of life ; the pace of housing growth must be in proportion and not result in fundamentally undermining the character of the hamlet e.g. if a hamlet has 50 houses,growth of 10 % over a number of years is probably sustainable but 25% almost certainly not.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8491

Received: 10/11/2017

Respondent: Redlingfield parish meeting

Representation:

Redlingfield
We want growth. So that people who were born here are able to afford to continue living here and the family support networks that have grown up over generations are allowed to thrive.
Currently young people are forced out because they can't find affordable housing within the village.
Currently we are a hamlet/countryside village yet within the lifetime of this plan (and probably before this plan has been fully adopted) we will meet and exceed the sustainability criteria to be reclassified as a Hinterland village. It is essential that a mechanism to reclassify villages such as ours is included

Full text:

Redlingfield
We want growth. So that people who were born here are able to afford to continue living here and the family support networks that have grown up over generations are allowed to thrive.
Currently young people are forced out because they can't find affordable housing within the village.
Currently we are a hamlet/countryside village yet within the lifetime of this plan (and probably before this plan has been fully adopted) we will meet and exceed the sustainability criteria to be reclassified as a Hinterland village. It is essential that a mechanism to reclassify villages such as ours is included

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8698

Received: 10/11/2017

Respondent: David Black & Sons Ltd.

Representation:

We have recently built 2 - 3bed semi-detached houses for rental and having advertised them for rent received over a dozen enquiries in just 2 weeks. We identified a call for more affordable rented accommodation, especially where:
Young families can be located near other family members who can assist with child care.
Families have broken up and neither party want to move too far away.
People want to get out of towns and enjoy the countryside.
People are working locally and don't want long commutes.

Full text:

We have recently built 2 - 3bed semi-detached houses for rental and having advertised them for rent received over a dozen enquiries in just 2 weeks. We identified a call for more affordable rented accommodation, especially where:
Young families can be located near other family members who can assist with child care.
Families have broken up and neither party want to move too far away.
People want to get out of towns and enjoy the countryside.
People are working locally and don't want long commutes.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8715

Received: 10/11/2017

Respondent: Mrs Hannah Lord-Vince

Representation:

For Sproughton the most important aspects rea:
- maintaining its identity as an independent village,
- improving transport and roads are improved as traffic at the junction of B1113 is terrible and congestion causes delays
- enhancing environmental assets and keeping green countryside

Full text:

For Sproughton the most important aspects rea:
- maintaining its identity as an independent village,
- improving transport and roads are improved as traffic at the junction of B1113 is terrible and congestion causes delays
- enhancing environmental assets and keeping green countryside

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8730

Received: 10/11/2017

Respondent: Mr Philip Schofield

Representation:

Maintain its identity, with sympathetic introduction of selected employment types and characterful, carefully-located new houses

Full text:

Maintain its identity, with sympathetic introduction of selected employment types and characterful, carefully-located new houses

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8841

Received: 10/11/2017

Respondent: Mr Simon Pearce

Representation:

There needs to be a vision to save what is beautiful and best about the villages in babergh district and not spoil them by rush to build across the contrysideandon green fields.

Full text:

Woolverstone is an ancient estate village. Much of the building that is listed took place in the eighteenth and nineteenth century. As you travel through the village, much of the estate building is still in clear evidence. To the north of the B1456 the village is situated within the Suffolk Coasts and Heaths Area of Outstanding Natural Beauty; to the south of the B1456 is within the AONB project area. The majority of the village is within a designated Conservation Area. However, the cumulative impacts of development further down the B1456 have brought noise, severance, pollution and vibration to the village. The local red brick walls, part of the historic fabric of the village, are being destroyed by the wash from cars through inadequate road drainage. The road is narrow in places and residents are subject to persistent speeding. This is before the impact of a 30% increase of traffic through the development at former HMS Ganges and Shotley Marina. Most important to Woolverstone is to see its designated Conservation Area protected and enhanced by planning policies and not being degraded by policy decisions. Second most important is to retain the vistas of ancient estate farmland and hedges without further development on the fertile (Grade 2) "greenfield" sites offered through the call for sites which have been listed in the Local Plan as being suitable for development. (Joint Local Plan Consultation Document. Appendix: SS0255 and SS0203)

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8910

Received: 10/11/2017

Respondent: Andrew Searle

Representation:

Education and Quality Utility Services

Full text:

Education and Quality Utility Services

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8982

Received: 10/11/2017

Respondent: Onehouse Parish Council

Representation:

To retain the independent identity of the village, and be shown respect for the views of the community that live in it.

Full text:

To retain the independent identity of the village, and be shown respect for the views of the community that live in it.

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9114

Received: 10/11/2017

Respondent: Mrs Lynda Shephard

Representation:

For Long Melford to stay roughly the same size as it has achieved a good balance between size and facilities. However I understand that more housing is needed in the area but sites should be well-chosen so that they don't ruin beautiful views. Long Melford is regarded as one of the most desirable villages in Suffolk which encourages many visitors and artists so it would be inappropriate to build industrial sites here which will be noisy and encourage more heavy lorries coming into the outskirts of the village

Full text:

For Long Melford to stay roughly the same size as it has achieved a good balance between size and facilities. However I understand that more housing is needed in the area but sites should be well-chosen so that they don't ruin beautiful views. Long Melford is regarded as one of the most desirable villages in Suffolk which encourages many visitors and artists so it would be inappropriate to build industrial sites here which will be noisy and encourage more heavy lorries coming into the outskirts of the village

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9164

Received: 07/11/2017

Respondent: J D Pickett

Representation:

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

Full text:

Dear Sir

Please send confirmation of receipt of this email.

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

Questions 1 - 5 - Vision, Objectives and Priorities

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

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

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

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

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

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

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

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

Questions 16 - 25 - Housing Types and Affordable Housing

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

Questions 26 - 28 - Rural Growth and Development

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

Questions 33 - 41 Economic Needs

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

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

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

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

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

Questions 63 - 68 infrastructure

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

Questions 74 -79 - Place

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

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

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9182

Received: 08/11/2017

Respondent: Mr Ken Seager

Representation:

Most important for Sproughton
Local services must be improved: transport infrastructure, school places, accessible healthcare services; and enhanced environmental assets.

Full text:

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

My comments are as follows:

Q1 and 2: Vision and Objectives

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

Objectives

Development must be balanced between homes and employment. Encourage inward investment, protect and enhance environmental assets, provision of necessary infrastructure and services. Provision of housing must be what local residents need and can afford.
Q3: Other objectives
The plan should achieve radically improved local road networks especially the "Ipswich Northern Route" and improvements to the A1071 at B1113 and Hadleigh Road junctions, and an access onto the A14. The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
The plan must ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time and without back paddling - planning needs to be pro-active on this.
Q4: Priorities
Development shouldn't lead to communities losing their identities by swamping and creeping coalescence (merging of communities). Location of growth to be spread more pragmatically across Babergh rather than fewer large sites.
Q5: Most important for Sproughton
Local services must be improved: transport infrastructure, school places, accessible healthcare services; and enhanced environmental assets.
Q7: Option HR1
Do NOT agree. The housing need identified in the Strategic Housing Market Assessment 2017 (SHMA) may well be overstated for the District during the life of the JLP. The report methodology uses historic patterns of migration, extrapolated forwards to arrive at a projected population growth, but no regard seems to be have been had for the likely effects on both domestic and overseas migration of the UK leaving the EU in 2019. This, and the intended tightening of immigration controls, is likely to quickly and significantly reduce the amount of inward migration and significantly increase the amount of outward migration in the District further, almost at the same time as the JLP itself is adopted. These effects are likely to reduce the forecast need for new housing during the life on the JLP.
Additionally, the potential relocation of major industries to continental Europe if a "hard" Brexit is the outcome of current negotiations is likely to further reduce demand for housing in the District and surrounding areas. Projected employment growth in the District is in the Professional and Business services sectors which may be especially vulnerable to relocation. Given the uncertainty on Brexit and levels of overseas migration, and with emphasis on the "Northern Powerhouse" and HS2, outward domestic migration could increase significantly with employment opportunities being created along the HS2 corridor rather than in East Anglia. This would reduce demand for housing in the District still further.
These potential impacts are real and significant. The JLP must take the most likely possibilities into account and be based on revised data.
The application of a "market signals uplift" is discussed in the SHMA (pp53-64). The consultants are clear that in the absence of any guidance other than an uplift should be "reasonable", a "judgement" is required. Their judgement (para 6.54 on page 63) in the case of Babergh is that a 15% uplift should be applied. Comparing the narrative summary of the case in Babergh with that of Suffolk Coastal on p64 (also judged at 15% uplift) the judgements do not seem to be equal and the uplift seems excessive in Babergh by comparison with Suffolk Coastal. All other Districts are judged at 10%.
The consultation document does not explain in simple enough detail how a projected population increase over the period of the JLP in Babergh of 8086 persons translates into an OAN of 7820 dwellings. In order to be able to comment effectively, it is important that the council's case is clearly stated in ways people can readily understand. The total dwelling figure seems incongruent with other evidence in the SHMA: the fact that over the period 2001-2015, both overseas migration and natural change were negative, and a past average occupancy of 2.3 persons per dwelling.
The JLP should also have an in-built flexibility so that the housing need can be regularly reviewed against forecasts during the life of the plan to 2036 and adjusted to take account of significant changes in demand which affect the amount, type and location of housing during that time.
Q8: Contingency
It makes sense in a plan that is expected to span such a considerable period of time for there to be some contingency provision against identified sites that cannot, for whatever reason, be developed within the specified time. In such circumstances, the activation of a contingency site should permanently remove the original intended site from the plan. In other words, each contingency activated should be a replacement within the plan for an original site that could not be developed as planned, NOT an additional site for development.

Q9: Specific measures to include

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

Q10: Trigger factors

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

Q11: Proposed criteria approach

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

Q12: Joint Settlement Hierarchy

See the answer above for doubts about its validity

Q13: Spatial Distribution Options

Of the options proposed in the document, BHD4

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

Q14: Other options

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

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

Q15: Where?

This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally, it should be situated where it least effects existing communities but with ready access to Road and Rail links.

Some suggestions: Near Gt Blakenham, South of Sudbury close to rail link, Somewhere between Belstead/Bentley and A12/Main Railway.

Q16-25 Housing Types and Affordable Housing

National space standards should apply with provision for storage.

Requirements for provision of accessible homes and bungalows on 10+ developments are becoming a necessity.
Self Builds support local economy and rural outlook so should be encouraged.
Provisions for Affordable homes should also consider Starter homes which are more appropriate to support growth of local community.
Housing mix should consider need not greatest developers profits.
I support policies that increase the provision of Bungalows and Accessible housing
A factor apparently ignored is that we are living longer, and the number of retired people selling high value houses in city areas migrating to the area. The ageing population is looking for bungalows but they will also need more care so there will be a need to increase health and care infrastructure.
I support the retention of a 35% affordable housing target, but it should be more robustly enforced.
The total need for affordable house suggested is 19.4%. This is a drop from the previous policy of 35% in the face of a 71% local increase in private rentals (i.e. homes being bought up and rented to people who can't afford to buy a home), an increase in single parents looking for homes and an increase in local financial deprivation. That just doesn't stack up.
BDC under the last Local Plan only achieved 23% affordable housing which probably was the consequence of viability arguments from developers. Perhaps the proposal to reduce this to a 20% requirement is intended to make the target achievable? But the outcome is likely to be developers making the same arguments for similar reductions bring the deliverable supply down to about 13%.
There is not a reduction in affordable housing need, there is an increase, that is a nationally recognised fact, and BMSDC need to enforce the standing policy of 35% more robustly to achieve that. This could be improved by apply the policy to developments of three or more homes, or BMSDC engaging in the construction of council homes themselves that could all be affordable/starter homes.
Starter homes should also be added into this mix. Sold at a discount of at least 20% below market value with a maximum sale cost of £250,000 exclusively to first time buyers these are the type of homes the local community needs.
Q26-28 Rural Growth and Development

Sustainable development: at the heart of planning? This is not a recommendation to build but to build wisely. There has to be a realistic prospect that houses are needed and suitable for a given location and it would appear from the surveys done that Rural housing is needed by the expanding local resident population
It is interesting that small and individual developments which complement the county character have come forward successfully whereas the larger strategic sites drag on. Surely an indication that individual development is best for need, and therefore gets done. Whereas national developers build for profit and will hold off until they feel they can get the maximum return with no consideration for need.
Smaller developments also assimilate into the rural, scattered hamlet, market town character of the county.
The present policies are too restrictive on small and individual development, in that what appears to be perfectly acceptable infills and small extensions to village boarders which complement their character without oppressive change have been blocked by planning policies when large estate developments that are oppressive, change the character and destroy the individuality of local communities have been supported.
Proportionality is key; The JLP proposes a 9% Housing need over 20 years. This equates to one new home in a ten house hamlet, but why stop there. Such growth is potentially desirable naturally matching the growth of any micro community. Generally children grow older and want their own homes within their community, why shouldn't the provision and burden be spread evenly at 9%, by hamlet, village and town.
would support a limit on development at a level that does not dramatically change any community, with every effort made to preserve the best of the local landscape, views and ecology.
Q33-41 Economic Needs
A fundamental oversight is that the effects of Brexit have not been considered, either in trade, employment or migration calculations.
JLP 20 year projections based on historic data, all pre Brexit Vote, and the bulk of growth came from migration, so are likely to be very over optimistic.
Council finances dependent on growth but projections appear optimistic. The finances of every council depend on attracting growth so this is nationally competitive and yet there is no policy to achieve that, just wishful thinking. The Sugar Beet Factory site alone is already more land than the projected requirement for employment land with a total oversupply of 187 hectares (identified need is 12.3 hectares).
Commercial brownfield sites should be considered in preference to greenfield for all types of development.
There is an overwhelming case for a Northern Ipswich Bypass
Improvements to A1071 junctions through Sproughton are urgently required
A1071 link directly with A14 to improve access into developing BDC area and to reduce traffic congestion in Sproughton
Better Railway Service (expensive service and Ipswich station has limited access)
Private sector building has been constant for decades, it's Council building that has dropped off.
I strongly support a policy for the Council to start building themselves.
Q51: Biodiversity
Local area/spot designations like Special Landscape areas, cherished view points, wildlife, flora and fauna reserves etc. have evolved from many years experience and often considerable efforts by communities, sometimes based on fleeting observations of rare species. They preserve the best of our environment & any policy that introduces a subjective opinion has the risk of overlooking years of experience and effort in favour of financial considerations.
A point overlooked is the sequence of Landscape Character designations that run down from The Holiday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB).
Q52-54: Climate Change
Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS (Sustainable Drainage Systems) are not adequate for sustained (several day) rainfall events especially in flood zones.
 would want to see much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk.
n relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.
If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.

Issues to consider:
* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.
Q55-62: Landscape, Heritage and Region
Relevant to Sproughton are SLA's (Special landscape Areas) which not only cover Chantry Vale but most of the area surrounding the village. Other local designations that relate to views, recreational and open spaces either do, or may also, relate to Sproughton.
I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
I am concerned that the JLP suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance". It appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of experience in favour of Public / Economic Need.
The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. It is a ticking rural development time bomb.
In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.
A Landscape Project Area is mentioned, this appears to be the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale, so a bit like the Gipping valley/Sproughton as it extends from Chantry Vale. Accordingly, this designation might be appropriate for Sproughton and the River Valley.
Design
The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character. That lends itself to small developments not estates which change the character of the county.
All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.
Q63-68: Infrastructure

Overall I agree with the Infrastructure provision policy as set out. However, I believe that any developments MUST (not should) have good access to all necessary infrastructure needs that have been identified.
Planning permission should only be granted if there is some legally binding agreement that any identified infrastructure services WILL BE delivered as will the timing of its delivery. Guarantees should be structured such that they cannot be cancelled or avoided. Planning permission should only to be granted if there is a robust and effective legal agreement in place to ensure delivery.
 fully support and indeed consider it essential, that each scheme considers both the existing infrastructure commitments and cumulative impacts from other developments in a locality.
It is essential that any new infrastructure requirements identified with a development are phased and delivered as the development progresses. Past experience has shown this has not always been the case.
 fully support Option INF 2 that provides a strategic approach over and above the NPPF for cumulative growth, but with the caveat that infrastructure policies are adhered to.
Option INF2 specifically mentions education but this policy needs to apply to all necessary infrastructure i.e. from Health to Transport.
KEY ISSUES FOR SPROUGHTON are: highway / transport, education, health and flood risk
KEY ISSUES FOR FUTURE are: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
KEY FOR GROWTH are: Ipswich northern route, A12/A14 improvements, A1071/B1113 commuter routes improvement and mitigation of effects on community, rail upgrades, flood management, recycling provision, Broadband improvements, school places & accessible healthcare.

Q69-73: Healthy Communities

Whilst I agree with the policies outlined in the consultation document, I am concerned that any existing individual communities should not lose their community identity and cohesion as a result of 'creeping coalescence 'arising from the inappropriate location of new developments.
think greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. We suggest that more emphasis is given to ensuring that any necessary developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities.
broadly support Policy OS2 but are concerned that this does not result in the 'watering down' of existing open space provision existing within communities.
 support Policies NROS2 and POS2 in the protection of our Open Spaces.
In the case of Policy CF2 whilst fully supporting this, it is considered essential that any proposals to remove existing community facilities is supported by an appropriate formal assessment carried out in conjunction with the local community.
Q74-78: Place
Functional Clusters

Functional clusters is a way of looking at the existing spatial geography based on how communities interconnect. The functional clusters then inform the settlement hierarchy. Classification for these purposes is relevant to determining the approach to planning.
The approach is not appropriate. Planning policy should not be based on artificial constructs, which over emphasise the role of larger settlements. Planning policy should ensure a proportional allocation of housing and employment land across the Districts in support of the characteristics and needs of existing communities.

Settlement Boundaries

The JLP view is that settlement boundaries need redrawing to allow rural growth opportunities.
Whereas some factors considered are appropriate the new boundaries have been drawn to include development sites that have not been delivered. Further thought needs to be given to planning consents that have been granted but not yet delivered.
Extensions to a settlement boundary are inappropriate if existing permissions have not been delivered.
 also feel that the determination of settlement on the basis purely of numbers is over-simplistic. The setting and historical purpose of any collection of houses is important; for example, a collection of farm workers cottages located in the countryside should not necessarily establish a basis for a larger settlement. The existence of 'community' is also important.
Potential Land for Development

The JLP proposes sites across the district which have come forward for development and which they provisionally assess as being technically acceptable. There is significantly more proposed than is needed for the 20 year supply so clearly some will be eliminated based on the strength of arguments and opinion both on validity and quantity.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9226

Received: 08/11/2017

Respondent: Mrs Mel Seager

Representation:

Q5: Most important for Sproughton
Local services must be improved: transport infrastructure, school places, accessible healthcare services; and enhanced environmental assets.

