Q5A (p16)

Showing comments and forms 61 to 90 of 109

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8019

Received: 10/11/2017

Respondent: Essex County Council

Representation:

ECC agrees it is DTC partner for 'Infrastructure provision'.

Recommend BMS active/ongoing engagement covering cross boundary strategic matters to ensure deliverable/viable JLP. ECC can provide advice ensure evidence consistent from Essex perspective. BMS need to ensure DtC undertaken with Braintree, Colchester and Tendring.

Education: Take into consideration ECC school places documents. Small rural primary schools close to Essex-Suffolk boundary might receive additional pupils, generated by new housing. Discuss proposals with ECC.

Include ECC under 'Employment'. Need to resolve any cross boundary transport and environmental issues.

Include ECC under 'Environmental protection' with Braintree, Colchester, Tendring. Designated environmental assets along Suffolk-Essex boundary.

Full text:

Infrastructure Provision

ECC agrees that it is an identified duty to cooperate partner for the topic 'Infrastructure provision' covering the 'provision and enhancement of strategic infrastructure improvements'.

ECC recommends that Babergh and Mid Suffolk District Council's ensure that engagement with ECC officers and members takes place on an active and ongoing basis covering cross boundary strategic matters to ensure the Joint Local Plan is deliverable and viable. ECC can provide advice to ensure that the evidence supporting the Joint Local Plan is consistent from an Essex perspective. Babergh and Mid Suffolk District Council will need to ensure the duty is also undertaken with the Braintree District, Colchester Borough and Tendring District Councils.

Education

In terms of education, ECC publishes two key documents, in respect of school places, that should be taken into consideration during the plan making process:
* Commissioning School Places in Essex (2016-2021)
* Meeting the demand for school places in Essex : 10-Year Plan

ECC would like it noted that there are a number of small rural primary schools close to the Essex-Suffolk county boundary that might receive additional pupils, generated by new housing. Any proposals to rely on Essex schools to meet the infrastructure requirements of the Joint Local Plan should be discussed with ECC in advance of preparing the Regulation 19 Publication Draft Local Plan.

Employment

It is recommended that ECC is included as a duty to cooperate partner under the topic 'Employment' which includes the 'Impact of bordering strategic employment land developments'. There may be cross boundary transport and environmental issues to resolve.

Environmental Protection

It is also recommended that ECC is included as a duty to cooperate partner under the topic 'Environmental protection'. This should also apply to the Essex local planning authorities of Braintree District Council, Colchester Borough Council and Tendring District Council. There are designated environmental assets along the Suffolk-Essex county boundary where protection and management will need to be ensured.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8027

Received: 10/11/2017

Respondent: RSPB Stour Estuary and Wolves Wood

Representation:

The RSPB welcomes that the "conservation and enhancement of the natural and historic environment" is identified as a key planning issue within the Duty to Co-operate.

We welcome the opportunity to work with the Council(s), partners and stakeholders in meeting these requirements.

The RSPB has considerable land-holdings within the District (Wolves Wood, Flatford, Stour Estuary) and extensive knowledge of the ecological sensitivities and priorities. We are happy to work with the Council to share this knowledge so that species and habitats can be enhanced.

Full text:

The RSPB welcomes that the "conservation and enhancement of the natural and historic environment" is identified as a key planning issue within the Duty to Co-operate.

We welcome the opportunity to work with the Council(s), partners and stakeholders in meeting these requirements.

The RSPB has considerable land-holdings within the District (Wolves Wood, Flatford, Stour Estuary) and extensive knowledge of the ecological sensitivities and priorities. We are happy to work with the Council to share this knowledge so that species and habitats can be enhanced.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8732

Received: 10/11/2017

Respondent: Mr Philip Schofield

Representation:

All valid for a large-scale challenge that crosses borders. Possibly complement this with a focus on employment (hence houses) deliverable across the districts, minimising cross-border complexity

Full text:

All valid for a large-scale challenge that crosses borders. Possibly complement this with a focus on employment (hence houses) deliverable across the districts, minimising cross-border complexity

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 8928

Received: 10/11/2017

Respondent: Andrew Searle

Representation:

All co-operation itemised is upwards - none is shown downwards to community or neighbourhoods

Full text:

All co-operation itemised is upwards - none is shown downwards to community or neighbourhoods

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9421

Received: 09/11/2017

Respondent: Bacton Parish Council

Representation:

Agree. East Anglia is a growth region and planning needs to co-ordinated over a wide area.