Full text:

My comments are as follows:

Q1 and 2: Vision and Objectives

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

Objectives

Development must be balanced between homes and employment. Encourage inward investment, protect and enhance environmental assets, provision of necessary infrastructure and services. Provision of housing must be what local residents need and can afford.
Q3: Other objectives
The plan should achieve radically improved local road networks especially the "Ipswich Northern Route" and improvements to the A1071 at B1113 and Hadleigh Road junctions, and an access onto the A14. The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
The plan must ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time and without back paddling - planning needs to be pro-active on this.
Q4: Priorities
Development shouldn't lead to communities losing their identities by swamping and creeping coalescence (merging of communities). Location of growth to be spread more pragmatically across Babergh rather than fewer large sites.
Q5: Most important for Sproughton
Local services must be improved: transport infrastructure, school places, accessible healthcare services; and enhanced environmental assets.
Q7: Option HR1
Do NOT agree. The housing need identified in the Strategic Housing Market Assessment 2017 (SHMA) may well be overstated for the District during the life of the JLP. The report methodology uses historic patterns of migration, extrapolated forwards to arrive at a projected population growth, but no regard seems to be have been had for the likely effects on both domestic and overseas migration of the UK leaving the EU in 2019. This, and the intended tightening of immigration controls, is likely to quickly and significantly reduce the amount of inward migration and significantly increase the amount of outward migration in the District further, almost at the same time as the JLP itself is adopted. These effects are likely to reduce the forecast need for new housing during the life on the JLP.
Additionally, the potential relocation of major industries to continental Europe if a "hard" Brexit is the outcome of current negotiations is likely to further reduce demand for housing in the District and surrounding areas. Projected employment growth in the District is in the Professional and Business services sectors which may be especially vulnerable to relocation. Given the uncertainty on Brexit and levels of overseas migration, and with emphasis on the "Northern Powerhouse" and HS2, outward domestic migration could increase significantly with employment opportunities being created along the HS2 corridor rather than in East Anglia. This would reduce demand for housing in the District still further.
These potential impacts are real and significant. The JLP must take the most likely possibilities into account and be based on revised data.
The application of a "market signals uplift" is discussed in the SHMA (pp53-64). The consultants are clear that in the absence of any guidance other than an uplift should be "reasonable", a "judgement" is required. Their judgement (para 6.54 on page 63) in the case of Babergh is that a 15% uplift should be applied. Comparing the narrative summary of the case in Babergh with that of Suffolk Coastal on p64 (also judged at 15% uplift) the judgements do not seem to be equal and the uplift seems excessive in Babergh by comparison with Suffolk Coastal. All other Districts are judged at 10%.
The consultation document does not explain in simple enough detail how a projected population increase over the period of the JLP in Babergh of 8086 persons translates into an OAN of 7820 dwellings. In order to be able to comment effectively, it is important that the council's case is clearly stated in ways people can readily understand. The total dwelling figure seems incongruent with other evidence in the SHMA: the fact that over the period 2001-2015, both overseas migration and natural change were negative, and a past average occupancy of 2.3 persons per dwelling.
The JLP should also have an in-built flexibility so that the housing need can be regularly reviewed against forecasts during the life of the plan to 2036 and adjusted to take account of significant changes in demand which affect the amount, type and location of housing during that time.
Q8: Contingency
It makes sense in a plan that is expected to span such a considerable period of time for there to be some contingency provision against identified sites that cannot, for whatever reason, be developed within the specified time. In such circumstances, the activation of a contingency site should permanently remove the original intended site from the plan. In other words, each contingency activated should be a replacement within the plan for an original site that could not be developed as planned, NOT an additional site for development.

Q9: Specific measures to include

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

Q10: Trigger factors

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

Q11: Proposed criteria approach

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

Q12: Joint Settlement Hierarchy

See the answer above for doubts about its validity

Q13: Spatial Distribution Options

Of the options proposed in the document, BHD4

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

Q14: Other options

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

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

Q15: Where?

This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally, it should be situated where it least effects existing communities but with ready access to Road and Rail links.

Some suggestions: Near Gt Blakenham, South of Sudbury close to rail link, Somewhere between Belstead/Bentley and A12/Main Railway.

Q16-25 Housing Types and Affordable Housing

National space standards should apply with provision for storage.

Requirements for provision of accessible homes and bungalows on 10+ developments are becoming a necessity.
Self Builds support local economy and rural outlook so should be encouraged.
Provisions for Affordable homes should also consider Starter homes which are more appropriate to support growth of local community.
Housing mix should consider need not greatest developers profits.
I support policies that increase the provision of Bungalows and Accessible housing
A factor apparently ignored is that we are living longer, and the number of retired people selling high value houses in city areas migrating to the area. The ageing population is looking for bungalows but they will also need more care so there will be a need to increase health and care infrastructure.
I support the retention of a 35% affordable housing target, but it should be more robustly enforced.
The total need for affordable house suggested is 19.4%. This is a drop from the previous policy of 35% in the face of a 71% local increase in private rentals (i.e. homes being bought up and rented to people who can't afford to buy a home), an increase in single parents looking for homes and an increase in local financial deprivation. That just doesn't stack up.
BDC under the last Local Plan only achieved 23% affordable housing which probably was the consequence of viability arguments from developers. Perhaps the proposal to reduce this to a 20% requirement is intended to make the target achievable? But the outcome is likely to be developers making the same arguments for similar reductions bring the deliverable supply down to about 13%.
There is not a reduction in affordable housing need, there is an increase, that is a nationally recognised fact, and BMSDC need to enforce the standing policy of 35% more robustly to achieve that. This could be improved by apply the policy to developments of three or more homes, or BMSDC engaging in the construction of council homes themselves that could all be affordable/starter homes.
Starter homes should also be added into this mix. Sold at a discount of at least 20% below market value with a maximum sale cost of £250,000 exclusively to first time buyers these are the type of homes the local community needs.
Q26-28 Rural Growth and Development

Sustainable development: at the heart of planning? This is not a recommendation to build but to build wisely. There has to be a realistic prospect that houses are needed and suitable for a given location and it would appear from the surveys done that Rural housing is needed by the expanding local resident population
It is interesting that small and individual developments which complement the county character have come forward successfully whereas the larger strategic sites drag on. Surely an indication that individual development is best for need, and therefore gets done. Whereas national developers build for profit and will hold off until they feel they can get the maximum return with no consideration for need.
Smaller developments also assimilate into the rural, scattered hamlet, market town character of the county.
The present policies are too restrictive on small and individual development, in that what appears to be perfectly acceptable infills and small extensions to village boarders which complement their character without oppressive change have been blocked by planning policies when large estate developments that are oppressive, change the character and destroy the individuality of local communities have been supported.
Proportionality is key; The JLP proposes a 9% Housing need over 20 years. This equates to one new home in a ten house hamlet, but why stop there. Such growth is potentially desirable naturally matching the growth of any micro community. Generally children grow older and want their own homes within their community, why shouldn't the provision and burden be spread evenly at 9%, by hamlet, village and town.
I would support a limit on development at a level that does not dramatically change any community, with every effort made to preserve the best of the local landscape, views and ecology.
Q33-41 Economic Needs
A fundamental oversight is that the effects of Brexit have not been considered, either in trade, employment or migration calculations.
JLP 20 year projections based on historic data, all pre Brexit Vote, and the bulk of growth came from migration, so are likely to be very over optimistic.
Council finances dependent on growth but projections appear optimistic. The finances of every council depend on attracting growth so this is nationally competitive and yet there is no policy to achieve that, just wishful thinking. The Sugar Beet Factory site alone is already more land than the projected requirement for employment land with a total oversupply of 187 hectares (identified need is 12.3 hectares).
Commercial brownfield sites should be considered in preference to greenfield for all types of development.
There is an overwhelming case for a Northern Ipswich Bypass
Improvements to A1071 junctions through Sproughton are urgently required
A1071 link directly with A14 to improve access into developing BDC area and to reduce traffic congestion in Sproughton
Better Railway Service (expensive service and Ipswich station has limited access)
Private sector building has been constant for decades, it's Council building that has dropped off.
I strongly support a policy for the Council to start building themselves.
Q51: Biodiversity
Local area/spot designations like Special Landscape areas, cherished view points, wildlife, flora and fauna reserves etc. have evolved from many years experience and often considerable efforts by communities, sometimes based on fleeting observations of rare species. They preserve the best of our environment & any policy that introduces a subjective opinion has the risk of overlooking years of experience and effort in favour of financial considerations.
A point overlooked is the sequence of Landscape Character designations that run down from The Holiday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB).
Q52-54: Climate Change
Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS (Sustainable Drainage Systems) are not adequate for sustained (several day) rainfall events especially in flood zones.
I would want to see much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk.
In relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.
If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.

Issues to consider:
* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.
Q55-62: Landscape, Heritage and Region
Relevant to Sproughton are SLA's (Special landscape Areas) which not only cover Chantry Vale but most of the area surrounding the village. Other local designations that relate to views, recreational and open spaces either do, or may also, relate to Sproughton.
I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
I am concerned that the JLP suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance". It appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of experience in favour of Public / Economic Need.
The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. It is a ticking rural development time bomb.
In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.
A Landscape Project Area is mentioned, this appears to be the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale, so a bit like the Gippingvalley/Sproughton as it extends from Chantry Vale. Accordingly, this designation might be appropriate for Sproughton and the River Valley.
Design
The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character. That lends itself to small developments not estates which change the character of the county.
All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.
Q63-68: Infrastructure

Overall I agree with the Infrastructure provision policy as set out. However, I believe that any developments MUST (not should) have good access to all necessary infrastructure needs that have been identified.
Planning permission should only be granted if there is some legally binding agreement that any identified infrastructure services WILL BE delivered as will the timing of its delivery. Guarantees should be structured such that they cannot be cancelled or avoided. Planning permission should only to be granted if there is a robust and effective legal agreement in place to ensure delivery.
I fully support and indeed consider it essential, that each scheme considers both the existing infrastructure commitments and cumulative impacts from other developments in a locality.
It is essential that any new infrastructure requirements identified with a development are phased and delivered as the development progresses. Past experience has shown this has not always been the case.
I fully support Option INF 2 that provides a strategic approach over and above the NPPF for cumulative growth, but with the caveat that infrastructure policies are adhered to.
Option INF2 specifically mentions education but this policy needs to apply to all necessary infrastructure i.e. from Health to Transport.
KEY ISSUES FOR SPROUGHTON are: highway / transport, education, health and flood risk
KEY ISSUES FOR FUTURE are: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
KEY FOR GROWTH are: Ipswich northern route, A12/A14 improvements, A1071/B1113 commuter routes improvement and mitigation of effects on community, rail upgrades, flood management, recycling provision, Broadband improvements, school places & accessible healthcare.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9231

Received: 08/11/2017

Respondent: The Gooderham Family and ESCO Developments Ltd

Agent: Cheffins Planning & Development

Representation:

Bacton is considered a suitable and sustainable location for residential development. However, in identifying sites suitable for development due regard needs to be given to the impact that they have on the character and setting of listed buildings, the relationship to existing residential development and potential sources of nuisance and odour such as waste water treatment works. The provision of access, both pedestrian and vehicular is an important consideration.

Full text:

See attached comment form

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9308

Received: 08/11/2017

Respondent: Mrs Mel Seager

Representation:

Q5: Most important for Sproughton
Local services must be improved: transport infrastructure, school places, accessible healthcare services; and enhanced environmental assets.

Full text:

My comments are as follows:

Q1 and 2: Vision and Objectives

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

Objectives

Development must be balanced between homes and employment. Encourage inward investment, protect and enhance environmental assets, provision of necessary infrastructure and services. Provision of housing must be what local residents need and can afford.
Q3: Other objectives
The plan should achieve radically improved local road networks especially the "Ipswich Northern Route" and improvements to the A1071 at B1113 and Hadleigh Road junctions, and an access onto the A14. The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
The plan must ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time and without back paddling - planning needs to be pro-active on this.
Q4: Priorities
Development shouldn't lead to communities losing their identities by swamping and creeping coalescence (merging of communities). Location of growth to be spread more pragmatically across Babergh rather than fewer large sites.
Q5: Most important for Sproughton
Local services must be improved: transport infrastructure, school places, accessible healthcare services; and enhanced environmental assets.
Q7: Option HR1
Do NOT agree. The housing need identified in the Strategic Housing Market Assessment 2017 (SHMA) may well be overstated for the District during the life of the JLP. The report methodology uses historic patterns of migration, extrapolated forwards to arrive at a projected population growth, but no regard seems to be have been had for the likely effects on both domestic and overseas migration of the UK leaving the EU in 2019. This, and the intended tightening of immigration controls, is likely to quickly and significantly reduce the amount of inward migration and significantly increase the amount of outward migration in the District further, almost at the same time as the JLP itself is adopted. These effects are likely to reduce the forecast need for new housing during the life on the JLP.
Additionally, the potential relocation of major industries to continental Europe if a "hard" Brexit is the outcome of current negotiations is likely to further reduce demand for housing in the District and surrounding areas. Projected employment growth in the District is in the Professional and Business services sectors which may be especially vulnerable to relocation. Given the uncertainty on Brexit and levels of overseas migration, and with emphasis on the "Northern Powerhouse" and HS2, outward domestic migration could increase significantly with employment opportunities being created along the HS2 corridor rather than in East Anglia. This would reduce demand for housing in the District still further.
These potential impacts are real and significant. The JLP must take the most likely possibilities into account and be based on revised data.
The application of a "market signals uplift" is discussed in the SHMA (pp53-64). The consultants are clear that in the absence of any guidance other than an uplift should be "reasonable", a "judgement" is required. Their judgement (para 6.54 on page 63) in the case of Babergh is that a 15% uplift should be applied. Comparing the narrative summary of the case in Babergh with that of Suffolk Coastal on p64 (also judged at 15% uplift) the judgements do not seem to be equal and the uplift seems excessive in Babergh by comparison with Suffolk Coastal. All other Districts are judged at 10%.
The consultation document does not explain in simple enough detail how a projected population increase over the period of the JLP in Babergh of 8086 persons translates into an OAN of 7820 dwellings. In order to be able to comment effectively, it is important that the council's case is clearly stated in ways people can readily understand. The total dwelling figure seems incongruent with other evidence in the SHMA: the fact that over the period 2001-2015, both overseas migration and natural change were negative, and a past average occupancy of 2.3 persons per dwelling.
The JLP should also have an in-built flexibility so that the housing need can be regularly reviewed against forecasts during the life of the plan to 2036 and adjusted to take account of significant changes in demand which affect the amount, type and location of housing during that time.
Q8: Contingency
It makes sense in a plan that is expected to span such a considerable period of time for there to be some contingency provision against identified sites that cannot, for whatever reason, be developed within the specified time. In such circumstances, the activation of a contingency site should permanently remove the original intended site from the plan. In other words, each contingency activated should be a replacement within the plan for an original site that could not be developed as planned, NOT an additional site for development.

Q9: Specific measures to include

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

Q10: Trigger factors

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

Q11: Proposed criteria approach

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

Q12: Joint Settlement Hierarchy

See the answer above for doubts about its validity

Q13: Spatial Distribution Options

Of the options proposed in the document, BHD4

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

Q14: Other options

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

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

Q15: Where?

This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally, it should be situated where it least effects existing communities but with ready access to Road and Rail links.

Some suggestions: Near Gt Blakenham, South of Sudbury close to rail link, Somewhere between Belstead/Bentley and A12/Main Railway.

Q16-25 Housing Types and Affordable Housing

National space standards should apply with provision for storage.

Requirements for provision of accessible homes and bungalows on 10+ developments are becoming a necessity.
Self Builds support local economy and rural outlook so should be encouraged.
Provisions for Affordable homes should also consider Starter homes which are more appropriate to support growth of local community.
Housing mix should consider need not greatest developers profits.
I support policies that increase the provision of Bungalows and Accessible housing
A factor apparently ignored is that we are living longer, and the number of retired people selling high value houses in city areas migrating to the area. The ageing population is looking for bungalows but they will also need more care so there will be a need to increase health and care infrastructure.
I support the retention of a 35% affordable housing target, but it should be more robustly enforced.
The total need for affordable house suggested is 19.4%. This is a drop from the previous policy of 35% in the face of a 71% local increase in private rentals (i.e. homes being bought up and rented to people who can't afford to buy a home), an increase in single parents looking for homes and an increase in local financial deprivation. That just doesn't stack up.
BDC under the last Local Plan only achieved 23% affordable housing which probably was the consequence of viability arguments from developers. Perhaps the proposal to reduce this to a 20% requirement is intended to make the target achievable? But the outcome is likely to be developers making the same arguments for similar reductions bring the deliverable supply down to about 13%.
There is not a reduction in affordable housing need, there is an increase, that is a nationally recognised fact, and BMSDC need to enforce the standing policy of 35% more robustly to achieve that. This could be improved by apply the policy to developments of three or more homes, or BMSDC engaging in the construction of council homes themselves that could all be affordable/starter homes.
Starter homes should also be added into this mix. Sold at a discount of at least 20% below market value with a maximum sale cost of £250,000 exclusively to first time buyers these are the type of homes the local community needs.
Q26-28 Rural Growth and Development

Sustainable development: at the heart of planning? This is not a recommendation to build but to build wisely. There has to be a realistic prospect that houses are needed and suitable for a given location and it would appear from the surveys done that Rural housing is needed by the expanding local resident population
It is interesting that small and individual developments which complement the county character have come forward successfully whereas the larger strategic sites drag on. Surely an indication that individual development is best for need, and therefore gets done. Whereas national developers build for profit and will hold off until they feel they can get the maximum return with no consideration for need.
Smaller developments also assimilate into the rural, scattered hamlet, market town character of the county.
The present policies are too restrictive on small and individual development, in that what appears to be perfectly acceptable infills and small extensions to village boarders which complement their character without oppressive change have been blocked by planning policies when large estate developments that are oppressive, change the character and destroy the individuality of local communities have been supported.
Proportionality is key; The JLP proposes a 9% Housing need over 20 years. This equates to one new home in a ten house hamlet, but why stop there. Such growth is potentially desirable naturally matching the growth of any micro community. Generally children grow older and want their own homes within their community, why shouldn't the provision and burden be spread evenly at 9%, by hamlet, village and town.
I would support a limit on development at a level that does not dramatically change any community, with every effort made to preserve the best of the local landscape, views and ecology.
Q33-41 Economic Needs
A fundamental oversight is that the effects of Brexit have not been considered, either in trade, employment or migration calculations.
JLP 20 year projections based on historic data, all pre Brexit Vote, and the bulk of growth came from migration, so are likely to be very over optimistic.
Council finances dependent on growth but projections appear optimistic. The finances of every council depend on attracting growth so this is nationally competitive and yet there is no policy to achieve that, just wishful thinking. The Sugar Beet Factory site alone is already more land than the projected requirement for employment land with a total oversupply of 187 hectares (identified need is 12.3 hectares).
Commercial brownfield sites should be considered in preference to greenfield for all types of development.
There is an overwhelming case for a Northern Ipswich Bypass
Improvements to A1071 junctions through Sproughton are urgently required
A1071 link directly with A14 to improve access into developing BDC area and to reduce traffic congestion in Sproughton
Better Railway Service (expensive service and Ipswich station has limited access)
Private sector building has been constant for decades, it's Council building that has dropped off.
I strongly support a policy for the Council to start building themselves.
Q51: Biodiversity
Local area/spot designations like Special Landscape areas, cherished view points, wildlife, flora and fauna reserves etc. have evolved from many years experience and often considerable efforts by communities, sometimes based on fleeting observations of rare species. They preserve the best of our environment & any policy that introduces a subjective opinion has the risk of overlooking years of experience and effort in favour of financial considerations.
A point overlooked is the sequence of Landscape Character designations that run down from The Holiday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB).
Q52-54: Climate Change
Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS (Sustainable Drainage Systems) are not adequate for sustained (several day) rainfall events especially in flood zones.
I would want to see much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk.
In relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.
If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.

Issues to consider:
* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.
Q55-62: Landscape, Heritage and Region
Relevant to Sproughton are SLA's (Special landscape Areas) which not only cover Chantry Vale but most of the area surrounding the village. Other local designations that relate to views, recreational and open spaces either do, or may also, relate to Sproughton.
I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
I am concerned that the JLP suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance". It appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of experience in favour of Public / Economic Need.
The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. It is a ticking rural development time bomb.
In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.
A Landscape Project Area is mentioned, this appears to be the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale, so a bit like the Gippingvalley/Sproughton as it extends from Chantry Vale. Accordingly, this designation might be appropriate for Sproughton and the River Valley.
Design
The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character. That lends itself to small developments not estates which change the character of the county.
All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.
Q63-68: Infrastructure

Overall I agree with the Infrastructure provision policy as set out. However, I believe that any developments MUST (not should) have good access to all necessary infrastructure needs that have been identified.
Planning permission should only be granted if there is some legally binding agreement that any identified infrastructure services WILL BE delivered as will the timing of its delivery. Guarantees should be structured such that they cannot be cancelled or avoided. Planning permission should only to be granted if there is a robust and effective legal agreement in place to ensure delivery.
I fully support and indeed consider it essential, that each scheme considers both the existing infrastructure commitments and cumulative impacts from other developments in a locality.
It is essential that any new infrastructure requirements identified with a development are phased and delivered as the development progresses. Past experience has shown this has not always been the case.
I fully support Option INF 2 that provides a strategic approach over and above the NPPF for cumulative growth, but with the caveat that infrastructure policies are adhered to.
Option INF2 specifically mentions education but this policy needs to apply to all necessary infrastructure i.e. from Health to Transport.
KEY ISSUES FOR SPROUGHTON are: highway / transport, education, health and flood risk
KEY ISSUES FOR FUTURE are: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
KEY FOR GROWTH are: Ipswich northern route, A12/A14 improvements, A1071/B1113 commuter routes improvement and mitigation of effects on community, rail upgrades, flood management, recycling provision, Broadband improvements, school places & accessible healthcare.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9372

Received: 09/11/2017

Respondent: Beyton Parish Council

Representation:

Beyton should remain a distinct village and the open spaces around the village protected as should conservation areas.
Any neigbouring development should not have an adverse impact on the village. Development within the village should be aligned to the need of the village and in keeping with the surrounding environment.

Full text:

See attached comment form

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9420

Received: 09/11/2017

Respondent: Bacton Parish Council

Representation:

As identified in Bacton Parish Plan 2010. Relocation of primary school to a new site to accommodate growth. Larger village hall, suitable for indoor sport on a new site with adequate car parking. Improve roadside footpaths especially under the railway bridge and along Broad Road (B1113). Recreational facilities, especially for under 11s.

Full text:

See attached letter

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9511

Received: 14/11/2017

Respondent: Cllr John Hinton

Representation:

That growth should be by Local agreement and that provisions of the Localism Act such as Neighbourhood Plan should when "made" be respected and implemented. That todays facilities should not be a given for the future. (Judging Health Provision by floor space without consideration of any medical practitioner to occupy it is not a reliable way to measure infrastructure provision.)

Full text:

See full scanned representation attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9634

Received: 07/11/2017

Respondent: Mr Chris Marshall

Representation:

MOST IMPORTANT FOR SPROUGHTON - transport infrastructure, school places, accessible healthcare services, enhance environmental assets.

Full text:

Dear Sir or Madam
I would like to lodge my response to the BMSDC JLP consultation document. Could you please confirm receipt of my submission and include me in the mailing list for updates on the progress of the JLP.
Section - Strategic
Vision
* Development to be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need.
Objectives
* Development balanced between homes and employment. Encourage inward investment, protect and enhance environmental assets, provision of necessary infrastructure and services, but emphasise provision of 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 junctions, and an access onto the A14. The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
* Ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time and without back paddling -Planning needs to be pro-active on this.
Priorities
* Development shouldn't lead to communities losing their identities by swamping and creeping coalescence (merging of communities).
* Location of growth to be spread more pragmatically across Babergh rather than fewer large sites
* MOST IMPORTANT FOR SPROUGHTON - transport infrastructure, school places, accessible healthcare services, enhance environmental assets.
Housing Requirement, Settlement Hierarchy and Housing Distribution
Housing Requirement 2014 to 2036 - Option HR1 - 7820 new houses based on pop. growth.
* I do not agree with this: numbers seem overstated with no apparent account taken of effects of BREXIT on domestic and overseas migration.
* Relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability.
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3)
CONTINGENCY and DELIVERY
* Current 'stuck' sites with permissions and no building suggests need for contingency going forward - replace 'stuck' sites with others.
* Contingency sites to be replacement and not additional, original sites to be taken out of plan. Regular review of demand required checking the guiding principles of type, tenure, place and need (local) - should trigger need for reserve sites.
HIERARCHY
* Village status distorted by scoring system, influences development location.
* Sproughton classed as CORE and also HINTERLAND village, can't be both.
* I do not agree with the stance 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.
* 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 offered: 1) County Town Focused, 2) Market Town/Rural balance, 3) Transport Corridor Focused. 4) New Settlement Focused. Due to the settlement types designated to Sproughton in the Hierarchy scoring the first three options propose over 50% of growth in our designations, only the last option reduces this to 35%.
* The combined arbitrary criteria for scoring of both Hierarchy and Spatial Distribution chosen by BMSDC for the JLP just appears to promote the site availability that has come forward, effectively a mechanism to justify the sites.
* JLP to 2036 gives opportunity for bold, innovative and creative thinking but continuing the urban sprawl / welding / merging communities not the answer.
* Creating well planned, self-sufficient purpose built settlements with their own identities is and thereby preserving the qualities of existing communities.
OTHER DITRIBUTION OPTIONS
* I would support an option for proportional ditribution
* 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 iopportunity; this matches a district wide 9% proportional distribution.
NEW SETTLEMENT
* It is the proposition to create a new or garden town, a separate and distinct community most probably in a new location with minimal local impact but the potential to improve/create improved county infrastructure/services.
* This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally situated where it least effects existing communities but with ready access to Road and Rail links.
* Some suggestions: Near Gt Blakenham, South of Sudbury close to rail link, Somewhere between Belstead/Bentley and A12/Main Rialway.
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
* I support policies that increase the provision of Bungalows and Accessible housing
* A factor apparently ignored is that we are living longer, and the number of retired people selling high value houses in city areas migrating to the area. The 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
* I support the retention of a 35% affordable housing target, but it should be more robustly enforced.
* The total need for affordable house suggested is 19.4%. This is a drop from the previous policy of 35% in the face of a 71% local increase in private rentals (i.e. homes being bought up and rented to people who can't afford to buy a home), an increase in single parents looking for homes and an increase in local financial deprivation. That just doesn't stack up.
* BDC under the last Local Plan only achieved 23% affordable housing which probably was the consequence of viability arguments from developers. Perhaps the proposal to reduce this to a 20% requirement is intended to make the target achievable? But the outcome is likely to be developers making the same arguments for similar reductions bring the deliverable supply down to about 13%.
* There is not a reduction in affordable housing need, there is an increase, that is a nationally recognised fact, and BMSDC need to enforce the standing policy of 35% more robustly to achieve that. This could be improved by apply the policy to developments of three or more homes, or BMSDC engaging in the construction of council homes themselves that could all be affordable/starter homes.
* Starter homes should also be added into this mix. Sold at a discount of at least 20% below market value with a maximum sale cost of £250,000 exclusively to first time buyers these are the type of homes the local community needs.
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.
* 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.
Gypsies and travellers
* Although policy relates to both BDC and Mid Suffolk the report suggests that need is M.S. The Cromer incident occurred when travellers gathered in large numbers therefore, limiting sites to short stay and small number of vehicles (say 3 days/3 plots) with sites well spread apart (say 20 miles) is safer for communities.
Economy
* A fundamental oversight is that the effects of Brexit has not been considered, either in trade, employment or migration calculations.
* JLP 20 year projections based on historic data, all pre Brexit Vote, and the bulk of growth came from migration, so are likely to be very over optimistic.
* Council finances dependent on growth but projections appear optimistic. The finances of every council depend on attracting growth so this is nationally competitive and yet there is no policy to achieve that, just wishful thinking. The Sugar Beet Factory site alone is already more land than the projected requirement for employment land with a total oversupply of 187 hectares (identified need is 12.3 hectares).
* Commercial brownfield sites should be considered in preference to greenfield for all types of development.
* Need for Northern Ipswich Bypass
* Improvements to A1071 junctions through Sproughton
* A1071 link directly with A14 to improve access into developing BDC area.
* Better Railway Service (expensive service and Ipswich station has limited access)
* Private sector building has been constant for decades, its Council building that has dropped off.
* We would support a policy for the Council to start building themselves.
Retail
* Call for sites did not actually bring forward any retail sites however there is a massive oversupply of Commercial sites that could accommodate Retail/Leisure parks if growth projections realised.
* Restricting all retail growth to town centres may be too restrictive as some growth may need to be accommodated away from town centres where sites become available.
* Retail policy inclined towards town centre growth, however as a rural community this is impractical without improved parking or an efficient transport network.
* Option to protect retail facilities in smaller towns/villages which would appear to be an appropriate policy. However how or what that might amount to is unclear.
* 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 view points, wildlife, flora and fauna reserves etc. have evolved from many years experience and often considerable efforts by communities, sometimes based on fleeting observations of rare species. They preserve the best of our environment & any policy that introduces a subjective opinion has the risk of overlooking years of experience and effort in favour of financial considerations.
* A point overlooked is the sequence of Landscape Character designations that run down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB). Does anyone know of a famous local artist?
Climate change
* Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS (Sustainable Drainage Systems) are not adequate for sustained (several day) rainfall events especially in flood zones.
* I would recommend much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk.
* In relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.
Sustainability standards
If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.
Issues to consider:
* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.
Landscape, heritage and design
* Relevant to Sproughton are SLA's (Special landscape Areas) which not only cover Chantry Vale but most of the area surrounding the village. Other local designations that relate to views, recreational and open spaces either do, or may also, relate to Sproughton.
* I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
* It then suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance" which is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of experience in favour of Public / Economic Need.
* The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. It is a ticking rural development time bomb.
* Important Note:
* In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.
* A Landscape Project Area is mentioned, this appears to be the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale, so a bit like the Gipping valley/Sproughton as it extends from Chantry Vale. Accordingly, this designation might be appropriate for Sproughton and the River Valley.
* Design
* The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character.
* That lends itself to small developments not estates which change the character of the county.
* All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.
Delivery
Infrastructure
* Overall I agree with the Infrastructure provision policy as set out. However, I believe that any developments MUST (not should) have good access to all necessary infrastructure needs that have been identified.
* Planning permission should only be granted if there is some legally binding agreement that any identified infrastructure services WILL BE delivered as will the timing of its delivery. Guarantees should be structured such that they cannot be cancelled or avoided. Planning permission should only to be granted if there is a robust and effective legal agreement in place to ensure delivery.
* I fully support and indeed, consider it essential that each scheme considers both the existing infrastructure commitments and cumulative impacts from other developments in a locality.
* It is 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.
* 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.
* 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 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.
* I consider greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. I suggest that more emphasis is given to ensuring that any necessary developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities.
* 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 fully supporting this, it is considered essential that any proposals to remove existing community facilities is supported by an appropriate formal assessment carried out in conjunction with the local community.
Functional Clusters
* Functional clusters is a way of looking at the existing spatial geography based on how communities interconnect. The functional clusters then inform the settlement hierarchy. Classification for these purposes is relevant to determining the approach to planning.
* The approach is not appropriate. Planning policy should not be based on artificial constructs, which over emphasise the role of larger settlements. Planning policy should ensure a proportional allocation of housing and employment land across the Districts in support of the characteristics and needs of existing communities.
Settlement Boundaries
* Settlement boundaries are used to identify where the principle of development has been established, a threshold of ten related dwellings is applied. land outside of this settlement boundaries is countryside.
* The JLP view is that they need redrawing to allow rural growth opportunities.
* Whereas some factors considered are appropriate the new boundaries have been drawn to include development sites that have not been delivered. Further thought needs to be given to planning consents that have been granted but not yet delivered.
* Extensions to a settlement boundary are inappropriate if existing permissions have not been delivered.
* I 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

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

On an aggregate basis, no - the sites identified are not appropriate for allocation within the settlement boundary. As a general principle, planning policy should ensure a proportional allocation of housing and employment land across the Districts, sympathetic to and in support of the characteristics and needs of existing communities. A total of 9,446 dwellings are proposed (sum of dwellings across all sites specified within the SHLAA). However, once the net number of dwellings is calculated having taken into account planning applications granted, in progress etc, the Objectively Assessed Need (OAN) is reduced to 4,210. It appears that 2,320 of these dwellings i.e. 55.11% of the total development proposed in Babergh is designated for Sproughton. This is a significant over development of Sproughton which currently has around 581 dwellings - this would be an increase of 397% in parish size. It is completely disproportionate and would result in Bramford joining with Sproughton and Sproughton being absorbed by Ipswich in the same way that Kesgrave and Rushmere-St- Andrew has been. Not so much 'creeping coalescence' as 'complete digestion'. A much fairer basis for development would be a pro-rated approach with some tweaking for those settlements that are very small in size.On an individual basis, please see below specific comments in respect of sites allocated in and around Sproughton village:
Some observations to help inform any responses to individual sites in Sproughton.
SS1024:
Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0721
Site appropriate for development, subject to the scheme proposal. It is not clear to local residents, however, why - given the size of the site - a portion may not be allocated to housing.
SS1023
Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0191
Some of the site (specifically, in the south-west corner / adjacent to the existing settlement on London Road) may be appropriate for development, subject to the development of an appropriate scheme, the considerations already identified (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats), and further considerations comprising:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0711
Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, environmental and heritage), additional key considerations include:
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley) and the views to and from the river-side walks that would be impacted by the proposed site
* 'Creeping coalescence' between Bramford and Sproughton.
SS0299
Site is appropriate subject to the development of an appropriate scheme.
With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is our view, however, that the scheme as set out in the application is not appropriate and we support any challenge Sproughton Parish Council may make to any decision approving that application.
SS0223
Site not appropriate for development.
The site assessment summary notes appropriate considerations to factor into any decision (highways, landscape, heritage and allotment relocation). However, the District Councils should be in no doubt that any proposed development of a special landscape area, which also results in a loss of amenity and potentially significant negative social and economic impacts on the existing local community, is deeply objectionable.
SS1026
Site is appropriate subject to the development of an appropriate scheme.
With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is our view, however, that the scheme as set out in the application is not appropriate and we support any challenge Sproughton Parish Council may make to any decision approving that application.
Growth
* The data used to forecast growth is too historic as it makes no consideration for the effects of the Brexit vote, it is therefore unreliable and potentially over ambitious.
* On the back of this data the JLP proposes significant home building to accommodate significant migration into the area to fulfil the employment needs of significant growth in business/employment.
* But the JLP does little or nothing to promote growth in Business other than bring in more potential employees by building more housing.
* The government is pushing growth in the Midlands and Northern Powerhouse and they have much better business infrastructures. Suffolk cannot compete with this to attract new business unless councils introduce competitive incentives and improve the business infrastructure of the county. But this JLP proposes nothing constructive to achieve that.
* This JLP is good for business as more housing will increase the unemployed pool making it easier and often cheaper to run a business, but that doesn't mean growth.
* But if house building is not matched by business growth it will not be good for the bulk of the resident population as there will be no increase in overall wealth in the community, but the community will be supporting a bigger population.
* Developers and Councils promote growth as the ultimate objective, but for who? Take a look at London and compare it with your present lifestyle. Businesses and Councils do well in Cities, but what is the quality of life of those that live there?
New NPPF white paper imminent
* The latest consultation paper on the NPPF is proposing a cap of 40% above any LP created prior to their new proposals.
* Therefore it is entirely possible that the unrealistic housing needs proposals being proposed in our JLP could be increased by another 40% making an unrealistic growth plan impossible.

Yours faithfully

Chris Marshall

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9690

Received: 07/11/2017

Respondent: Miss R P Baillon

Representation:

Debenham: the most important aspect is the development of an adequate infrastructure and facilities for the current population and those who come into the village from neighbouring villages and hamlets where there are no facilities. This needs to be addressed if further developments are to take place. The amenities and infrastructure for the area needs to be planned carefully to allow for a positive quality of life.

There needs to be continual upkeep by the Council and Highways Agency in their various spheres of responsibility to maintain the village adequately.

Full text:

It is hoped that Mid Suffolk residents' opinions will be taken into account when finalising the Joint Local Plan particularly as it is well known that, in the past, little notice has been taken of the comments made by the Parish Council and individuals regarding the developments taking place in Debenham.

In the case of the named development, 'Market Pyghtle', comments from the Parish Council and individuals were not taken into account and four large houses which are out of all proportion to the size of the site involved have been built with minimally sized gardens. This is interesting when the word 'pyghtle' is an Anglo-Saxon word meaning a 'small plot of land'. So presumably, the developer realised the site consisted of a small area and yet submitted plans for comparatively large houses and was granted permission to build them. In relation to this, I understand there was a competition in the Primary School to provide a name for the site and residents from the village also contributed. Despite these suggestions, the developer appears to have had his way regarding the name of the site. Also, of course, one house is in Chancery Lane, another in Great Back Lane and two in The Butts, each could have been given a number in its respective road.

No suitable houses or apartments were built for first-time buyers on this plot. Not only that, a flint wall of several hundred years was knocked down with the statement that its foundations were not safe. This must have been obvious given that the developers had had to clear the site of contamination and thus inevitably made the wall unstable due to the necessary work carried out on the soil adjacent to it. Instead of this historic wall being replaced, a brick wall with some flint inlay and railings have been built which in no way represents the original wall. This not only does not respect historic constructions but indicates that developers can get away with what is not possible for a householder and is inappropriate in the circumstances. Also, in this case it enables the developer to sell the remaining flint. Thus the developer will make several thousand pounds due to the reduced skilled labour involved in the construction of the new wall and railings and the flint sales. Also, the fact that the gardens are extremely limited and there is a large paved area, there is no immediate drainage and therefore rainwater will tend to collect and create the possibility of flooding.

With regard to The Cherry Tree development, again the developer has not adhered to the planning permission. For instance, the cellar, an integral requirement for a pub, has been filled in and cemented over and yet nothing has been done by the Council about this.

There have been strong comments about the proposed development off Little London Road and one wonders how much notice will be taken of both the Parish Council's recommendations and the comments from residents who know the area well as they live near the site. It would be interesting to know how many staff in the Planning Office of Mid Suffolk Council have been to the site and researched the area carefully over several days and at different seasons of the year. Also, it was extraordinary to see that some of the accompanying reports to the planning documents contradicted one another. On 12 October there was an accident outside the school between the school bus and a Land Rover and a child had to be taken to hospital. This demonstrates the traffic problems in this area which many residents have commented upon.


1. What do you think the vision should be?
The Council does not state what their vision is for Mid Suffolk, only mentioning that the Joint Local Plan needs 'to set a spatial vision'. A 'spatial vision' is very restrictive as there are major historical and ecological components which should be included in the vision. The identified objectives must be based upon the vision. Therefore, it is paramount for the Council to state their vision if the objectives and the rest of the document are to relate to it.

Mid Suffolk is a rural area with many of the towns and villages containing significant historical buildings and areas of natural habitat. It is important that these aspects of the county are maintained and cherished as an asset to the region and be seen as a backdrop to the Joint Local Plan. The vision for the area should be to enhance the current settlements, to regenerate some regions, eg Stowmarket town centre, within Mid Suffolk, and to create more housing in the style of the region, avoiding despoiling current towns, villages and hamlets and encourage innovative businesses with the necessary incentives to provide local employment and to enrich the countryside with its many areas of environmental biodiversity. At the same time, pioneering ideas should be developed to provide the necessary amenities and infrastructure within the region; this is being recognised as an important element for the wellbeing and health of the inhabitants.

It is noted that in Mid Suffolk, the main towns are designated as Eye, Needham Market and Stowmarket. However, elsewhere in the document, Appendix 1, under the Town Centre Maps, Debenham is classed as the main settlement in a 'Functional Cluster', with 19 settlements classified within this cluster. This is many more than other settlements, eg Framlingham which is a town. In no way can Debenham be classified as a town; it has few shops and increasingly inadequate amenities and infrastructure given the developments in recent years.

2. Do you agree with the identified objectives? Please explain reasoning.
I do agree with the objectives that have been identified. However, I do not feel that these objectives have been met until now so I hope they will be in the future. To fulfil these objectives, considerable research needs to be carried out to identify ways of fulfilling them within the culture of the towns, village and hamlets. Appropriate people need to be consulted - not large consultancy firms whose staff are often not skilled in the type of research which is required in these circumstances. With regard to the environment, far more care and action needs to be taken. In some areas of the country, Councils and developers are working with the Wild Life Trusts to provide a holistic way of building to avoid damage to protected sites and working with the natural surroundings to create gains for nature and better health and well-being for residents. (See www.wildlifetrusts.org/housing)

Recent research at the universities of Illinois and Glasgow has confirmed that natural scenery can be a useful tool to help reduce psychological stress and that spending time in natural environments have positive psychological benefits by stimulating relevant hormones. Particularly being around trees and grass lowers brain stress levels. This should be taken into account when planning developments. The way in which the 'Market Pyghtle' in Debenham has been developed does not allow for trees to be planted and there will be minimal space for grass to be laid down thus providing a sterile environment for the inhabitants and those living in the vicinity.

3. Are there other objectives which should be added?
Yes. Education; nursery, primary, secondary and tertiary. Currently, in Debenham there are parents who cannot obtain a place for their children in the senior classes of the primary school and have to travel elsewhere for their child's education.

Also, within the environment objective, the aspect of flooding needs to be addressed continually. This is especially the case as since the last big flood in the village in 1993, more houses have been allowed to be built in low lying areas of the village and there are 248 properties officially assessed as at risk of "fluvial floods". I know that the Debenham Holistic Flood Alleviation Project has been set up with collaboration between the Environment Agency, East Suffolk Drainage Board, Essex and Suffolk Rivers Trust and SCC. However, this is dependent upon more Deben Valley landowners becoming involved in the project (Debenham Parish Magazine, November 2017, page 5).

In Debenham due to the previous severe flooding and the pressure of new building sites, particularly in flood plain areas, eg at the lower end of Little London Road, flood risk needs to be researched further before further building takes place. I do not agree with the statement: '...and reduce future flood risk where possible.' Any development must ensure that flood risk is reduced. Professor David Balmforth of Imperial College and President of the Institute of Civil Engineers has spoken about sustainable drainage systems. Indicating that paved over areas prevent drainage and therefore water collects with the result of the greater possibility of flooding. This is likely to be the case in Caterham, Surrey, where flooding has taken place in the lower slopes of hills where new developments have been built higher up the hill. Professor Balmforth stresses the need for full investigations to be undertaken and old sewers and surface water drainage systems to be replaced.