Full text:

See attached letter

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9513

Received: 14/11/2017

Respondent: Cllr John Hinton

Representation:

Neither agree or disagree. Too many so called consultative bodies have no local or regional democratic mandate and no real understanding of local issues: - New Anglia LEP and Highways England to name but two!

Full text:

See full scanned representation attachment

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9691

Received: 07/11/2017

Respondent: Miss R P Baillon

Representation:

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.

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: 9807

Received: 10/11/2017

Respondent: Merton College, Oxford

Agent: Savills

Representation:

Our client acknowledges the Councils' efforts to engage with surrounding authorities in order to seek fulfilment of the Duty to Co-operate.

It is agreed that defining the housing market area and objectively assessed need is a key area. We agree that the highlighted partners must be engaged in this process. We agree that resolving any unmet housing need, confirming the approach to delivery of the housing requirement, and weighing up any impact(s) of bordering strategic housing developments is also a key topic relevant to the Duty to Co-operate.

At this stage we reserve specific comment on this matter until the Joint Local Plan is at a more advanced stage and where the Duty to Co-operate can be properly considered in the context of agreed OAN.

Full text:

See attachments

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 9981

Received: 08/11/2017

Respondent: Charlotte Lavington

Representation:

* 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.

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?


Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10057

Received: 09/11/2017

Respondent: Historic England

Representation:

Agree. We are pleased to see that the conservation and enhancement of the historic
environment is identified as a key planning issue and a strategic duty-to-cooperate
priority in line with paragraph 156 of the NPPF. We are also pleased to see that
Historic England is listed as a partner.

Full text:

See attachment

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10409

Received: 08/11/2017

Respondent: Wendy Lavington

Representation:

* 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.

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?


Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10519

Received: 08/11/2017

Respondent: Mr Joe Lavington

Representation:

* 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.

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?

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10524

Received: 09/11/2017

Respondent: Mr john barratt

Representation:

I fully understand that more housing is urgently required throughout the UK, and that Boroughs/ Councils have been allocated certain quota's that have to be fulfilled within certain time frames. 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 the Ipswich housing overspill. In this case around 4000 dwellings. Babergh should NOT be picking up all 4000.

Full text:


I fully understand that more housing is urgently required throughout the UK, and that Boroughs/ Councils have been allocated certain quota's that have to be fulfilled within certain time frames. 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 the Ipswich housing overspill. In this case around 4000 dwellings. Babergh should NOT be picking up all 4000.
Sproughton village currently has around 581 dwellings, and would appear to have had 2300+ houses (55% of OAN) allocated to it. This is an increase in the region of 397%! This is clearly what would be far too many houses crammed into what is really only a relatively small area. This is clearly disproportionate for the area and would result in the village losing its identity or even its existence, and with 'creeping coalescence' simply become part of Ipswich with Bramford (similar to Kesgrave and Rushmere St. Andrew).
The basic physical and organizational structures and facilities (e.g. roads, power supplies, health and education services etc) needed for the operation of a society or enterprise would not be able to cope with this extra load. It barely copes at present. It only takes a local road traffic incident on the A14 or A12 or closure of the Orwell bridge (a fairly common occurrence) to swiftly bring the whole of Ipswich and surrounding areas to a prolonged grinding halt ( I cannot understand why a northern by-pass hasn't already been constructed allowing a second major access road to what is the UK's largest container port. This would relieve the pressures on the west and southern areas in and around Ipswich and provide express access not only to Felixstowe, but to new residential/commercial/industrial areas) along the route.
Has 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 been fully explored. 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). Could housing now be considered for this area?
There is also the possible irreversible environmental damage which may be caused. 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.
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.
There is also a fundamental oversight in the mix, in 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.
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 you please acknowledge receipt of this email.

Many thanks
John Barratt

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10538

Received: 09/11/2017

Respondent: Alison Barratt

Representation:

I fully understand that more housing is urgently required throughout the UK, and that Boroughs/ Councils have been allocated certain quota's that have to be fulfilled within certain time frames. 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 the Ipswich housing overspill. In this case around 4000 dwellings. Babergh should NOT be picking up all 4000.