Paul Cobbing, Chief Executive of the National Flood Forum, has also reiterated the importance of thorough research in the planning of developments to avoid flooding in areas that have been free from flooding for years due to measures that have been implemented in the past.

While water quality is mentioned, there is no indication concerning increased requirements for sewage, electricity, telephone and broadband connections. These are vitally important aspects of development which should be considered at the planning stage.

In conjunction with this, all brown field sites need to be investigated and used for development and long-term empty dwellings need to be utilised.

4. What should be the priority across the district area? Please state which district.
Debenham core village: As I live in Debenham, I can best contribute an opinion about this village. Due to past building projects and current building developments the population of the village has grown significantly resulting in the village being in dire need of improved amenities and better infrastructure. Maps of the village depict the enormous development on all sides of the historic, core village which demonstrates an imbalance of development.
* the schools are oversubscribed;
* the doctors surgery is in need of expansion due to the number of patients. Regularly, one has to wait several weeks for an appointment;
* traffic needs to be controlled within the village: huge lorries thunder through the village, often at speed; there are insufficient parking facilities near the Coop and, during term time, there is parking near the schools which daily causes significant problems on weekdays.

Also, the issue of potential flooding with further building projects needs to be addressed by carrying out thorough research. See comments under No.3.

5. What is most important for your town or village? (page 13)
For the core village of Debenham the most important aspect for the future is the development of an adequate infrastructure and facilities for the current population and those who come into the village from neighbouring villages and hamlets where there are no facilities at all. This needs to be addressed if further developments are to take place. The amenities and infrastructure for the area needs to be planned carefully to allow for a positive quality of life for the current residents and should new residents come to the village in the future.

There needs to be continual upkeep by the Council and Highways Agency in their various spheres of responsibility to maintain the village adequately.

5a. Do you agree or disagree with the identified key issues for compliance with the Duty to Co-operate for the Babergh and Mid Suffolk Joint Local Plan? Please explain why. (page 16)
I agree with the strategic polices listed (1-5) on page 14. However, it is the responsibility of the Council to ensure that there is full compliance with the Duty to Co-operate.

6. Are there any other key planning issues which need to be considered in accordance with the Duty-to-Cooperate? Please explain why.
Different areas of Mid Suffolk need to be analysed so that aspects of the Duty to Co-operate that have not been fulfilled are dealt with fully before new projects are undertaken.

7. Do you agree with the proposed approach set out under Option HR1? If not, please explain why and what alternatives you propose.
I do not agree with the Option HR1. The allocation of sites should be carried out with due research. Reserve sites could create problems if the general infrastructure is not addressed prior to any further development. Where houses are currently being built in some towns and core villages considerable problems are arising due to lack of facilities and infrastructure thus ruining the places, eg Alderton, Gloucestershire, Framlingham, Suffolk/.

8. When allocating sites what scale of contingency should be applied? Please explain why?
This would be dependent upon the area in question. In some environments there will be greater capacity than others. For the core villages such as Debenham there are a very limited number of sites for development given the historic core village, the comparatively new developments and the current infrastructure.
To cope with the problem of contingency and having an adequate number of sites, perhaps a new garden city should be considered. This garden city could be built near the centres of work and be planned with innovation and flair. Not only could the building of a new town address the number of houses required to be built but would also preserve the current towns, villages and hamlets which are steadily being spoilt. The Ebbsfleet garden city in Kent is a current example and plans are depicted on the website www.kentonline.org.uk. Any such development would need to located near to rail and road links.
9. Are there any specific measures that could be included within the Joint Local Plan that would assist with delivery?
Yes, as mentioned in No.8, the building of a new garden city. Perhaps the Babergh and Mid Suffolk Councils could collaborate to explore such a suggestion.

10. What factors or priorities should be set as triggers for reserve sites to come forward?
Brownfield sites should be explored for reserve sites and possibly run-down industrial sites and disused airfields. In some cases, perhaps airfields with limited current use could be amalgamated and the land used for building a village or town from scratch. This would allow the amenities and infrastructure to be incorporated at the start of the development.


With regard to the building of more houses and generating employment opportunities it might be worth considering more inventive ideas. During the programme on Channel 4: Is Britain Full? Michael Buerk investigated the differing population percentages in the south, particularly London, and in the north, particularly Liverpool. London is becoming over-populated while Liverpool has whole streets with houses boarded up and a decreasing population. The northern towns need radical redevelopment with employment opportunities being created. In conjunction with this, good transport links between northern towns and southern towns, especially London, need to be created. Perhaps councils from the north and the south need to co-operate and explore ways of making positive conditions out of this discrepancy in the population distribution. Suitable 'twinning' between councils could be investigated which could benefit both areas of the country. Collaboration between councils and genuine research institutions as in universities rather than consultancy firms could well help to propose some inventive ideas to help solve the problems.

11. Do you agree with the proposed criteria approach to rank settlements in the hierarchy? If not, please explain a suggested amendment or alternative.
Generally yes.

12. Do you agree with the proposed joint settlement hierarchy? If no, please provide further details as to how the hierarchy should be amended.
I agree that Debenham should be classified as a core village. I am not in a position to comment of many of the other designated core villages.

13. Which option(s) for housing spatial distribution do you think is the best? Please explain your answer.
The percentages given in each area appear to be arbitrary. While one can classify the variously sized settlements, this is just a manmade classification. Urban areas, market towns, core villages, hinterland villages and hamlets all vary in their composition and this needs to be taken into account with careful consideration so as not to destroy the individuality of the settlements.

I think that a new settlement area would be the best option, ie a garden city development. This avoids over-development in core villages, hinterland villages and hamlets. One is seeing the destruction of the character of towns such as Framlingham (not mentioned in the lists on page 25) with the overdevelopment of building projects where houses are being built extremely close together with practically no gardens and a considerable area of road/pavement which does not allow for infiltration into the soil. Also, there appears to be no development of amenities and infrastructure. The current build indicates the need for recreation areas etc.

14. Are there other realistic broad distribution options which should be considered?
Yes. There needs to be greater flexibility as to where new developments are to be located, taking into account the region and established settlements. Settlements listed as Settlement Categories are not all similar so percentages for district growth should be explored for each settlement.

15. If a new settlement was to be planned in the area, where should it be located? Please explain your answer.
If a new settlement is to be planned there needs to be considerable research carried out to ensure that it is placed in a viable area, near to transport facilities and job opportunities. If there is a comparatively large brownfield site, this could be a starting point. Careful planning would need to take place to ensure that the town had good facilities and transport links covering the needs of the intended population with good transport links. If there was a brownfield site, eg disused airfield, run down industrial area, this could be utilised. A good example is the current large-scale development in the City of York. Ideas could be gleaned from the www.kentonline.org.uk website concerning the Ebbsfleet Garden City.

16. Should the Joint Local Plan include a requirement for new dwellings to meet the Nationally Described Space Standards?
These standards should be enforced. In the Space Standards for Homes RIBA Report a variety of problems are given, eg Local Authorities will struggle to set the new space standard as it is over complicated, costs too much and will take too long. They have suggested that the government should create a fair housing offer by embedding the Nationally Described Space Standard in building regulations. However, it is important that new dwellings have reasonably sized rooms rather than the occupants being cramped which is not compatible with stress-free living.

17. Do you have any views on the proposed approach towards self-build and custom build dwellings?
It is not clear what the proposed approach is towards self-build and custom built dwellings. Where permission is granted for these dwellings the plans need to be rigorously explored and then the development needs to be monitored carefully so that the plans are adhered to and that the buildings are of a design that is appropriate in the designated area.

18. What should the Councils' approach to Starter Homes be?
The Council should be promoting the building of Starter Homes for first-time buyers under the age of 40. It seems extraordinary that when the Parish Council proposed the building of starter homes on the now named site 'Market Pyghtle' in Debenham, the developer was given the go ahead to build 3 and 4 bedroom houses with practically no gardens. It is important that Starter Homes are built and an arbitrary percentage figure should not be used across the board. There should be a mechanism whereby first-time buyers from each settlement could put their names forward so that at least a realistic number of homes could be considered. There are some young people who would ideally like to have a home with a reasonable garden in a hamlet whereas others might prefer to be in a larger settlement with amenities and good public transport links.

19. Should the Councils be prioritising the provision of any particular types of homes?
Yes, both starter homes and homes for the elderly who are having to move to more appropriate housing should be prioritised. The latter should be custom-built.

20. Are there any other types of housing that should be planned for/required?
Yes, there should be homes similar to those built in Chelmsford city centre for the homeless as interim homes. Suitable sites could be chosen in towns and they would help to prevent vulnerable people having to sleep on the streets. This would enable organisations that help the homeless to be in a position to help and monitor the occupants. In a country such as ours, it is scandalous that we have people sleeping on the streets particularly when we have a section of society who are vulgarly rich, many of whom have several luxurious properties both in the UK and abroad.

21. How can the Councils promote/facilitate development of homes for private rent?
Contracts with the developers should stipulate that some homes for rent must be built. These should be a 'gift' to the Council. There should be strict rules to which developers have to adhere if they are given contracts to build houses. Currently, they appear to be getting away with far too much and the Council needs to have control which implies checking on the progress of developments and ordering the developers to rectify situations that go against the planning agreement.

22. In relation to affordable housing, do you consider the requirement should be set at a percentage other than the current 35%. If so, please provide reasons.
It depends upon how 35% is calculated. Presumably, there are different needs in different parts of the Mid Suffolk area. Each area requires research and, as far as possible, the percentage should depend upon need.

23. To what extent should affordable housing be (or not be) prioritised over provision of other infrastructure where viability is an issue?
In every case, all aspects of infrastructure where viability is an issue should be dealt with prior to building new houses. Currently, the situation is untenable where houses are being built with no development of infrastructure. However, affordable housing should take precedence over other housing.

24. In relation to affordable housing, should there be any preference for housing to accommodate key workers?
It is important that key workers are given some preference. However, if there is an influx of key workers into an area it could mean that some individuals/families are continually being moved down the waiting list. Therefore, a reasonable arrangement should be made dependent upon the circumstances. If key workers such as nurses are considered then affordable housing for them should be within a reasonable distance of good transport and/or near the place of work.

25. If Option RE2 is supported, what maximum percentage of market housing should be acceptable?
It is not clear what is meant by 'to bring the site forward'? However, so much is dependent upon the circumstances and, again a maximum percentage of market housing would not be appropriate. In general, rural areas should be maintained but, if this refers to rural towns and villages, then the individual settlement needs to be researched for appropriate building projects with a significant number of houses being built for first-time buyers who are being squeezed out of the market.

26. Which option for the policy approach to rural growth do you think is most appropriate?
RG1 as this should mean that each case in judged individually.

27. Are there any other approaches to distributing development in rural areas that we should consider?
Yes. Open meetings together with Parish Councils should be held in the settlement concerned to obtain the views of the inhabitants and the results of these meetings should be presented to the Councillors who come to the settlement in question. Even if Council members visit settlements on several occasions they will never be in a position to imbibe the current situation as seen by the inhabitants.

28. Do you support the approach proposed for hamlets? If not please explain.
As it is stated that 'National policy sets out that development should be distributed in a way which reduces the need to travel, supports the retention of existing services and helps to sustain rural areas' it would seem that neither HG1 or HG2 are sensible. However, if suitable sites are available to be purchased by individual families, building consent could be considered.

29. What should the Councils' approach to provision of negotiated stopping places be?
If 'stopping places' refers to families/groups with caravans etc, then the existing caravan sites should be adequate. Presumably, families/groups plan their journeys with these sites in mind.

30. Please submit details of any sites, or extensions to existing sites, which you consider are suitable for allocation as Gypsy and Traveller sites or travelling Showpeople sites.
I do not have the knowledge to answer this question.

31. Should the Joint Local Plan include a policy which identifies areas where moorings would be acceptable in principal?
Yes.
32. If so, are there any specific locations where additional moorings could be located?
I do not know enough about the appropriate areas to comment.

33. Should we continue to identify existing employment areas and protect land and premises in these areas from redevelopment/conversion to other uses unless marketing evidence demonstrates there is no demand for employment use?
Yes.

34. If we continue to protect existing employment areas, which areas should be identified?
I do not know enough about the existing employment areas throughout Mid Suffolk, except that in Debenham the current area, Meadow Works Business Park, should be protected.

35. Are there any existing employment areas that could be reallocated to other use?
I do not know of any.
.
36. Should we identify areas where non-B class uses, such as car showrooms, tyre and exhaust centres and building material stores, can
be located?
Yes. Careful placement of these kinds of employment areas is important as they can totally destroy the historical and aesthetic aspects of a settlement. They are not the kind of employment areas suitable to be located in villages and hamlets.

37. Should there be a policy that allows a wider range of uses than just B class on all employment sites or selected employment sites?
Careful consideration should be given in every case. Local skills and appropriate sites should be taken into account without exception together with the views of the population adjacent to the site.

38. Should we allocate more than enough land to meet the forecast needs to enable more choice in the market and give flexibility to changing circumstances?
Only where there is significant development and local manpower. Land should not be allocated in inappropriate places such as near/in villages and hamlets which do not have this kind of facility already. It is inappropriate to continually add buildings to a settlement without restrictions. The choice of sites should be made by the Council and not be developers.

39. Should we make specific employment provisions for small and medium sized enterprises? If so, how and where.
Yes, especially high-tech. However, this employment provision should be carefully researched and the businesses placed in appropriate places, eg near centres of research and other high-tech businesses so that meaningful collaboration can take place.

40. If we expand, or allocate additional employment land where should these be?
Near existing centres of research, engineering etc. This would allow interaction between research and development. Examples of this type of development are taking place in Cambridge and Norwich.

41. What approach should we take to supporting new business formation across the Districts?
Realistic consideration of applications for new business formation should take place, with possible financial incentives being given, eg lower rent. It is important that the population have adequate local employment that is relevant to the area in which they live and is not duplicated.

42. Do you consider that any of the sites put forward as part of the Call for Sites should be allocated for retail or commercial leisure use? Please state why.
It is extraordinary that Debenham, which is designated as a core village, is grouped with Eye, which is designated as: urban areas and Market Town. While Debenham can be seen as a Core Village/Functional Cluster, and seen to have a District Centre role, in no way can it be classed with the other centres mentioned in this section. Its dependent villages and hamlets have been listed as 19 in number, whereas towns such as Framlingham have 3 in its cluster. The retail provision in Debenham is limited when compared with somewhere like Framlingham and Eye and there is nowhere in the heart of the village that further retail development can take place. It would seem sensible to increase the retail opportunities in places like Stowmarket where the town centre is rundown, inadequate and depressing. Retailers with smaller floorspace should be encouraged, perhaps financially, together with what is being classed as commercial leisure facilities. Out of town retail should be discouraged as this tends to deplete the viability of the town centres and encourages the use of private transport. In all cases there needs to be an increase in public transport.

43. Are there any other sites that should be considered for retail or commercial leisure use?
I do not know the full area of Mid Suffolk to suggest sites. If the town centres such as Stowmarket were reinvigorated this would make a difference to the situation. However, building developments such as the current ones in Framlingham do not solve these problems but destroy the ethos of the town and put to great a strain on the infrastructure. Brownfield sites should be utilised and the possibility of a new garden city should be considered as this could be custom built with amenities and infrastructure developed to suit the number of dwellings and house a significant number of people. It would also cut down the imposition of developments in towns and villages that have reached capacity.

44. If you consider allocations for retail development should come forward as mixed use, please provide details.
I do. As mentioned in Para 3 in the section headed 'Retail capacity and allocations'.

45. Do you agree with the proposed Town Centre boundaries, Primary Shopping Areas, Primary Shopping Frontages and Secondary Shopping Frontages? If not, please explain why.
Debenham listed in the Settlement Hierarchy it is classed as a core village. Therefore, it is not clear why it is included here. On the map there is a darker pink area depicted but no indication as to what this is. For Eye, Hadleigh, Needham Market and Sudbury I do not have the necessary information to answer the question.

Map 4: Debenham has the largest number of cluster villages. As Debenham itself is a core village this cannot be right or sensible. Given that the retail outlets of Eye, Framlingham and Stowmarket are greater in number, the boundary of Eye should extend further south, the boundary of Framlingham further west and the boundary of Stowmarket further east.

46. Do you agree with the approach to not define Primary Shopping Area boundaries within settlements other than the three main towns? If not, please explain why.
Yes.

47. Do you agree with the approach to maintain and increase retail provision within the District Centres? If not, please explain why.
Retail provision should be maintained. However, in Debenham there is no area in the centre that could offer increased retail provision. The current developments have already far outstripped the possible retail provision in the heart of the village and the capacity of other amenities.

48. Do you agree with the proposed thresholds relating to the mix of uses within Primary Shopping Frontage? If not, please explain why.
Thresholds have been given but there is no reasoning behind the suggested percentages. Explanation is required for an answer to this question.

49. Do you agree with the proposal to require an impact assessment for all edge of centre and out of centre retail proposals that are 400sqm gross floorspace or more? If not, please explain why.
Yes. It is apparent that where there are retail developments outside the town centres it has taken the heart out of the town. Very careful research and subsequent consideration needs to take place so as not to destroy vibrant and thriving communities.

50. The Councils propose to protect A1-A5 uses in Core Villages and Hinterland Villages, and in local centres within towns. Do you consider this to be the correct approach?
Yes.

51. Do you have views on the Option BIO1 and/or BIO2?
I prefer Option BIO2 as it includes the 'enhancement' of the areas. In no way should these areas be encroached upon and if development takes place nearby then this should not impinge on the habitat and biodiversity of the designated area.

52. How should the local plan consider the impact of renewable technologies? What types of effects should be assessed within the policy criteria?
Research institutions including universities involved in work on renewable energy and sustainable construction should be consulted so that the most appropriate schemes are introduced. These experts would be able to give full details of the types of effects that would occur. Also, the population in the vicinity of the proposed introduction of the new technologies should be consulted. It is important not to involve organisations with a financial interest at the stage of research as they often do not have the expertise required and have to buy in assistance. Sub-contracting always involves increased financial costs.

53. Do you support the Council's initial preference to include water efficiency measures in new build? If no, please explain why?
Yes.
54. Are there any other additional environmental standards Babergh and Mid Suffolk should be requiring? If so, please provide details and reasons why.
While water efficiency is mentioned, there is no indication concerning sewage disposal capacity and surface water drainage. Air pollution needs to be addressed in hinterland villages as huge vehicles are tending to use the country roads which are totally unsuitable. They need to be prohibited. If deliveries need to be made rather smaller vehicles should to be used.

55. Are there any other approaches that the Joint Local Plan could take to protect the landscape?
Yes. Have stricter regulations for the developers and ensure that inspections take place at regular intervals during the development of a given site. If the developers are not complying with regulations and the permissions given, they should be made to comply. A holistic way of building should be adopted to avoid damaging protected and historical sites. Working with the surroundings to create gains for better health and well-being for resident and improvements for wildlife should be adopted. See www.wildlifetrusts.org/housing. The developers should be required to rectify all surrounding areas before they leave the area.

With regard to landscape surrounding settlements, conservation is important so that the biodiversity is maintained and depletion of species is curtailed..

56. Should additional protection be given to areas which form part of a landscape project area but which aren't designated?
Yes. This is most important in order to maintain the character of the landscape and historic towns and villages. Environmental habitats need to be protected so that the biodiversity of the region does not become depleted.

The diverse landscape of the area needs to be maintained and cherished. The non-designated areas which have a rich environment need to be protected. Possibly a reappraisal of non-designated areas needs to be carried out.

57. How can the Joint Local Plan make the most of the heritage assets?
The Joint Local Plan can do nothing by just being printed unless those responsible for it and in positions of authority within the Council are strict about ensuring that the Plan is adhered to with firm control. Heritage assets need to be preserved and protected. Those responsible should be encouraged to go for Lottery funding and other grants in order to restore buildings where necessary. If developers are making significant amounts of money in nearby areas, they should contribute financially or in kind to the upkeep of the heritage sites within the area. Many heritage sites bring income from tourism. Collaboration with the variety of trusts such as Suffolk Wildlife Trust, the RSPB etc could provide valuable information.

58. What level of protection should be given to identified non-designated assets? Are there any specific situations in which the balance should favour or not favour protection of identified non-designated assets?
A high level of protection should be given to maintain the uniqueness of Suffolk. HA1 is acceptable but it needs the vigilance of the appropriate departments of Mid Suffolk and research to be carried out on these assets. Collaboration with scientific organisations could help with this situation.

59. Should a more flexible approach toward climate change objectives be adopted where this would assist in protecting a heritage asset?
Yes.

60. Is there any aspect of design that priority should be given to?
Developments should be in keeping with the character of the town/village/hamlet. The Council should apply stringent rules on developers and insist that they should adhere to these regulations. The information in the six bullet points given on page 64 should all be insisted upon. However, in totally new areas or in a new settlement, innovative designs could be developed.

61. Is there any aspect of design that should be introduced to the Councils' policies?
Some new sustainable and economical designs could be explored for introduction to the Councils' policies. However, these new designs should be implemented in carefully chosen sites. As mentioned previously the www.wildlifetrusts.org/housing website gives some ideas and contact and collaboration with the organisation might be advantageous.

62. Is there an area of design related to past development that you consider needs to be addressed in future development?
Yes. The size and design of the buildings are important in historic areas of settlements. The new houses being built on the 'Market Pyghtle' site are too large for the site and they have miniscule gardens which are inappropriate for a village. This arrangement is more for a town situation. Other houses built in the older parts of the village in recent years have been out of keeping with the general design. Thus the ambience of the village is steadily being destroyed by inappropriately designed new housing.

Areas of design related to past development such as the quintessential Suffolk houses should be incorporated in a sensitive and sensible manner.

63. Which option do you consider most appropriate? Please explain why.
INF1. Debenham has had significant development over the years, eg The Meadows, Henniker Road developments, but no attention has been given to amenities and infrastructure. This has resulted in an almost untenable situation with regard to medical facilities, educational provision, transport and parking facilities. Currently, far too much heavy traffic is being allowed to pass through the village and many vehicles at speeds far in excess of the limit.

64. What do you consider the key infrastructure issues in your community?
The key infrastructure issues in Debenham are the need for:
* adequate medical facilities - larger surgery and more staff for the population and nearby villages and hamlets without this facility
* adequate school places in both the Primary older children's classes and the High School
* adequate parking facilities
* adequate maintenance of the streams throughout the village
* adequate research and development with regard to possible flooding
* adequate maintenance of the highways and byroads
* control of huge vehicles passing through the village. They need to be diverted via the main roads and above a certain size should not be allowed on the minor roads. Should the contents of these vehicles need to be delivered, then smaller vehicles need to be employed
* control of the speed limit through the village. Given the straight nature of the High Street and Aspall Road, they often become a race track

65. What infrastructure issues do you consider to be a priority for the future?
This question has mainly been answered in No.64 above. Most of the key infrastructures issues have been caused by over-development over recent decades when it appears that no or little thought has been given to amenities and infrastructure.
* Health centre/GP surgery which is currently inadequate.
* Education. Local people can no longer find places for their children in the senior classes of the Primary School in Debenham. Debenham children should have priority.
* Transport. Currently, the traffic through the village is dreadful. Vehicles are breaking the speed limit and heavy goods vehicles are coming through the village when they should be diverted. Once outside the village, they cannot remain within the central road markings and therefore break up the verges. Diversions should be in place.
* Parking. Totally inadequate.
* Public transport. Inadequate with regard to frequency and destinations.
* Flood risk management. This needs to be addressed particularly with the new developments. Currently, the Highways Agency carries out an inadequate job with regard to clearing the streams around Debenham.

66. What infrastructure do you think would be needed to support the growth scenarios?
As for Nos.64 and 65. Before any further growth to Debenham village is contemplated these issues should be addressed.

67. What comments do you have on the proposed strategic approach to infrastructure delivery?
Currently, the amenities and infrastructure are inadequate given the recent developments within Debenham core village. Therefore, this needs to be addressed prior to any further housing development.

68. Should a separate policy be developed to manage provision of education and healthcare?
Yes.

69. Should the strategy of the Plan be focussed on addressing deprivation?
The Plan should address deprivation but should not be totally focussed upon it as there are many other issues that need to be addressed.

70. Are there any specific approaches that should be applied to address deprivation?
The Council should work with local organisations that are addressing the needs of the deprived and develop meaningful ways of coping with this problem. They should find out how this problem is being addressed in other areas of the country and see if lessons can be learned so that meaningful policies can be introduced.

71. Are there any other circumstances and/or provisions under which open space, sports facilities or community facilities should be required and/or protected?
In Debenham the Leisure Centre together with the outdoor sports facilities and playground areas should be protected and the local green spaces such as Hoggs Kiss Wood, Hoppit Wood and the lakes and the woodland area next to Coopersfield and the cemetery and opposite the playground area should be protected.

72. Through the Plan should any other areas of Local Green Space be identified and protected?
Where none are provided, then they should be found and protected so that all populations have access to these facilities. Those members of the population who can least afford them are possibly those who require them most.

73. Are there any specific facilities that should be included in the definition of community facilities?
These have already been mentioned.

74. Do you consider the approach to identifying functional clusters appropriate for Babergh and Mid Suffolk? If not, please explain what would be your preferred approach?
Identifying functional clusters could be appropriate. However, not in the way they have been identified. In the explanation under para. 4 there is no mention of Debenham and then under 'Settlement Boundaries' it is given the status of a 'core village' with the largest functional cluster. This does not seem reasonable or sensible given the amenities and facilities when compared with Stowmarket for instance. This needs to be looked at again.
Debenham is classified as a 'core village'. However, on the Map: 'Functional Clusters in Mid Suffolk', Debenham is depicted as the largest functional cluster. This cannot be justified given the facts and is totally unacceptable. For instance, Framlingham has 3 villages within its cluster, Stowmarket has 16, Diss 4 and Eye 13, all with far more amenities than Debenham which is given 18 neighbouring villages and hamlets which must be incorrect. (Debenham is also listed as a village within the cluster which presumably is a mistake.)
The boundaries should be redrawn to illustrate a more meaningful depiction.
* Eye to the south
* Stowmarket to the east
* Framlingham to the west

75. Do you consider the proposed new settlement boundaries to be appropriate? Please explain your answer.
With regard to Debenham: the depiction on the map of the proposed new settlement boundary is not clear and cannot be clearly distinguished from the existing settlement boundary. So I cannot comment.

With regard to other towns, villages and hamlets I am not in a position to comment as I do not know the settlements sufficiently well.

76. Are there any other settlements that should be given new settlement boundaries? Please explain your answer.
I am not in a position to comment.

77. Is the threshold (10 well related dwellings) for identifying settlement boundaries appropriate?
This seems reasonable.

78. Do you consider the sites identified to be appropriate for allocation or inclusion within the settlement boundary? Please explain why and quote the settlement and site reference number ieSS0001).
I can only comment on Debenham. I do not consider the sites identified to be appropriate. No indication is given as to the number of dwellings to be built nor is there any suggestion of the Council's intention for the development of associated amenities and infrastructure.

SS0902: Totally unsuitable as this area is within the flood plain and flooding has taken place in this area of Low Road in the past as a result of other developments in the area, eg The Meadows. With flooding being on the increase due to climate change it would seem most inappropriate to continue building in areas such as this.

SS0642: Totally unsuitable. Again building in this area would contribute to flooding around Low Road. With the huge development of houses between Gracechurch Street and Low Road, the map demonstrates the imbalance of development with respect to the core village. It does not seem that there is an appropriate nearby area to create a 'slow and flow' feature.

SS0267: Far too large an area of development. Again this will put a strain on all the systems related to house building and possibly lead to increased potential for flooding in the area of The Butts and further downstream.

The maps are generally not that easy to follow as none of the roads are named. However, looking at the map of Debenham it can be seen that the developments are massively larger than the original core village and although roads have been built within the developments, no amenities or infrastructure has been built to accommodate the large number of houses that have been built. Thus, it makes these proposals untenable for the village life of the inhabitants.

79. Are there any other sites/areas which would be appropriate for allocation? If yes, please provide further information and complete a site submission form.
Brownfield sites need to be explored, eg run down industrial sites, disused airfields etc. A more inventive approach needs to be sought to avoid spoiling the culture and uniqueness of town and villages within Mid Suffolk.

(Further letter sent 7 November 2017 in attachments)

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9697

Received: 10/11/2017

Respondent: Mr Frank Lawrenson

Representation:

The huge consensus in our village of Great Waldingfield is that we all moved here for the ruralness and tranquility, choosing to forfeit easy access to town facilities for the health and wellbeing resulting from living in close proximity to the countryside. We recognise the need for development and believe that large scale housing developments have no place in a rural village - a number of smaller developments, with rural rather than urban density of housing, around the edge of the village would best serve to retain our landscape's character.

Full text:


Q4 What should be the priority across the district?
Retaining the landscape character, the spaces between the settlements, keeping the villages as rural rather than urban in order to protect our biggest economy - tourism. This is the best way to keep our area sustainable - that is to ensure that it continues as a thriving district for present and future generations.


Q5 What is most important for your town or village?
The huge consensus in our village of Great Waldingfield is that we all moved here for the ruralness and tranquility, choosing to forfeit easy access to town facilities for the health and wellbeing resulting from living in close proximity to the countryside. We recognise the need for development and believe that large scale housing developments have no place in a rural village - a number of smaller developments, with rural rather than urban density of housing, around the edge of the village would best serve to retain our landscape's character.

Q 11. Do you agree with the proposed criteria approach to rank settlements in the hierarchy? If not, please explain a suggested amendment or alternative.
Whilst agreeing in broad terms with the criteria approach it is important to ensure proportional development and to that end we believe that village size/population should play a significant role in the calculation. Additionally penalizing villages, via the points system, for being located close to market towns risks overdevelopment and destroying the very character of Suffolk that we seek to preserve. Through all this we must remember the reason we chose to live in this beautiful part of the world and ensure we improve and preserve it for future generations.

Q 12. Do you agree with the proposed joint settlement hierarchy? If no, please provide further details as to how the hierarchy should be amended.
We do not agree with the joint settlement hierarchy in the case of Great Waldingfield. When Chilton Wood is complete Great Waldingfield will be within 1km of the new development. To add further significant development to a village so close to 1100 new homes and associated industrial units must by any measure count as over development. We therefore believe Great Waldingfield should be considered as an exception and be classified as a hinterland village. Any development should be proportionate to the size of the current village as a fixed percentage.

Q 26. Which option for the policy approach to rural growth do you think is most appropriate?
Whichever option is chosen there must be clear guidelines set out similar to the Joint Landscape Plan and CS11 that protect rural sites from over-development. Loose wording ("without undue harm") must be avoided as these leave too much room for interpretation.

Q 27. Are there any other approaches to distributing development in rural areas that we should consider?
Local landscapes must be protected. Conservation areas, sites of Outstanding Natural Beauty and of Special Scientific Interest must be protected with clear guidelines. Development needs to go where there is appropriate infrastructure. Sustainability must refer to the natural environment not merely to housing. Large housing estates are inappropriate for rural villages whether Core or Hinterland. Smaller developments should be spread evenly across all villages, restricted to a small percentage of the existing number of dwellings.


Q 28. Do you support the approach proposed for hamlets? If not please explain?
Some growth can be allowed in hamlets if it is proportionate, of a suitable density, design and if it enhances the hamlet. Phrases such as development that does not "cause undue harm" seem to water down current guidelines where new development should enhance the area.

Q 55. Are there any other approaches that the Joint Local Plan could take to protect the landscape?
The Heritage Settlement and Landscape Sensitivity Assessment will be a key document relating to the protection of the landscape. Will there be consultation on this? If a document is produced without local consultation, local communities will be powerless to protect the local environment from outside development.

Q 64. What do you consider the key infrastructure issues in your community?
Traffic around the school site in Great Waldingfield is already at dangerous levels at the start, end of the school day and at lunchtime. The Primary School itself has capacity for only 30 more children so will not cater for large scale development and has no further room to extend. Cars from the Cromwell Field estate are parked on the main road and adjacent roads. Sewerage has been a problem on the new estate and much additional housing will exacerbate this. There is limited employment in Great Waldingfield so any major development will only add to traffic and pollution problems as people drive to local towns.

Settlement Hierarchy
We accept the need to review settlements. We welcome the use of services measured by a points system but there must be a clear correlation between services which meet current needs and those which provide opportunity for further development. If a school is near to capacity it should be awarded no/fewer points than a school with potential to grow. If a village can be designated as Core with only one shop then the system needs to be reviewed. Larger weighting needs to be given to those villages which have more services than to those where you must travel 5km to reach them. Where a village provides limited employment, it should not be designated Core as development will lead to traffic congestion and pollution. At a distance of over 1 km private transport will be used for its convenience whether for employment, shopping or entertainment etc. Consideration also needs to be given to existing cycle routes.

Spatial Distribution (BHD1): comment
The council has already stated that necessary infrastructure is of prime importance before any new development is considered, therefore it seems obvious that the bulk of housing should be sited in the Ipswich fringe area or with easy access to the A14 and A12 corridors. Indeed if 'Since 2001, approximately 60% of new housing growth has come forward in 'rural' areas across Babergh and Mid Suffolk' , it seems it is now the time to redress the balance towards the urban areas and protect the rural landscape which is so important for tourism, our largest business.

Housing: Rural Exception Sites (RE2) Agree
The existing balance in a village must be reviewed so that a good balance between affordable and market housing is retained within any new development. It is very important not to have large developments of only market housing or only affordable housing so that mixed communities are encouraged. Also developers must not be allowed to wriggle out of their affordable housing quota once planning permission has been given.

Rural Growth - comment
The important issue here is the proportion and density of the development allowed in any area whether Core or Hinterland village so that the distinctive character of that area is not only retained but enhanced. (To allow this will ensure that the area remains a popular place to live and work as well as encouraging tourism)The Government has already put in place strong guidelines regarding sustainable development and these must be clearly followed in the Local Plan (PPS1.5, 1.36, PPS3 46) In order for RG2 to fit in with these Planning Statements, there must be reference made to maintaining and enhancing the local character of the area especially in terms of ensuring that the spaces between settlements are retained and the density of the housing allowed is in keeping with the existing dwellings, thereby keeping a clear delineation between our urban, village and rural areas. Whether Core or Hinterland there should be only a percentage increase in village size, previous development in the village must be taken into account and the effect on the existing community carefully considered.
Density and proportion of new development key ingredients
Government guidelines relating to local character and distinctiveness to be followed
Clear differences between amount of development for urban, rural and village settings
Percentage increase so that no village receives disproportionate growth
Previous development must be taken into account

Hamlets (HG2) comment
Regarding infill in hamlets, the wording of HG2 which is of most concern is 'will not cause undue harm to the character and appearance of the cluster'. This gives very little protection to the area. There is no comment on the density of infill allowed - it is the spaces between dwellings which contributes to the rural feel of an area. Perhaps a clear ratio of house to plot depending on the local character could be defined. There must only ever be a small percentage increase in number of dwellings in an existing hamlet.

Landscape, Heritage and Design (L1)
It has to be best to have certain areas where building cannot take place - otherwise no area will be sacrosanct and it will be a matter of every area fighting to protect itself. The dangers of a criteria -based policy for all is its subjective nature.The greatest concern is again the wording in L2 ' all development would be expected to minimise impacts on the landscape and to enhance landscape character wherever possible, by reference to the Joint Babergh and Mid Suffolk Landscape Guidance.' This seems to open the way for development that does not enhance the landscape character as required by the NPPF.

Also needed is a clear set of rules for deciding what does and does not impact on the character of the settlement or landscape.

Heritage Assets (HG1) (p63)
It is obviously very important to protect non-designated assets.
NPPF 131. In determining planning applications, local planning authorities should take account of: the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality.



Infrastructure (IN2) (p65)
It is imperative in this rural area to recognise the importance of suitable infrastructure before any development takes place so a policy that takes into account the nature of the area in addition to the NPPF seems highly relevant.


Comments on sites
SS0247
The Great Waldingfield Conservation Area is highly important as a local amenity offering rural tranquility away from the busier main part of the village and as an historic heritage site extremely popular with tourists. It is therefore imperative that it is maintained as such for its value to the local economy and to the wellbeing of the local community.

NPPF 131. In determining planning applications, local planning authorities should take account of: the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality.

PPS1
The government's Objectives for the Planning System
1. Good planning ... makes a positive difference to people's lives and helps to deliver homes, jobs, and better opportunities for all, whilst protecting and enhancing the natural and historic environment, and conserving the countryside and open spaces that are vital resources for everyone.

Great Waldingfield Conservation Area sits in 'Ancient Rolling Farmland' and as such the
'settlement pattern mainly consists of dispersed farmsteads of mediaeval origin with the some larger hamlets and small villages that complement the rural land form and landscape."

Much of this has unfortunately already been lost and so the aims below from the JLG are of even greater importance:

* To retain, enhance and restore the distinctive landscape and settlement character. In particular safeguarding the influences of the area.
and the resulting objective:
* To maintain and enhance the landscape and the settlement pattern, ensuring the sense of separation between settlements is maintained.

Large scale development on this site (similar to the recent development in the village) would directly contravene the aims laid out in the Joint Landscape Guidance regarding the need to protect our Conservation Areas.

1.5.13 Much of the significance of many of the district's conservation areas lay in their
landscape setting, agricultural heritage and relationship with the countryside. (JLG)

If this site were developed it would seriously harm the view into and out of the Conservation Area which has already been affected by a large development of over 100 houses in the main part of the village. (close to SS0194)

3 Location/Siting of development (Visual effects) (JLG)
2.3.2 In considering development proposals, account should be taken of the potential
impact of a new building or development in both immediate and distant views,
particularly from roads, public footpaths and settlements.

This is especially relevant for this where development would destroy the iconic view up to the Church as appeared in the Times in 1935.

The JLG also states:
2.2.1 Some areas within Babergh appear to be remote, tranquil and removed from the
noise and activity of busy roads and places. These intangible qualities contribute to
the character and local distinctiveness of those areas.

Many local people and tourists come to this important historic Conservation Area because of its 'ruralness' and tranquility and any development that encroaches further into the space between the CA and the main part of the village will greatly affect its value both as a heritage site and local amenity.

However, it might be possible for infill or a small part of these sites to be used without further damage.

Summary:
* Great Waldingfield Conservation Area a vital heritage and tourist asset
* Importance of NPPF 131 and PPS1 in setting development guidelines
* Importance of Joint Landscape Guidance in enhancing and preserving distinctiveness, character of area, settlement pattern and separation of settlements
* Large scale settlement in or near Conservation Area would contravene JLG adversely affecting ruralness and tranquility
* Cromwell Field site was promised as last large scale development in the village.


SS0194
* Great Waldingfield Conservation Area a vital heritage and tourist asset
* Importance of NPPF 131 and PPS1 in setting development guidelines
* Importance of Joint Landscape Guidance in enhancing and preserving distinctiveness, character of area, settlement pattern and separation of settlements
* Large scale settlement in or near Conservation Area would contravene JLG adversely affecting ruralness and tranquility
* Sewerage system for village already near capacity
* Dangerous traffic congestion already evident on Folly Road
* Biodiversity impaired due to Cromwell Fields development and needs to be protected
* Cromwell Field site was promised as last large scale development in the village
* Some infill along Folly Road may be appropriate



SS0196
* Sewerage system for village already near capacity
* Dangerous traffic congestion already evident on Folly Road. Bantocks Road used as over-spill parking from Cromwell Fields site leading to congestion here and on Folly Road
* School small capacity and no room for further expansion.
* Cromwell Field site was promised as last large scale development in the village


SS0198
* Sewerage system for village already near capacity
* Bantocks Road unsuitable for further traffic due to large scale parking on road and number of bends leading to poor visibility ahead. Road used as cut-through from large Cromwell Fields development.
* School small capacity and no room for further expansion.
* Cromwell Field site was promised as last large scale development in the village

SS0200
* Sewerage system for village already near capacity
* School small capacity and no room for further expansion.
* Cromwell Field site was promised as last large scale development in the village
* Dangerous junction on to Valley Farm Road as traffic approaches from A134 and accelerates away from mini-roundabout on B1115


SS0948* and SS1029*
These sites are on the historic WW2 American airfield, a hugely important part of wartime history which should be so designated, developed as a heritage site and protected for future generations.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9980

Received: 08/11/2017

Respondent: Charlotte Lavington

Representation:

* Most important for Sproughton - transport infrastructure, school places, accessible healthcare services, enhance environmental assets are all missing already - the proposed development will exacerbate the problem and there is no clear financial plan to rectify this. You need to invest, not simply develop.

Full text:

SECTION 1 - STRATEGIC
Vision
* The development is not sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need.