Full text:

I would like to lodge my response to the BMSDC JLP consultation document. I object to the proposals in their current form and would like to see a more proportionate dispersal of housing development throughout the Babergh area.

I fully understand that more housing is urgently required throughout the UK, and that Boroughs/ Councils have been allocated certain quota's that have to be fulfilled within certain time frames. 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 the Ipswich housing overspill. In this case around 4000 dwellings. Babergh should NOT be picking up all 4000.
Sproughton village currently has around 581 dwellings, and would appear to have had 2300+ houses (55% of OAN) allocated to it. This is an increase in the region of 397%! This is clearly what would be far too many houses crammed into what is really only a relatively small area. This is clearly disproportionate for the area and would result in the village losing its identity or even its existence, and with 'creeping coalescence' simply become part of Ipswich with Bramford (similar to Kesgrave and Rushmere St. Andrew).
The basic physical and organizational structures and facilities (e.g. roads, power supplies, health and education services etc) needed for the operation of a society or enterprise (infrastructure) would not be able to cope with this extra load. It barely copes at present. It only takes a local road traffic incident on the A14 or A12 or closure of the Orwell bridge (a fairly common occurrence) to swiftly bring the whole of Ipswich and surrounding areas to a prolonged grinding halt ( I cannot understand why a northern by-pass hasn't already been constructed allowing a second major access road to what is the UK's largest container port. This would relieve the pressures on the west and southern areas in and around Ipswich and provide express access not only to Felixstowe, but to new residential/commercial/industrial areas) along the route.
Has the considerable over supply of commercial sites coming forward as retail/leisure parks or even housing, especially where those sites are brownfield and have little community/environmental impact been fully explored. 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). Could housing now be considered for this area?
There is also the possible irreversible environmental damage which may be caused. 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.
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.
There is also a fundamental oversight in the mix, in 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.
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 you please acknowledge receipt of this email.

Many thanks

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10602

Received: 10/11/2017

Respondent: Ms Caroline Powell

Representation:

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.

Full text:

Please see attached full representation.

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10611

Received: 09/11/2017

Respondent: Mrs LP Wheatley

Representation:

Do not agree

Full text:

see attached for full rep

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10756

Received: 10/11/2017

Respondent: Mendlesham Parish Council

Representation:

Agree

Full text:

See attached

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10890

Received: 10/11/2017

Respondent: Bloor Homes Eastern

Agent: Strutt & Parker

Representation:

Need for the Councils to work positively with neighbouring authorities, particularly those that are within the same housing market area, as per the NPPF. Particularly pertinent to the JLP, given that the main centre within the administrative boundary of the main centre of the housing market area is tightly drawn around the existing settlement.

The JLP must consider whether a proportion of Ipswich's (as well as other authorities with the housing market area) housing needs need to, and can sustainably met through, development within Babergh and/or Mid Suffolk Districts. The matter of housing supply needs to take account of the primary role of Ipswich within the sub-region, unmet need, and the alignment of local plans.

Full text:

See attachments

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10940

Received: 10/11/2017

Respondent: Babergh Alliance of Parish & Town Councils

Representation:

The framework of the JLP is to cherry pick the NPPF and to ignore not only the letter of that document but also its spirit of a bottom up process based on local involvement at the community level.

It is not clear where authority is derived to ignore the NPPF as a whole. Many sections reference paragraph 156 of the NPPF, leapfrogging the need to; 'reflect the vision and aspirations of local communities' (para 150), 'be consistent with the principles and policies set out in this Framework' (para 151), 'Early and meaningful engagement and collaborations with neighbourhoods' (para 155). By starting at 156 the need to engage and involve local communities is not fully addressed. The current consultation is not a substitute for proper engagement.

Full text:

See attached

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 10984

Received: 10/11/2017

Respondent: Stowmarket Town Council

Representation:

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

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

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11088

Received: 10/11/2017

Respondent: Catesby Estates Plc

Agent: Strutt & Parker LLP

Representation:

Babergh and Mid Suffolk need to plan to meet Ipswich's unmet need. Given Ipswich's restrictive
administrative boundary it is unlikely Ipswich will be able to meet this need within its boundary, as
such Babergh and Mid Suffolk must plan to meet this unmet need.