Objectives
* The development should be balanced between homes and employment and be mindful of housing that local residents need and can afford.
* The already strained local road networks especially the "Ipswich Northern Route" and improvements to the A1071 at B1113 and Hadleigh Road junctions, and an access onto the A14 all need to be radically improved.
* The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
* How can you ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time? It is currently non-existent.
Priorities
* The development will lead to communities losing their identities by swamping and creeping coalescence (merging of communities).
* Location of growth should be spread more pragmatically across Babergh rather than fewer large sites - you're in danger of creating super developments and no-go areas such as Nacton.
* Most important for Sproughton - transport infrastructure, school places, accessible healthcare services, enhance environmental assets are all missing already - the proposed development will exacerbate the problem and there is no clear financial plan to rectify this. You need to invest, not simply develop.
Duty to Cooperate
* Ipswich say they have insufficient land to meet their projected housing numbers which means under the 'Duty to Cooperate' surrounding district councils must assist in finding land to accommodate Ipswich housing overspill.
* In this case around 4000 dwellings - how are Babergh proposing to help meet this requirement? Babergh should NOT be picking up all 4000.
SECTION 2 - DELIVERY

Housing Requirement, Settlement Hierarchy and Housing Distribution

Housing Requirement 2014 to 2036 - Option HR1 - 7,820 new houses based on population growth.
* I don't agree with this - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
* You do not take into account the relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability. How can you achieve this without legislation (which you do not have the power to do)?
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated
Contingency and Delivery
* Current 'stuck' sites with permissions and no building suggests need for contingency going forward - replace 'stuck' sites with others.
* Contingency sites to be replacement and not additional, original sites to be taken out of plan. Regular review of demand required checking the guiding principles of type, tenure, place and need (local) - should trigger need for reserve sites.

Hierarchy
* Our village status distorted by the scoring system, which in turn influences development location.
* Sproughton classed as CORE and also HINTERLAND village, it can't be both.
* I don't agree with approach taken - scoring based on distance to services and facilities; it should be based on travel time as accessibility overstated.
* No account is taken of capacity of a service in scoring eg Primary School/shops (Sproughton 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.
* We would support reconsideration of the scoring criteria adopted to include fairly balanced negative scores for the threat of Creeping Coalescence.

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

Other Distribution Options
* I would support an option for proportional distribution with the carefully planned 'organic growth' of existing communities.
* The expected Babergh population growth of 8000 by 2036 (9%) should be applied to each community - which would mean Sproughton will grow by 120 (50 or so new houses).
* This would 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 - all inward investment with the wealth and jobs 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
* Is the proposition to create a new or garden town, a separate and distinct community most probably in a new location with minimal local impact but the potential to improve/create improved county infrastructure/services?
* This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally situated where it least effects existing communities but with ready access to Road and Rail links - for example Needham Market or Stowmarket - both on the main line to London Liverpool Street.

Housing Types
* The national space standards should apply with provision for storage.
* The requirements for provision of accessible homes and bungalows on 10+ developments should be observed.
* Encourage Self Builds - they support the local economy and rural outlook so should be encouraged.
* The provisions for Affordable homes should also consider Starter homes which are more appropriate to support growth of local community.
* The 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.
* 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?
* 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 £180,000 (or a maximum of 3 times joint income if average salaries are at £27,600 with a £15,000 deposit - prudential lending limits) 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.
* 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 this is 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.

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, wider economic 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 not based on current circumstances.
* Council finances dependent on growth but projections appear optimistic. The finances of every council depend on attracting growth so this is nationally competitive and yet there is no policy to achieve that, just wishful thinking. The Sugar Beet Factory site alone is already more land than the projected requirement for employment land with a total oversupply of 187 hectares (identified need is 12.3 hectares).
* Commercial brownfield sites should be considered in preference to greenfield for all types of development.
* There is a real need for a Northern Ipswich Bypass, regardless of the proposed development in Sproughton. An issue with the Orwell Bridge can add at least 1 1/2 hours to a two minute transverse of Sproughton. This has a massive environmental impact and it is quite likely breaks all pollution laws and limits.
* Improvements to A1071 junctions through Sproughton are desperately needed - even without the proposed development.
* The A1071 should link directly with A14 to improve access into developing BDC area.
* A better railway service is needed (it is a prohibitively expensive service and Ipswich station has limited access)

Retail
* Retail policy inclined towards town centre growth, however as a rural community this is impractical without improved parking or an efficient transport network.
* The option to protect retail facilities in smaller towns/villages would appear to be an appropriate policy. However how or what that might amount to is unclear. How would it affect our community shop for instance?

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.
* The land that runs down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley is designated as an Area of Outstanding National Beauty (AONB). There is only one other place in Suffolk with the same combination and that is Dedham Vale. It would be political suicide to propose this development for Dedham Vale, so why is it acceptable to destroy the AONB in Sproughton?

Climate change
* Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS (Sustainable Drainage Systems) are not adequate for sustained (several day) rainfall events especially in flood zones.
* We would recommend much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk.
* In relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.

Sustainability standards
If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.
I would like you 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;
* that different technologies have different impacts and impacts can vary by place;
* that 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.
* I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
* You are suggesting that practices have changed and to look at the landscape as a whole rather than pockets of "deemed significance". Do you have a legal right to do this? It 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 national and local government experience in favour of council need. Should this on its' own be subject to legal challenge?
* 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 is a ticking rural development time bomb.
* In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.
* A Landscape Project Area is mentioned, this appears to be the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale, so a bit like the Gipping valley/Sproughton as it extends from Chantry Vale. Accordingly, this designation might be appropriate for Sproughton and the River Valley.

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

Infrastructure
* 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 don't want a repeat of the dealings and failed delivery of community projects surrounding the Snoasis project.
* It is 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 delivered at the beginning of the development. Past experience has shown this has not always been the case.
* Option INF2 specifically mentions education but this policy needs to apply to all necessary infrastructure i.e. from Health to Transport. For example:

o Key issues for Sproughton: highway / transport, education, health and flood risk
o Key issues for the future: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
o Key issues 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

* 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.
* I consider greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. I suggest that more emphasis is given to ensuring that any necessary developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities.
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.
* I also feel that the determination of settlement on the basis purely of numbers is over-simplistic. The setting and historical purpose of any collection of houses is important; for example, a collection of farm workers cottages located in the countryside should not necessarily establish a basis for a larger settlement. The existence of 'community' is also important.

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

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

* The number of houses proposed for Sproughton is 2,310 (total obtained by adding up the number of house per site as per the 'Sites Submitted' document. This is a disproportionate amount of housing for Sproughton. If the net OAN is 4,210 then Sproughton has 55% of the house required allocated to it.
* A better approach would be to pro-rata the allocation across all parishes - this is more simplistic as the JLP states but some tweaking could be done where appropriate. This would allow settlements to grow in a more organic way without penalising one parish in particular to the extent that it would be absorbed into Ipswich and merge with Bramford.

Consultation question 78 asks:
Do you consider the sites identified to be appropriate for allocation or inclusion within the settlement boundary? (please explain why and quote the settlement and site reference numbers).

As a general response
On an aggregate basis, no - the sites identified are not appropriate for allocation within the settlement boundary. In principle, planning policy should ensure a proportional allocation of housing and employment land across the Districts, sympathetic to and in support of the characteristics and needs of existing communities. A total of 9,446 dwellings are proposed (sum of dwellings across all sites specified within the SHLAA). However, once the net number of dwellings is calculated having taken into account planning applications granted, in progress etc., the Objectively Assessed Need (OAN) is reduced to 4,210. It appears that 2,320 of these dwellings i.e. 55.11% of the total development proposed in Babergh is designated for Sproughton. This is a significant over development of Sproughton which currently has around 581 dwellings - this would be an increase of 397% in parish size. It is completely disproportionate and would result in Bramford joining with Sproughton and Sproughton being absorbed by Ipswich in the same way that Kesgrave and Rushmere-St- Andrew has been. Not so much 'creeping coalescence' as 'complete digestion'. A much fairer basis for development would be a pro-rated approach with some tweaking for those settlements that are very small in size. On an individual basis, please see below specific comments in respect of sites allocated in and around Sproughton village:
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
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.
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
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.
Some Other issues to consider
5 Year housing supply
It is recognised that a primary reason for creating a new JLP is that the councils are failing to provide the 5 year supply of development sites. This failure may result in government taking over administration of planning applications. However this in itself throws up a multitude of questions not addressed in this JLP.
* This is becoming a problem nationwide, it is possible that the Government could set up a department to deal with all the planning applications from the massive number of councils that are failing?
* What is the main problem here? Would application based on NPPF be such a hardship when BDC is proposing policies to circumvent the environmental and social policies of the NPPF and rarely abides by their own policies if it disadvantages developers. The basic NPPF may be better.
* Councils are no longer public services, they are businesses, only the elected councillors are there to represent the community. Their primary interest is profit and loss.
* The electorate are bound by law to pay their council tax, nothing done good or bad by the council effects that income other than that by increasing the electorate they increase their income.
* On the other hand, interaction with commercial interest can generate income so for housing that will include new homes bonuses, planning fees, 106 payments, CIL etc.
* If the council is failing to achieve the 5 year supply now and builders are failing to build (over 2000 approved home applications lying dormant in BDC area) why are they not setting an achievable Housing Need objective? If they can't achieve what they need now how can they expect to achieve even more? Why have they accepted data that is unreliable because it makes no consideration for Brexit when a more up to date analysis would almost certainly provide a smaller growth figure that might be achievable. Is the answer that the bigger the numbers the bigger the opportunity to generate income regardless of what the electorate wants?

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


Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10014

Received: 10/11/2017

Respondent: Henley Parish Council

Agent: Mr Rod Caird

Representation:

The Parish Council feels that future development should be managed in such a way that the character of the village is protected and retained. It should not become an extension of northern Ipswich, and it should be protected as well from becoming an increasingly busy road junction between Ipswich, Claydon and Ashbocking. Growing populations near Henley will need to find access to the A14 and major population centres without Henley becoming an overloaded crossroads with bolted-on housing. The Community Centre, the Primary School, the Church and the mix of housing and agricultural land create a village ecology which could easily be unbalanced by uncontrolled development.

Full text:

Full representation attached.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10408

Received: 08/11/2017

Respondent: Wendy Lavington

Representation:

* Most important for Sproughton - transport infrastructure, school places, accessible healthcare services, enhance environmental assets are all missing already - the proposed development will exacerbate the problem and there is no clear financial plan to rectify this. You need to invest, not simply develop.

Full text:

To whom it may concern
I would like to lodge my response to the BMSDC JLP consultation document, as detailed below.
Could you please confirm receipt of my submission and include me in the mailing list for updates on the progress of the JLP.
Thank you and regards,
Wendy Lavington
SECTION 1 - STRATEGIC
Vision
* The development is not sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need.

Objectives
* The development should be balanced between homes and employment and be mindful of housing that local residents need and can afford.
* The already strained local road networks especially the "Ipswich Northern Route" and improvements to the A1071 at B1113 and Hadleigh Road junctions, and an access onto the A14 all need to be radically improved.
* The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
* How can you ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time? It is currently non-existent.
Priorities
* The development will lead to communities losing their identities by swamping and creeping coalescence (merging of communities).
* Location of growth should be spread more pragmatically across Babergh rather than fewer large sites - you're in danger of creating super developments and no-go areas such as Nacton.
* Most important for Sproughton - transport infrastructure, school places, accessible healthcare services, enhance environmental assets are all missing already - the proposed development will exacerbate the problem and there is no clear financial plan to rectify this. You need to invest, not simply develop.
Duty to Cooperate
* Ipswich say they have insufficient land to meet their projected housing numbers which means under the 'Duty to Cooperate' surrounding district councils must assist in finding land to accommodate Ipswich housing overspill.
* In this case around 4000 dwellings - how are Babergh proposing to help meet this requirement? Babergh should NOT be picking up all 4000.
SECTION 2 - DELIVERY

Housing Requirement, Settlement Hierarchy and Housing Distribution

Housing Requirement 2014 to 2036 - Option HR1 - 7,820 new houses based on population growth.
* I don't agree with this - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
* You do not take into account the relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability. How can you achieve this without legislation (which you do not have the power to do)?
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated
Contingency and Delivery
* Current 'stuck' sites with permissions and no building suggests need for contingency going forward - replace 'stuck' sites with others.
* Contingency sites to be replacement and not additional, original sites to be taken out of plan. Regular review of demand required checking the guiding principles of type, tenure, place and need (local) - should trigger need for reserve sites.

Hierarchy
* Our village status distorted by the scoring system, which in turn influences development location.
* Sproughton classed as CORE and also HINTERLAND village, it can't be both.
* I don't agree with approach taken - scoring based on distance to services and facilities; it should be based on travel time as accessibility overstated.
* No account is taken of capacity of a service in scoring eg Primary School/shops (Sproughton 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.
* We would support reconsideration of the scoring criteria adopted to include fairly balanced negative scores for the threat of Creeping Coalescence.

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

Other Distribution Options
* I would support an option for proportional distribution with the carefully planned 'organic growth' of existing communities.
* The expected Babergh population growth of 8000 by 2036 (9%) should be applied to each community - which would mean Sproughton will grow by 120 (50 or so new houses).
* This would 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 - all inward investment with the wealth and jobs 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
* Is the proposition to create a new or garden town, a separate and distinct community most probably in a new location with minimal local impact but the potential to improve/create improved county infrastructure/services?
* This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally situated where it least effects existing communities but with ready access to Road and Rail links - for example Needham Market or Stowmarket - both on the main line to London Liverpool Street.

Housing Types
* The national space standards should apply with provision for storage.
* The requirements for provision of accessible homes and bungalows on 10+ developments should be observed.
* Encourage Self Builds - they support the local economy and rural outlook so should be encouraged.
* The provisions for Affordable homes should also consider Starter homes which are more appropriate to support growth of local community.
* The 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.
* 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?
* 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 £180,000 (or a maximum of 3 times joint income if average salaries are at £27,600 with a £15,000 deposit - prudential lending limits) 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.
* 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 this is 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.

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, wider economic 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 not based on current circumstances.
* Council finances dependent on growth but projections appear optimistic. The finances of every council depend on attracting growth so this is nationally competitive and yet there is no policy to achieve that, just wishful thinking. The Sugar Beet Factory site alone is already more land than the projected requirement for employment land with a total oversupply of 187 hectares (identified need is 12.3 hectares).
* Commercial brownfield sites should be considered in preference to greenfield for all types of development.
* There is a real need for a Northern Ipswich Bypass, regardless of the proposed development in Sproughton. An issue with the Orwell Bridge can add at least 1 1/2 hours to a two minute transverse of Sproughton. This has a massive environmental impact and it is quite likely breaks all pollution laws and limits.
* Improvements to A1071 junctions through Sproughton are desperately needed - even without the proposed development.
* The A1071 should link directly with A14 to improve access into developing BDC area.
* A better railway service is needed (it is a prohibitively expensive service and Ipswich station has limited access)

Retail
* Retail policy inclined towards town centre growth, however as a rural community this is impractical without improved parking or an efficient transport network.
* The option to protect retail facilities in smaller towns/villages would appear to be an appropriate policy. However how or what that might amount to is unclear. How would it affect our community shop for instance?

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.
* The land that runs down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley is designated as an Area of Outstanding National Beauty (AONB). There is only one other place in Suffolk with the same combination and that is Dedham Vale. It would be political suicide to propose this development for Dedham Vale, so why is it acceptable to destroy the AONB in Sproughton?

Climate change
* Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS (Sustainable Drainage Systems) are not adequate for sustained (several day) rainfall events especially in flood zones.
* We would recommend much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk.
* In relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.

Sustainability standards
If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.
I would like you 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;
* that different technologies have different impacts and impacts can vary by place;
* that 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.
* I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
* You are suggesting that practices have changed and to look at the landscape as a whole rather than pockets of "deemed significance". Do you have a legal right to do this? It 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 national and local government experience in favour of council need. Should this on its' own be subject to legal challenge?
* 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 is a ticking rural development time bomb.
* In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.
* A Landscape Project Area is mentioned, this appears to be the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale, so a bit like the Gipping valley/Sproughton as it extends from Chantry Vale. Accordingly, this designation might be appropriate for Sproughton and the River Valley.

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

Infrastructure
* 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 don't want a repeat of the dealings and failed delivery of community projects surrounding the Snoasis project.
* It is 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 delivered at the beginning of the development. Past experience has shown this has not always been the case.
* Option INF2 specifically mentions education but this policy needs to apply to all necessary infrastructure i.e. from Health to Transport. For example:

o Key issues for Sproughton: highway / transport, education, health and flood risk
o Key issues for the future: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
o Key issues 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

* 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.
* I consider greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. I suggest that more emphasis is given to ensuring that any necessary developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities.
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.
* I also feel that the determination of settlement on the basis purely of numbers is over-simplistic. The setting and historical purpose of any collection of houses is important; for example, a collection of farm workers cottages located in the countryside should not necessarily establish a basis for a larger settlement. The existence of 'community' is also important.

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

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

* The number of houses proposed for Sproughton is 2,310 (total obtained by adding up the number of house per site as per the 'Sites Submitted' document. This is a disproportionate amount of housing for Sproughton. If the net OAN is 4,210 then Sproughton has 55% of the house required allocated to it.
* A better approach would be to pro-rata the allocation across all parishes - this is more simplistic as the JLP states but some tweaking could be done where appropriate. This would allow settlements to grow in a more organic way without penalising one parish in particular to the extent that it would be absorbed into Ipswich and merge with Bramford.

Consultation question 78 asks:
Do you consider the sites identified to be appropriate for allocation or inclusion within the settlement boundary? (please explain why and quote the settlement and site reference numbers).

As a general response
On an aggregate basis, no - the sites identified are not appropriate for allocation within the settlement boundary. In principle, planning policy should ensure a proportional allocation of housing and employment land across the Districts, sympathetic to and in support of the characteristics and needs of existing communities. A total of 9,446 dwellings are proposed (sum of dwellings across all sites specified within the SHLAA). However, once the net number of dwellings is calculated having taken into account planning applications granted, in progress etc., the Objectively Assessed Need (OAN) is reduced to 4,210. It appears that 2,320 of these dwellings i.e. 55.11% of the total development proposed in Babergh is designated for Sproughton. This is a significant over development of Sproughton which currently has around 581 dwellings - this would be an increase of 397% in parish size. It is completely disproportionate and would result in Bramford joining with Sproughton and Sproughton being absorbed by Ipswich in the same way that Kesgrave and Rushmere-St- Andrew has been. Not so much 'creeping coalescence' as 'complete digestion'. A much fairer basis for development would be a pro-rated approach with some tweaking for those settlements that are very small in size. On an individual basis, please see below specific comments in respect of sites allocated in and around Sproughton village:
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
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.
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
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.
Some Other issues to consider
5 Year housing supply
It is recognised that a primary reason for creating a new JLP is that the councils are failing to provide the 5 year supply of development sites. This failure may result in government taking over administration of planning applications. However this in itself throws up a multitude of questions not addressed in this JLP.
* This is becoming a problem nationwide, it is possible that the Government could set up a department to deal with all the planning applications from the massive number of councils that are failing?
* What is the main problem here? Would application based on NPPF be such a hardship when BDC is proposing policies to circumvent the environmental and social policies of the NPPF and rarely abides by their own policies if it disadvantages developers. The basic NPPF may be better.
* Councils are no longer public services, they are businesses, only the elected councillors are there to represent the community. Their primary interest is profit and loss.
* The electorate are bound by law to pay their council tax, nothing done good or bad by the council effects that income other than that by increasing the electorate they increase their income.
* On the other hand, interaction with commercial interest can generate income so for housing that will include new homes bonuses, planning fees, 106 payments, CIL etc.
* If the council is failing to achieve the 5 year supply now and builders are failing to build (over 2000 approved home applications lying dormant in BDC area) why are they not setting an achievable Housing Need objective? If they can't achieve what they need now how can they expect to achieve even more? Why have they accepted data that is unreliable because it makes no consideration for Brexit when a more up to date analysis would almost certainly provide a smaller growth figure that might be achievable. Is the answer that the bigger the numbers the bigger the opportunity to generate income regardless of what the electorate wants?

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


Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10520

Received: 08/11/2017

Respondent: Mr Joe Lavington

Representation:

* Most important for Sproughton - transport infrastructure, school places, accessible healthcare services, enhance environmental assets are all missing already - the proposed development will exacerbate the problem and there is no clear financial plan to rectify this. You need to invest, not simply develop.

Full text:

To whom it may concern
I would like to lodge my response to the BMSDC JLP consultation document, as detailed below.
Could you please confirm receipt of my submission and include me in the mailing list for updates on the progress of the JLP.
Thank you and regards,
Joe Lavington

SECTION 1 - STRATEGIC
Vision
* The development is not sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need.

Objectives
* The development should be balanced between homes and employment and be mindful of housing that local residents need and can afford.
* The already strained local road networks especially the "Ipswich Northern Route" and improvements to the A1071 at B1113 and Hadleigh Road junctions, and an access onto the A14 all need to be radically improved.
* The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
* How can you ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time? It is currently non-existent.
Priorities
* The development will lead to communities losing their identities by swamping and creeping coalescence (merging of communities).
* Location of growth should be spread more pragmatically across Babergh rather than fewer large sites - you're in danger of creating super developments and no-go areas such as Nacton.
* Most important for Sproughton - transport infrastructure, school places, accessible healthcare services, enhance environmental assets are all missing already - the proposed development will exacerbate the problem and there is no clear financial plan to rectify this. You need to invest, not simply develop.
Duty to Cooperate
* Ipswich say they have insufficient land to meet their projected housing numbers which means under the 'Duty to Cooperate' surrounding district councils must assist in finding land to accommodate Ipswich housing overspill.
* In this case around 4000 dwellings - how are Babergh proposing to help meet this requirement? Babergh should NOT be picking up all 4000.
SECTION 2 - DELIVERY

Housing Requirement, Settlement Hierarchy and Housing Distribution

Housing Requirement 2014 to 2036 - Option HR1 - 7,820 new houses based on population growth.
* I don't agree with this - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
* You do not take into account the relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability. How can you achieve this without legislation (which you do not have the power to do)?
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated
Contingency and Delivery
* Current 'stuck' sites with permissions and no building suggests need for contingency going forward - replace 'stuck' sites with others.
* Contingency sites to be replacement and not additional, original sites to be taken out of plan. Regular review of demand required checking the guiding principles of type, tenure, place and need (local) - should trigger need for reserve sites.

Hierarchy
* Our village status distorted by the scoring system, which in turn influences development location.
* Sproughton classed as CORE and also HINTERLAND village, it can't be both.
* I don't agree with approach taken - scoring based on distance to services and facilities; it should be based on travel time as accessibility overstated.
* No account is taken of capacity of a service in scoring eg Primary School/shops (Sproughton 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.
* We would support reconsideration of the scoring criteria adopted to include fairly balanced negative scores for the threat of Creeping Coalescence.

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

Other Distribution Options
* I would support an option for proportional distribution with the carefully planned 'organic growth' of existing communities.
* The expected Babergh population growth of 8000 by 2036 (9%) should be applied to each community - which would mean Sproughton will grow by 120 (50 or so new houses).
* This would 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 - all inward investment with the wealth and jobs 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
* Is the proposition to create a new or garden town, a separate and distinct community most probably in a new location with minimal local impact but the potential to improve/create improved county infrastructure/services?
* This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally situated where it least effects existing communities but with ready access to Road and Rail links - for example Needham Market or Stowmarket - both on the main line to London Liverpool Street.

Housing Types
* The national space standards should apply with provision for storage.
* The requirements for provision of accessible homes and bungalows on 10+ developments should be observed.
* Encourage Self Builds - they support the local economy and rural outlook so should be encouraged.
* The provisions for Affordable homes should also consider Starter homes which are more appropriate to support growth of local community.
* The 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.
* 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?
* 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 £180,000 (or a maximum of 3 times joint income if average salaries are at £27,600 with a £15,000 deposit - prudential lending limits) 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.
* 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 this is 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.

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, wider economic 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 not based on current circumstances.
* Council finances dependent on growth but projections appear optimistic. The finances of every council depend on attracting growth so this is nationally competitive and yet there is no policy to achieve that, just wishful thinking. The Sugar Beet Factory site alone is already more land than the projected requirement for employment land with a total oversupply of 187 hectares (identified need is 12.3 hectares).
* Commercial brownfield sites should be considered in preference to greenfield for all types of development.
* There is a real need for a Northern Ipswich Bypass, regardless of the proposed development in Sproughton. An issue with the Orwell Bridge can add at least 1 1/2 hours to a two minute transverse of Sproughton. This has a massive environmental impact and it is quite likely breaks all pollution laws and limits.
* Improvements to A1071 junctions through Sproughton are desperately needed - even without the proposed development.
* The A1071 should link directly with A14 to improve access into developing BDC area.
* A better railway service is needed (it is a prohibitively expensive service and Ipswich station has limited access)

Retail
* Retail policy inclined towards town centre growth, however as a rural community this is impractical without improved parking or an efficient transport network.
* The option to protect retail facilities in smaller towns/villages would appear to be an appropriate policy. However how or what that might amount to is unclear. How would it affect our community shop for instance?

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.
* The land that runs down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley is designated as an Area of Outstanding National Beauty (AONB). There is only one other place in Suffolk with the same combination and that is Dedham Vale. It would be political suicide to propose this development for Dedham Vale, so why is it acceptable to destroy the AONB in Sproughton?

Climate change
* Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS (Sustainable Drainage Systems) are not adequate for sustained (several day) rainfall events especially in flood zones.
* We would recommend much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk.
* In relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.

Sustainability standards
If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.
I would like you 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;
* that different technologies have different impacts and impacts can vary by place;
* that 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.
* I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
* You are suggesting that practices have changed and to look at the landscape as a whole rather than pockets of "deemed significance". Do you have a legal right to do this? It 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 national and local government experience in favour of council need. Should this on its' own be subject to legal challenge?
* 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 is a ticking rural development time bomb.
* In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.
* A Landscape Project Area is mentioned, this appears to be the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale, so a bit like the Gipping valley/Sproughton as it extends from Chantry Vale. Accordingly, this designation might be appropriate for Sproughton and the River Valley.

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

Infrastructure
* 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 don't want a repeat of the dealings and failed delivery of community projects surrounding the Snoasis project.
* It is 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 delivered at the beginning of the development. Past experience has shown this has not always been the case.
* Option INF2 specifically mentions education but this policy needs to apply to all necessary infrastructure i.e. from Health to Transport. For example:

o Key issues for Sproughton: highway / transport, education, health and flood risk
o Key issues for the future: education, public transport, highways, health, water, waste, energy, telecoms, leisure and environmental
o Key issues 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

* 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.
* I consider greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. I suggest that more emphasis is given to ensuring that any necessary developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities.
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.
* I also feel that the determination of settlement on the basis purely of numbers is over-simplistic. The setting and historical purpose of any collection of houses is important; for example, a collection of farm workers cottages located in the countryside should not necessarily establish a basis for a larger settlement. The existence of 'community' is also important.

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

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

* The number of houses proposed for Sproughton is 2,310 (total obtained by adding up the number of house per site as per the 'Sites Submitted' document. This is a disproportionate amount of housing for Sproughton. If the net OAN is 4,210 then Sproughton has 55% of the house required allocated to it.
* A better approach would be to pro-rata the allocation across all parishes - this is more simplistic as the JLP states but some tweaking could be done where appropriate. This would allow settlements to grow in a more organic way without penalising one parish in particular to the extent that it would be absorbed into Ipswich and merge with Bramford.

Consultation question 78 asks:
Do you consider the sites identified to be appropriate for allocation or inclusion within the settlement boundary? (please explain why and quote the settlement and site reference numbers).

As a general response
On an aggregate basis, no - the sites identified are not appropriate for allocation within the settlement boundary. In principle, planning policy should ensure a proportional allocation of housing and employment land across the Districts, sympathetic to and in support of the characteristics and needs of existing communities. A total of 9,446 dwellings are proposed (sum of dwellings across all sites specified within the SHLAA). However, once the net number of dwellings is calculated having taken into account planning applications granted, in progress etc., the Objectively Assessed Need (OAN) is reduced to 4,210. It appears that 2,320 of these dwellings i.e. 55.11% of the total development proposed in Babergh is designated for Sproughton. This is a significant over development of Sproughton which currently has around 581 dwellings - this would be an increase of 397% in parish size. It is completely disproportionate and would result in Bramford joining with Sproughton and Sproughton being absorbed by Ipswich in the same way that Kesgrave and Rushmere-St- Andrew has been. Not so much 'creeping coalescence' as 'complete digestion'. A much fairer basis for development would be a pro-rated approach with some tweaking for those settlements that are very small in size. On an individual basis, please see below specific comments in respect of sites allocated in and around Sproughton village:
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
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.
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
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.
Some Other issues to consider
5 Year housing supply
It is recognised that a primary reason for creating a new JLP is that the councils are failing to provide the 5 year supply of development sites. This failure may result in government taking over administration of planning applications. However this in itself throws up a multitude of questions not addressed in this JLP.
* This is becoming a problem nationwide, it is possible that the Government could set up a department to deal with all the planning applications from the massive number of councils that are failing?
* What is the main problem here? Would application based on NPPF be such a hardship when BDC is proposing policies to circumvent the environmental and social policies of the NPPF and rarely abides by their own policies if it disadvantages developers. The basic NPPF may be better.
* Councils are no longer public services, they are businesses, only the elected councillors are there to represent the community. Their primary interest is profit and loss.
* The electorate are bound by law to pay their council tax, nothing done good or bad by the council effects that income other than that by increasing the electorate they increase their income.
* On the other hand, interaction with commercial interest can generate income so for housing that will include new homes bonuses, planning fees, 106 payments, CIL etc.
* If the council is failing to achieve the 5 year supply now and builders are failing to build (over 2000 approved home applications lying dormant in BDC area) why are they not setting an achievable Housing Need objective? If they can't achieve what they need now how can they expect to achieve even more? Why have they accepted data that is unreliable because it makes no consideration for Brexit when a more up to date analysis would almost certainly provide a smaller growth figure that might be achievable. Is the answer that the bigger the numbers the bigger the opportunity to generate income regardless of what the electorate wants?

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

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10598

Received: 10/11/2017

Respondent: Ms Caroline Powell

Representation:

* MOST IMPORTANT FOR SPROUGHTON - transport infrastructure, school places, accessible healthcare services, enhance environmental assets.

Full text:

Please see attached full representation.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10609

Received: 09/11/2017

Respondent: Mrs LP Wheatley

Representation:

The most important for Sproughton Village is to remain a village and remain detached from nearby towns and villages. To retain the way of life of the village and to protect the allotments are important issues. Sproughton does not wish to be categorised as "Ipswich Fringe"

Full text:

see attached for full rep

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10755

Received: 10/11/2017

Respondent: Mendlesham Parish Council

Representation:

Maintaining a village and historic environment.
Avoiding single large areas of growth that risk losing the surrounding rural environment.
Maintaining the supply of high quality agricultural land that is a prominent feature of the district.
Good road links which will manage traffic out of Mendlesham village/ conservation area

Full text:

See attached

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10770

Received: 20/11/2017

Respondent: Mrs Carol Marshall

Representation:

MOST IMPORTANT FOR SPROUGHTON - transport infrastructure, school places, accessible healthcare services, enhance environmental assets.

Full text:

Section - Strategic
Vision
* Development to be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need.
Objectives
* Development balanced between homes and employment. Encourage inward investment, protect and enhance environmental assets, provision of necessary infrastructure and services, but emphasise provision of 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 junctions, and an access onto the A14. The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
* Ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time and without back paddling -Planning needs to be pro-active on this.
Priorities
* Development shouldn't lead to communities losing their identities by swamping and creeping coalescence (merging of communities).
* Location of growth to be spread more pragmatically across Babergh rather than fewer large sites
* MOST IMPORTANT FOR SPROUGHTON - transport infrastructure, school places, accessible healthcare services, enhance environmental assets.
Housing Requirement, Settlement Hierarchy and Housing Distribution
Housing Requirement 2014 to 2036 - Option HR1 - 7820 new houses based on pop. growth.
* I do not agree with this: numbers seem overstated with no apparent account taken of effects of BREXIT on domestic and overseas migration.
* Relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability.
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3)
CONTINGENCY and DELIVERY
* Current 'stuck' sites with permissions and no building suggests need for contingency going forward - replace 'stuck' sites with others.
* Contingency sites to be replacement and not additional, original sites to be taken out of plan. Regular review of demand required checking the guiding principles of type, tenure, place and need (local) - should trigger need for reserve sites.
HIERARCHY
* Village status distorted by scoring system, influences development location.
* Sproughton classed as CORE and also HINTERLAND village, can't be both.
* I do not agree with the stance 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.
* 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 offered: 1) County Town Focused, 2) Market Town/Rural balance, 3) Transport Corridor Focused. 4) New Settlement Focused. Due to the settlement types designated to Sproughton in the Hierarchy scoring the first three options propose over 50% of growth in our designations, only the last option reduces this to 35%.
* The combined arbitrary criteria for scoring of both Hierarchy and Spatial Distribution chosen by BMSDC for the JLP just appears to promote the site availability that has come forward, effectively a mechanism to justify the sites.
* JLP to 2036 gives opportunity for bold, innovative and creative thinking but continuing the urban sprawl / welding / merging communities not the answer.
* Creating well planned, self-sufficient purpose built settlements with their own identities is and thereby preserving the qualities of existing communities.
OTHER DITRIBUTION OPTIONS
* I would support an option for proportional ditribution
* 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 iopportunity; this matches a district wide 9% proportional distribution.
NEW SETTLEMENT
* It is the proposition to create a new or garden town, a separate and distinct community most probably in a new location with minimal local impact but the potential to improve/create improved county infrastructure/services.
* This issue is highly adversarial and personal. No one wants something like this in their back yard. So ideally situated where it least effects existing communities but with ready access to Road and Rail links.
* Some suggestions: Near Gt Blakenham, South of Sudbury close to rail link, Somewhere between Belstead/Bentley and A12/Main Rialway.
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
* I support policies that increase the provision of Bungalows and Accessible housing
* A factor apparently ignored is that we are living longer, and the number of retired people selling high value houses in city areas migrating to the area. The 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
* I support the retention of a 35% affordable housing target, but it should be more robustly enforced.
* The total need for affordable house suggested is 19.4%. This is a drop from the previous policy of 35% in the face of a 71% local increase in private rentals (i.e. homes being bought up and rented to people who can't afford to buy a home), an increase in single parents looking for homes and an increase in local financial deprivation. That just doesn't stack up.
* BDC under the last Local Plan only achieved 23% affordable housing which probably was the consequence of viability arguments from developers. Perhaps the proposal to reduce this to a 20% requirement is intended to make the target achievable? But the outcome is likely to be developers making the same arguments for similar reductions bring the deliverable supply down to about 13%.
* There is not a reduction in affordable housing need, there is an increase, that is a nationally recognised fact, and BMSDC need to enforce the standing policy of 35% more robustly to achieve that. This could be improved by apply the policy to developments of three or more homes, or BMSDC engaging in the construction of council homes themselves that could all be affordable/starter homes.
* Starter homes should also be added into this mix. Sold at a discount of at least 20% below market value with a maximum sale cost of £250,000 exclusively to first time buyers these are the type of homes the local community needs.
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.
* 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.
Gypsies and travellers
* Although policy relates to both BDC and Mid Suffolk the report suggests that need is M.S. The Cromer incident occurred when travellers gathered in large numbers therefore, limiting sites to short stay and small number of vehicles (say 3 days/3 plots) with sites well spread apart (say 20 miles) is safer for communities.
Economy
* A fundamental oversight is that the effects of Brexit has not been considered, either in trade, employment or migration calculations.
* JLP 20 year projections based on historic data, all pre Brexit Vote, and the bulk of growth came from migration, so are likely to be very over optimistic.
* Council finances dependent on growth but projections appear optimistic. The finances of every council depend on attracting growth so this is nationally competitive and yet there is no policy to achieve that, just wishful thinking. The Sugar Beet Factory site alone is already more land than the projected requirement for employment land with a total oversupply of 187 hectares (identified need is 12.3 hectares).
* Commercial brownfield sites should be considered in preference to greenfield for all types of development.
* Need for Northern Ipswich Bypass
* Improvements to A1071 junctions through Sproughton
* A1071 link directly with A14 to improve access into developing BDC area.
* Better Railway Service (expensive service and Ipswich station has limited access)
* Private sector building has been constant for decades, its Council building that has dropped off.
* We would support a policy for the Council to start building themselves.
Retail
* Call for sites did not actually bring forward any retail sites however there is a massive oversupply of Commercial sites that could accommodate Retail/Leisure parks if growth projections realised.
* Restricting all retail growth to town centres may be too restrictive as some growth may need to be accommodated away from town centres where sites become available.
* Retail policy inclined towards town centre growth, however as a rural community this is impractical without improved parking or an efficient transport network.
* Option to protect retail facilities in smaller towns/villages which would appear to be an appropriate policy. However how or what that might amount to is unclear.
* 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 view points, wildlife, flora and fauna reserves etc. have evolved from many years experience and often considerable efforts by communities, sometimes based on fleeting observations of rare species. They preserve the best of our environment & any policy that introduces a subjective opinion has the risk of overlooking years of experience and effort in favour of financial considerations.
* A point overlooked is the sequence of Landscape Character designations that run down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB). Does anyone know of a famous local artist?
Climate change
* Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS (Sustainable Drainage Systems) are not adequate for sustained (several day) rainfall events especially in flood zones.
* I would recommend much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains and that they should be designed and built not to reduce additional flood risk but to eliminate any additional risk.
* In relation to renewable energy the balance also has to be carefully managed with Agriculture, Biodiversity and Landscape. Food production is just as important for green management as green energy, as is protection of biodiversity and preservation of the landscape for society.
Sustainability standards
If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.
Issues to consider:
* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.
Landscape, heritage and design
* Relevant to Sproughton are SLA's (Special landscape Areas) which not only cover Chantry Vale but most of the area surrounding the village. Other local designations that relate to views, recreational and open spaces either do, or may also, relate to Sproughton.
* I support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them.
* It then suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance" which is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of experience in favour of Public / Economic Need.
* The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. It is a ticking rural development time bomb.
* Important Note:
* In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.
* A Landscape Project Area is mentioned, this appears to be the designation for the landscape overlooking the River Stour as an extension of the Dedham Vale, so a bit like the Gipping valley/Sproughton as it extends from Chantry Vale. Accordingly, this designation might be appropriate for Sproughton and the River Valley.
* Design
* The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character.
* That lends itself to small developments not estates which change the character of the county.
* All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.
Delivery
Infrastructure
* Overall I agree with the Infrastructure provision policy as set out. However, I believe that any developments MUST (not should) have good access to all necessary infrastructure needs that have been identified.
* Planning permission should only be granted if there is some legally binding agreement that any identified infrastructure services WILL BE delivered as will the timing of its delivery. Guarantees should be structured such that they cannot be cancelled or avoided. Planning permission should only to be granted if there is a robust and effective legal agreement in place to ensure delivery.
* I fully support and indeed, consider it essential that each scheme considers both the existing infrastructure commitments and cumulative impacts from other developments in a locality.
* It is 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.
* 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.
* 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 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.
* I consider greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. I suggest that more emphasis is given to ensuring that any necessary developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities.
* 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 fully supporting this, it is considered essential that any proposals to remove existing community facilities is supported by an appropriate formal assessment carried out in conjunction with the local community.
Functional Clusters
* Functional clusters is a way of looking at the existing spatial geography based on how communities interconnect. The functional clusters then inform the settlement hierarchy. Classification for these purposes is relevant to determining the approach to planning.
* The approach is not appropriate. Planning policy should not be based on artificial constructs, which over emphasise the role of larger settlements. Planning policy should ensure a proportional allocation of housing and employment land across the Districts in support of the characteristics and needs of existing communities.
Settlement Boundaries
* Settlement boundaries are used to identify where the principle of development has been established, a threshold of ten related dwellings is applied. land outside of this settlement boundaries is countryside.
* The JLP view is that they need redrawing to allow rural growth opportunities.
* Whereas some factors considered are appropriate the new boundaries have been drawn to include development sites that have not been delivered. Further thought needs to be given to planning consents that have been granted but not yet delivered.
* Extensions to a settlement boundary are inappropriate if existing permissions have not been delivered.
* I 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