Full text:

See attachments

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11160

Received: 10/11/2017

Respondent: Old Newton Parish Council

Representation:

Agree - East Anglia is a relatively cheap place to live in Southern England and transport links to London, Birmingham and other major cities need to be improved. It should be noted that this could push the price for properties up and there is still a need to keep properties affordable for local residents.

Full text:



Q 1. What do you think the vision should be? We broadly agree with MSDC outlined vision within the consultation document.

Q 2. Do you agree with the identified objectives? Please explain reasoning. Yes - Provided the infrastructure meets education, healthcare and transport needs of the growing population.


Q 3. Are there other objectives which should be added? Transport links to core villages is presently not acceptable and would need to be improved. Increased population needs to have an enhancement to our current healthcare provision as these are already stretched to capacity.


Q 4. What should be a priority across the district area? (please state which district) MSDC - Priority to downsizing from within and first time buyers allowing younger generations to stay local.


Q 5. What is most important for your town or village? Maintaining the village identity and growing the community provision within the environment to accommodate increased population. The Need for a safe and well lit footpath to accommodate young parents and their families to be able to reach the primary school on foot.


Q 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.
Agree - East Anglia is a relatively cheap place to live in Southern England and transport links to London, Birmingham and other major cities need to be improved. It should be noted that this could push the price for properties up and there is still a need to keep properties affordable for local residents.
Q 6. Are there any other key planning issues which need to be considered in accordance with the Duty-to-Cooperate? Please explain why.
District wise Social Care and health services need to be enhanced to handle increased population.
Q 7. Do you agree with the proposed approach set out under Option HD1? If not, please explain why and what alternatives you propose.
Agree with option HD2 as we currently have two major building projects in for planning development and we would naturally assume they are included within the village quota expected.
Q 8. When allocating sites what scale of contingency should be applied? Please explain why.
There is a need for some contingency in order to protect against loss of the 5 year supply and therefore not allowing unplanned growth in unsuitable areas.
Q 9. Are there any specific measures that could be included within the Joint Local Plan that would assist with delivery?
Insist on a substantial financial penalty of % of Cil payments upfront.
Q 10. What factors or priorities should be set as triggers for reserve sites to come forward?
Loss of the 5 year supply.
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.
Broadly agree
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.
Broadly agree. We would question the source of the data to substantiate this as it appears out of date.
Q 13. Which option(s) for housing spatial distribution do you think is the best? Please explain your answer.
MHD1 - As a core village we would want to keep our development proportionate to the population and we do not want to further develop our hamlet villages.
Q 14. Are there other realistic broad distribution options which should be considered? Please explain your answer.
No
Q 15. If a new settlement was to be planned in the area, where should it be located? Please explain your answer.
Within easy access to major transport links and employment.

Q 16. Should the Joint Local Plan include a requirement for new dwellings to meet the Nationally Described Space Standards?
Yes - Agree
Q 17. Do you have any views on the proposed approach towards self-build and custom build dwellings?
Self-build and custom build dwellings should not be exempt from CIL payments and should contribute towards parish infrastructure.
Q 18. What should the Councils' approach to Starter Homes be?
As identified in our housing needs survey there is a need for affordable housing for starter homes in proportion to housing stock within the area.
Q 19. Should the Councils be prioritising the provision of any particular types of homes? Out of our housing needs survey - 10 households stated they had a need. A further 5 households stated that they wanted to return to the village. A total of 15 households identified. There were an additional 15 households claiming a local connection on gateway to home choice. Indicating a combined need of up to 30 new houses. CAS recommendation would be to bring forward circa 10 new houses to begin with. This would need to be a mixture of affordable, family and retirement bungalows.