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


On an aggregate basis, no - the sites identified are not appropriate for allocation within the settlement boundary. As a general principle, planning policy should ensure a proportional allocation of housing and employment land across the Districts, sympathetic to and in support of the characteristics and needs of existing communities. A total of 9,446 dwellings are proposed (sum of dwellings across all sites specified within the SHLAA). However, once the net number of dwellings is calculated having taken into account planning applications granted, in progress etc, the Objectively Assessed Need (OAN) is reduced to 4,210. It appears that 2,320 of these dwellings i.e. 55.11% of the total development proposed in Babergh is designated for Sproughton. This is a significant over development of Sproughton which currently has around 581 dwellings - this would be an increase of 397% in parish size. It is completely disproportionate and would result in Bramford joining with Sproughton and Sproughton being absorbed by Ipswich in the same way that Kesgrave and Rushmere-St- Andrew has been. Not so much 'creeping coalescence' as 'complete digestion'. A much fairer basis for development would be a pro-rated approach with some tweaking for those settlements that are very small in size.On an individual basis, please see below specific comments in respect of sites allocated in and around Sproughton village:
Some observations to help inform any responses to individual sites in Sproughton.
SS1024:
Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0721
Site appropriate for development, subject to the scheme proposal. It is not clear to local residents, however, why - given the size of the site - a portion may not be allocated to housing.
SS1023
Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats - all of which are reasons for NOT permitting development on the scale indicated, if at all) consideration should also be given to:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0191
Some of the site (specifically, in the south-west corner / adjacent to the existing settlement on London Road) may be appropriate for development, subject to the development of an appropriate scheme, the considerations already identified (highways, cordon sanitare and A14 noise, impact upon landscape, townscape and heritage assets, and biodiversity impact upon protected species and habitats), and further considerations comprising:
* The setting and the views into and from Chantry Vale, which are almost unique
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley)
* Topography of the proposed site and water courses / drainage
* Provision of schools and health services
* The 'creeping coalescence' between Ipswich town and Sproughton village, which would threaten the identity, if not the very existence of, Sproughton village.
SS0711
Site not appropriate for development.
In addition to those matters identified as requiring further investigation in the site assessment summary (highways, environmental and heritage), additional key considerations include:
* Maintaining a green corridor along the route of the River Gipping (i.e. the Gipping Valley) and the views to and from the river-side walks that would be impacted by the proposed site
* 'Creeping coalescence' between Bramford and Sproughton.
SS0299
Site is appropriate subject to the development of an appropriate scheme.
With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is our view, however, that the scheme as set out in the application is not appropriate and we support any challenge Sproughton Parish Council may make to any decision approving that application.
SS0223
Site not appropriate for development.
The site assessment summary notes appropriate considerations to factor into any decision (highways, landscape, heritage and allotment relocation). However, the District Councils should be in no doubt that any proposed development of a special landscape area, which also results in a loss of amenity and potentially significant negative social and economic impacts on the existing local community, is deeply objectionable.
SS1026
Site is appropriate subject to the development of an appropriate scheme.
With respect to the current Wolsey Grange application, no formal decision has yet been published by the Planning Committee. It is our view, however, that the scheme as set out in the application is not appropriate and we support any challenge Sproughton Parish Council may make to any decision approving that application.
Growth
* The data used to forecast growth is too historic as it makes no consideration for the effects of the Brexit vote, it is therefore unreliable and potentially over ambitious.
* On the back of this data the JLP proposes significant home building to accommodate significant migration into the area to fulfil the employment needs of significant growth in business/employment.
* But the JLP does little or nothing to promote growth in Business other than bring in more potential employees by building more housing.
* The government is pushing growth in the Midlands and Northern Powerhouse and they have much better business infrastructures. Suffolk cannot compete with this to attract new business unless councils introduce competitive incentives and improve the business infrastructure of the county. But this JLP proposes nothing constructive to achieve that.
* This JLP is good for business as more housing will increase the unemployed pool making it easier and often cheaper to run a business, but that doesn't mean growth.
* But if house building is not matched by business growth it will not be good for the bulk of the resident population as there will be no increase in overall wealth in the community, but the community will be supporting a bigger population.
* Developers and Councils promote growth as the ultimate objective, but for who? Take a look at London and compare it with your present lifestyle. Businesses and Councils do well in Cities, but what is the quality of life of those that live there?
New NPPF white paper imminent
* The latest consultation paper on the NPPF is proposing a cap of 40% above any LP created prior to their new proposals.
* Therefore it is entirely possible that the unrealistic housing needs proposals being proposed in our JLP could be increased by another 40% making an unrealistic growth plan impossible.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10898

Received: 09/11/2017

Respondent: Lady Anne Windsor Charity

Representation:

A clear vision statement such as the example given is most important for every town and village

Full text:

see attached for full rep

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10983

Received: 10/11/2017

Respondent: Stowmarket Town Council

Representation:

Stowmarket needs a regenerated town centre, fit for the challenges of the 21st century with employment opportunities included.

Full text:

Please find below, comments from Stowmarket Town Council in response the consultation on the Babergh & Mid Suffolk Joint Local Plan.


1. What do you think the Vision should be?

Stowmarket Town Council supports the Vision as set out in the Joint Local Plan.


2. Do you agree with the identified objectives? Please explain your reasoning
Stowmarket Town Council agrees with the identified objectives as set out in the Joint Local Plan.


3. Are there other objectives that should be added?
Stowmarket Town Council does not feel that other objectives should be added.


4. What should be a priority across the district area? (please state which district)

Stowmarket Town Council believes that investment in infrastructure across both districts should be a priority. It is essential that suitable and sufficient infrastructure be established in a timely manner i.e. prior to the completion of new development in order to adequately support residents, businesses and the wider community.


5. What is important for your town or village?

Stowmarket needs a regenerated town centre, fit for the challenges of the 21st century with employment opportunities included.


5a. Do you agree or disagree with the identified key issues for compliance with the Duty-to-Cooperate for the Babergh and Mid Suffolk Joint Local Plan? Please explain why.

Stowmarket Town Council notes that the Duty-to-Cooperate is a legal obligation and agrees with the identified key issues for compliance.


6. Are there any other key planning issues which need to be considered in accordance with the Duty-to-Cooperate? Please explain why.
Stowmarket Town Council has no comment to make in respect of this question.


7. Do you agree with the proposed approach set out under Option HR1? If not, please explain why and what alternatives you propose.

Stowmarket Town Council has no comment to make in respect of this question.


8. When allocating sites what scale of contingency should be applied? Please explain why?
Stowmarket Town Council has no comment to make in respect of this question.


9. Are there any specific measures that could be included within the Joint Local Plan what would assist with delivery?

Stowmarket Town Council has no comment to make in respect of this question.


10. What factors or priorities should be set as triggers for reserve sites to come forward?

Stowmarket Town Council has no comment to make in respect of this question.


11. Do you agree with the proposed criteria approach to rank settlements in the hierarchy? If not, please explain a suggested amendment or alternative.
Stowmarket Town Council agrees with the proposed criteria approach to rank settlements in the hierarchy.


12. Do you agree with the proposed joint settlement hierarchy? If no, please provide further details as to how the hierarchy should be amended.

Stowmarket Town Council believes that there is a necessity for the proposed joint settlement hierarchy categories to be reviewed and amended, as appropriate. In respect of Stowmarket, the designation of 'Urban Area and Market Town' is correct.

13. Which option(s) for housing spatial distribution do you think is best? Please explain your answer.
Stowmarket Town Council believes that option MHD3 - transport corridor focussed is the most suitable as this option would provide the most sustainable approach by providing development close to the transport network, allowing for people to be less reliant on cars and so addressing the strategic policies of mitigating climate change.

14. Are there other realistic broad distribution options which should be covered? Please explain your answer.
Stowmarket Town Council does not consider there to be other realistic broad distribution options which should be covered.

15. If a new settlement was to be planned in the area, where should it be located? Please explain your answer
The Town Council does not believe that a new settlement would be sustainable due to the pressures placed upon the immediate area by the two largest towns, Bury St Edmunds and Ipswich. The expansion of those towns has led to a position whereby Stowmarket competes for the employment opportunities which are vital for the long term viability of the town. A new town settlement in close proximity to Stowmarket would not support either settlement and would not create the sustainability for Stowmarket which is needed.

16. Should the Joint Local Plan include a requirement for new dwellings to meet the Nationally Described Space Standards?

Stowmarket Town Council believes that the Joint Local Plan should include a requirement for new dwellings to meet the Nationally Described Space Standards.


17. Do you have any views on the proposed approach towards self-build and custom build dwellings?

Stowmarket Town Council has no objection to the proposed approach. Due to the nature of some self builds, there may be instances of homes being built where only a limited type of dwelling would be suitable and planning policies would need to reflect this to encourage innovation and excellence.


18. What should the Councils' approach to starter homes be?

Stowmarket Town Council believes that adequate provision of starter homes should be given due consideration by the District Councils.


19. Should the Councils' be prioritising the provision of any particular types of homes?

Stowmarket Town Council believes that prioritisation should be given to the provision of Lifetime Homes.


20. Are there any other types of housing that should be planned/required?

Stowmarket Town Council believes that facilitation of a mix of housing types within developments is essential for the long-term sustainability of developments.

21. How can the Councils promote/facilitate development of homes for private rent?

Stowmarket Town Council does not believe that the promotion or the facilitation of the development of homes for private rent should fall within the remit of the District Councils.

22. In relation to affordable housing, do you consider the requirement should be set at a percentage other than the current 35% if so, please provide reasons?

Stowmarket Town Council believes that the current requirement of 35% should remain.


23. To what extent should affordable housing be (or not be) prioritised over provision of other infrastructure where viability is an issue?

Stowmarket Town Council believes that the provision of affordable housing should be a top priority, however, the provision of infrastructure must take precedence in all instances.


24. In relation to affordable housing, should there be any preference for housing to accommodate key workers?

Stowmarket Town Council does not believe that there should be any preference for housing to accommodate key workers, however, the local authority should retain a proportion of its temporary accommodation for key workers.


25. If Option RE2 is supported, what maximum percentage of market housing should be acceptable?
Stowmarket Town Council recommends a maximum of 25%.

26. Which option for the policy approach to rural growth do you think is most appropriate?

Stowmarket Town Council believes that option RG2 is most appropriate for rural growth.


27. Are there any other approaches to distributing development in rural areas that we should consider?

Stowmarket Town Council has no comment to make in respect of this question.


28. Do you support the proposed approach for hamlets? If not please explain?
Stowmarket Town Council supports the proposed approach for hamlets.


29. What should the Councils' approach to provision of negotiated stopping places be?
Stowmarket Town Council does not support the provision of negotiated stopping places as it supports the provision of fixed and transient sites, if they are deemed necessary.


30. Please submit details of any sites, or extensions to existing sites, which you consider are suitable for allocation as Gypsy and Traveller sites or Travelling Showpeople sites?

There are no suitable sites or extensions to existing sites which are known to Stowmarket Town Council.


31. Should the Joint Local Plan include a policy which identifies areas where moorings would be acceptable in principal?

Stowmarket Town Council has no comment to make in respect of this question.


32. If so, are there any specific locations where additional moorings could be?
Stowmarket Town Council has no comment to make in respect of this question.

33. Should we continue to identify existing employment areas and protect land and premises in these areas from redevelopment/conversion to other uses unless marketing evidence demonstrates there is no demand for employment use?

Stowmarket Town Council believes that the District Councils should continue to identify existing employment areas and protect land and premises in those areas from redevelopment/conversion to other uses unless market evidence demonstrates there is no demand for employment use.


34. If we continue to protect existing employment areas, which areas should be identified?

Stowmarket Town Council believes that all the current designated sites within the town should be protected.


35. Are there any existing employment areas that could be reallocated to other uses?

Stowmarket Town Council has no comment to make in respect of this question.


36. Should we identify areas where non-B class uses, such as car showrooms, tyre and exhaust centres and building material stores, can be located?

Stowmarket Town Council believes that non-B uses should be located on small industrial parks rather than in town centres.

37. Should there be a policy that allows a wider range of uses than just B class on all employment sites or selected employment sites?

Stowmarket Town Council believes that dependent upon circumstances, if units cannot be sold/let, then consideration should be given to other uses.


38. Should we allocate more than enough land to meet the forecast needs to enable more choice in the market and give flexibility to changing circumstances?

Stowmarket Town Council believes that the District Councils should allocate more than enough land to meet the forecast needs to enable more choice in the market and give flexibility to changing circumstances.


39. Should we make specific employment provisions for small and medium sized enterprises? If so, how and where?

Stowmarket Town Council believes that this should be considered in line with the Local Economic Strategy.


40. If we expand, or allocate additional employment land where should these be?

Stowmarket Town Council believes that this should be considered in line with the Local Economic Strategy.


41. What approach should we take to supporting new business formation across the Districts?
Stowmarket Town Council believes that this should be considered in line with the Local Economic Strategy.


42. Do you consider that any of the sites put forward as part of the Call for Sites should be allocated for retail or commercial leisure use? Please state why.

Stowmarket Town Council believes that this should be considered in line with the Local Economic Strategy.


43. Are there any other sites that should be considered for retail or commercial leisure use?

Stowmarket Town Council would expect that other sites should come forward in the "Delivering a Vision for Prosperity for Stowmarket" process.


44. If you consider allocations for retail development should come forward as mixed use, please provide details.

Stowmarket Town Council believes that if the town centre boundary were to be extended, as it strongly recommends, then allocations for retail development should come forward as mixed use.


45. Do you agree with the proposed Town Centre boundaries, Primary Shopping Areas, Primary Shopping Frontages and Secondary Shopping Frontages? If not, please explain why.

Stowmarket Town Council wishes for the town centre boundary to be extended to included additional existing areas and wishes to enter into dialogue with the District Councils in respect of an extension.


46. Do you agree with the approach to not define Primary Shopping Area boundaries within settlements other than the three main towns? If not, please explain why.

Stowmarket Town Council agrees with the approach to not define Primary Shopping Area boundaries within settlements other than the three main towns.


47. Do you agree with the approach to maintain and increase retail provision within the District Centres? If not, please explain why.

Stowmarket Town Council agrees with the approach to maintain and increase retail provision within the District Centres.


48. Do you agree with the proposed thresholds relating to the mix of uses within Primary Shopping Frontage? If not, please explain why.

Stowmarket Town Council agrees with the proposed thresholds relating to the mix of uses within Primary Shopping Frontage.


49. Do you agree with the proposal to require an impact assessment for all edge of centre and out of centre retail proposals that are 400sqm gross floor space or more? If not, please explain why.

Stowmarket Town Council agree with the proposal to require an impact assessment for all edge of centre and out of centre retail proposals that are 400sqm gross floor space or more.


50. The Councils propose to protect A1-A5 uses in Core Villages and Hinterland Villages, and in local centres within towns. Do you consider this to be the correct approach?
Stowmarket Town Council considers that the proposal to protect A1-A5 uses in Core Villages and Hinterland Villages, and in local centres within towns to be the correct approach.


51. Do you have views on the Option BIO 1 and / or BIO 2?

Stowmarket Town Council feels that BIO2 would be the preferred option.

52. How should the local plan consider the impact of renewable technologies? What types of effects should be assessed within the policy criteria?
Stowmarket Town Council has no comment to make in respect of this question.

53. Do you support the Council's initial preference to include water efficiency measures in new build? If no, please explain why?
Yes, with more extreme weather events occurring, it is vital to future-proof arrangements in respect of more extreme dry periods.

54. Are there any other additional environmental standards Babergh and Mid Suffolk should be requiring? If so, please provide details and reasons why.
Babergh & Mid Suffolk should aim to achieve the highest environmental standard as is possible. The Passivhaus Building Standard would be the ultimate aim, however, it is acknowledged that developers may be unable to achieve the standard in every instance.
55. Are there any other approaches that the Joint Local Plan could take to protect the landscape?
Stowmarket Town Council believes that the river corridors within the town should be designated within the Joint Local Plan and would ask that the District Councils enter into dialogue with The Pickerel Project in order to achieve the designation.
56. Should additional protection be given to areas which form part of a landscape project area but which aren't designated?
As with the answer to question 55, Stowmarket Town Council believes that the river corridors in the town should be designated within the Joint Local Plan.

57. How can the Joint Local Plan make the most of the heritage assets?
Stowmarket Town Council has no comment to make in respect of this question.

58. What level of protection should be given to identify non-designated assets? Are there any specific situations in which the balance should favour or not favour protection of identified non-designated assets?
Stowmarket Town Council believes that the current arrangements are sufficient.

59. Should a more flexible approach toward climate change objectives be adopted where this would assist in protecting a heritage asset?
Stowmarket Town Council believes that a more flexible approach should be taken in respect of the attainment of energy efficiency modifications to residential properties within the conservation area.

60. Is there any aspect of design that priority should be given to?
Stowmarket Town Council believes that the Suffolk Design Guide for Residential Areas 2000 should be reviewed, updated and adopted by the District Councils.

61. Is there any aspect of design that should be introduced to the Councils' policies?
Stowmarket Town Council believes that the Suffolk Design Guide for Residential Areas 2000 should be reviewed, updated and adopted by the District Councils.
62. Is there an area of design related to past development that you consider needs to be addressed in future development?
Stowmarket Town Council believes that the Suffolk Design Guide for Residential Areas 2000 should be reviewed, updated and adopted by the District Councils.
63. Which option do you consider most appropriate? Please explain why?
Stowmarket Town Council believes that option INF2 is the most appropriate.

64. What do you consider the key infrastructure issues in your community?
Stowmarket Town Council believes that the key infrastructure issues in the town are transport links and the provision of healthcare services.
65. What infrastructure issues do you consider to be a priority for the future?
Stowmarket Town Council believes that the future priority infrastructures in the town are transport links and the provision of healthcare services.

66. What infrastructure do you think would be needed to support the growth scenarios?
Stowmarket Town Council believes that good transport links are essential to support growth in the town. It is vital that infrastructure be provided in a timely manner.

67. What comments do you have on the proposed strategic approach to infrastructure delivery?
Stowmarket Town Council believes that a county-wide strategic approach to infrastructure delivery should be adopted.

68. Should a separate policy be developed to manage provision of education and healthcare?
Stowmarket Town Council believes that this is not within the remit of the District Councils.

69. Should the strategy of the Plan be focussed on addressing deprivation?
Stowmarket Town Council believes that a focus of the Joint Local Plan should be the provision of affordable housing, which may help to address deprivation.

70. Are there any specific approaches that should be applied to address deprivation?
Stowmarket Town Council believes that provision of affordable housing, good public transport and access to support providers should be at the heart of the Joint Local Plan.
71. Are there any other circumstances and / or provisions under which open space, sports facilities or community facilities should be required and / or protected?
Stowmarket Town Council has no comment to make in respect of this question.

72. Through the Plan should any other areas of Local Green Space be identified and protected?
Stowmarket Town Council believes that Chilton Fields should be protected within the Joint Local Plan.

73. Are there any specific facilities that should be included in the definition of community facilities?
Stowmarket Town Council has no comment to make in respect of this question.

74. Do you consider the approach to identifying functional clusters appropriate for Babergh and Mid Suffolk? If not, please explain what would be your preferred approach?
Stowmarket Town Council believes that the approach to identifying functional clusters for Babergh and Mid Suffolk to be appropriate.

75. Do you consider the proposed new settlement boundaries to be appropriate? (please explain your answer)
Stowmarket Town Council does not consider the Stowmarket town boundary to be appropriate. It has adopted a policy position thus:
i) Stowmarket Town Council shall seek to ensure that all development around the edge of Stowmarket which is a natural extension of the town, shall form part of Stowmarket; and

ii) Stowmarket Town Council shall recognise that all development which is a natural extension of village settlements shall form part of those villages.

76. Are there any other settlements that should be given new settlement boundaries? (please explain your answer)
Stowmarket Town Council does not have any comment to make in respect of other settlement boundaries.

77. Is the threshold (10 well related dwellings) for identifying settlement boundaries appropriate?
Stowmarket Town Council has no comment to make in respect of this question.

78. Do you consider the sites identified to be appropriate for allocation or inclusion within the settlement boundary? (Please explain why and quote the settlement and site reference numbers i.e. SS0001)
Stowmarket Town Council considers that the sites which have been identified to be appropriate for allocation or inclusion within the settlement boundary, however, it is disappointed that there are no reserve sites in the town and recommends that the matter be addressed as soon as possible.

79. Are there any other sites/areas which would be appropriate for allocation? (If yes, please provide further information and complete a site submission form
Stowmarket Town Council has no comment to make in respect of this question.




Please do not hesitate to contact me if you require any further information.

Kind regards,
Michelle

Michelle Marshall
Deputy Town Clerk


Stowmarket Town Council
Milton House I Milton Road South I Stowmarket I Suffolk I IP14 1EZ

01449 612060 I michellelm@stowmarket.org I www.stowmarket.org
@stowmarketTC