Q 20. Are there any other types of housing that should be planned for / required?
Assisted living or sheltered accommodation for the elderly
Q 21. How can the Councils promote / facilitate development of homes for private rent?
We currently have no data to make an appropriate comment to this question.
Q 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.
Agree
Q 23. To what extent should affordable housing be (or not be) prioritised over provision of other infrastructure where viability is an issue?
The value of land in our parish is not at a premium and therefore the viability of both social housing and larger dwellings are equal.
Q 24. In relation to affordable housing, should there be any preference for housing to accommodate key workers?
There is a recruitment problem for the health service and teaching and therefore it should be welcomed if an incentive for key workers was introduced.
Q 25. If Option RG2 is supported, what maximum percentage of market housing should be acceptable?
65% market housing and 35% affordable would be agreeable.
Q 26. Which option for the policy approach to rural growth do you think is most appropriate?
RG2.
Q 27. Are there any other approaches to distributing development in rural areas that we should consider?
Consider impact of cluster villages and the essential services on health and education.
Q 28. Do you support the approach proposed for hamlets? If not please explain?
Yes - Agree
Q 29. What should the Councils' approach to provision of negotiated stopping places be?
There is currently provision for travellers within close proximity and therefore not deemed a requirement for our parish.
Q 30. Please submit details of any sites, or extensions to existing sites, which you consider suitable for allocation as Gypsy and Traveller sites or Travelling Showpeople sites.
N/A
Q 31. Should the Joint Local Plan include a policy which identifies areas where moorings would be acceptable in principal?
N/A
Q 32. If so, are there any specific locations where additional moorings could be located?
N/A
Q 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 - Agree
Q 34. If we continue to protect existing employment areas, which areas should be identified?
Agree to continue to protect existing employment areas.
Q 35. Are there any existing employment areas that could be reallocated to other uses?
No
Q 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?
We have garage and MOT services at Old Newton and we have car sales and builders merchants at Bacton and we are close to Stowmarket for larger enterprises.
Q 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?
No
Q 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?
No
Q 39. Should we make specific employment provisions for small and medium sized enterprises? If so, how and where?
No
Q 40. If we expand, or allocate additional employment land where should these be?
N/A
Q 41. What approach should we take to supporting new business formation across the Districts?
Golden Hello's to businesses to attract them to the area, essential broadband provision.
Q 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.
No - We have industrial units and sporting facilities that suit the village needs.
Q 43. Are there any other sites that should be considered for retail or commercial leisure use?
No
Q 44. If you consider allocations for retail development should come forward as mixed use, please provide details.
N/A
Q 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.
N/A to Old Newton
Q 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.
N/A to Old Newton
Q 47. Do you agree with the approach to maintain and increase retail provision within the District Centres? If not, please explain why.
N/A to Old Newton
Q 48. Do you agree with the proposed thresholds relating to the mix of uses within Primary Shopping Frontage? If not, please explain why
N/A to Old Newton
Q 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 - Agree
Q 50. The Councils propose to protect RIA1-RIA5 uses in Core Villages and Hinterland Villages, and in local centres within towns. Do you consider this to be the correct approach?
Yes -Agree
Q 51. Do you have views on the Option BIO 1 and / or BIO 2? We have areas of significant scientific interest and therefore we agree with option Bio2.


Q 52. How should the local plan consider the impact of renewable technologies? What types of effects should be assessed within the policy criteria?
Option RE2 is our preferred option.
Q 53. Do you support the Council's initial preference to include water efficiency measures in new build? If no, please explain why?
The East is recognised as having low rainfall and therefore it is only right that water supplies are treated with respect.
Q 54. Are there any other additional environmental standards Babergh and Mid Suffolk should be requiring? If so, please provide details and reasons why.
Limited expertise but we welcome renewable infrastructure on new properties
Q 55. Are there any other approaches that the Joint Local Plan could take to protect the landscape?
Sympathetic landscaping to new developments.
Q 56. Should additional protection be given to areas which form part of a landscape project area but which aren't designated?
We would like to see new development to include open spaces and recreational areas with suitable planting to ensure the rural nature of the development is maintained and preserved.
Q 57. How can the Joint Local Plan make the most of the heritage assets?
We need to ensure our heritage areas and assets are protected and if threatened comprehensive public consultation to judge strength of public opinion.
Q 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?
Consult local opinion through public forums.
Q 59. Should a more flexible approach toward climate change objectives be adopted where this would assist in protecting a heritage asset?
We should protect at all costs our heritage assets as they cannot be replaced.
Q 60. Is there any aspect of design that priority should be given to?
Needs to be in-keeping and sympathetic to the existing properties and environment.
Q 61. Is there any aspect of design that should be introduced to the Councils' policies?
Not that we can see.
Q 62. Is there an area of design related to past development that you consider needs to be addressed in future development?
Drainage is a major issue in certain parts of our village and therefore any development needs to have a comprehensive plan to deal with grey water and run off water combined. Broadband is an essential provision to properties and the broadband infrastructure needs to be enhanced within our village as a priority.
Q 63. Which option do you consider most appropriate? Please explain why? INF 2 - Especially with regard to education as our village school is now full to capacity and because it is a successful school and is attracting out of catchment children and therefore it is essential to increase capacity and ensure sufficient funding is put in place when numbers increase. A robust and strategic plan must be put in place to ensure the provision is ready to accept increased numbers.


Q 64. What do you consider the key infrastructure issues in your community? Broadband is a major issue at present but is being addressed. As already mentioned there is a need for a footpath direct to the school, better parking in and around the school. Plans to extend the health provision within the locality especially with the explosion of houses in and around our neighbouring villages.

Q 65. What infrastructure issues do you consider to be a priority for the future?
Maintain broadband to a good quality. Enforcement of Speed limit restrictions through the village. Police presence is already significantly reduced in rural areas and this is a concern if we increase the number of properties.
Q 66. What infrastructure do you think would be needed to support the growth scenarios?
Drainage, public transport, education, health as already outlined in the above.
Q 67. What comments do you have on the proposed strategic approach to infrastructure delivery? It is essential that any infrastructure plan is developed in co-ordination with the parish council in partnership with the district council and we expect CIL payments to be given to the parish to support the development and enhancement of the infrastructure to maintain the nature of Old Newton and enhance it for the residents.



Q 68. Should a separate policy be developed to manage provision of education and healthcare?
Yes. This is a key area and a comprehensive approach needs to be developed to provide education at a consistent high quality to create a sound bedrock for a good village community. Our current healthcare provision is adequate but with the expected explosion of development in our neighbouring villages such as Mendlesham, Bacton and Haughley this needs to be addressed.

Q 69. Should the strategy of the Plan be focussed on addressing deprivation? With increased housing within the village we need to become eligible for bus services to Stowmarket. Currently public transport is not acceptable for deprived families. Our local support network is struggling to meet demand to assist the elderly and less fortunate to attend local supermarkets, market towns and health services.


Q 70. Are there any specific approaches that should be applied to address deprivation?
Social housing element is not adequate for the present need.
Q 71. Are there any other circumstances and / or provisions under which open space, sports facilities or community facilities should be required and / or protected?
Our current provision addresses above and beyond the needs of our parish.
Q 72. Through the Plan should any other areas of Local Green Space be identified and protected?
To provide safe play areas and open green spaces within any new development would be essential.
Q 73. Are there any specific facilities that should be included in the definition of community facilities?
No
Q 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?
Yes
Q 75. Do you consider the proposed new settlement boundaries to be appropriate? (please explain your answer) The following is in the parish council order of preference. The settlement boundaries were considered at both a public consultation and our monthly parish council meetings during the consultation period.

SS0131 is the parish council's preferred site for development as this is abutting the current village boundary. The parish council would like to see this land developed in phases and not densely populated with essential safe green spaces. The parish council would like developers to seriously consider access from Church Road as well as limited access from Greenacres and Mutton Meadow if brought to fruition.

SS1021 - This identified piece of land is felt to be ideal for smaller developments in Chapel Road and School Hill and will have a smaller impact on village life and give a more natural growth to the village.

The area identified as SS0012 is not the parish council preferred site but accept that this is already in the planning process with a live application. Should this development be successful we would naturally assume this development will count against our housing quota.



Q 76. Are there any other settlements that should be given new settlement boundaries? (please explain your answer)
27 Church Road is already within the curtilage of the village envelope, however it is not marked as part of the call for sites. The parish council would be in agreement should this be put forward for development. The parish council would also like to see this as part of the housing quota for the village if developed in the future.

Q 77. Is the threshold (10 well related dwellings) for identifying settlement boundaries appropriate?
Yes
Q 78. Do you consider the sites identified to be appropriate for allocation or inclusion within the settlement boundary? Yes - As already mentioned we do not consider Site SS0012 appropriate for development but accept this may be inevitable. If this development is approved, the parish council do wish to include the numbers as part of our quota.



Q 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) No




Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11243

Received: 10/11/2017

Respondent: Suffolk Wildlife Trust

Representation:

The Duty-to-Cooperate should extend to non-statutory consultees (such as nature conservation organisations local groups) who can provide local knowledge and help deliver solutions to issues on the ground. This will help ensure that issues are tackled in the best way possible.

Full text:

See attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11317

Received: 10/11/2017

Respondent: Eleanor & Guy Barker & Mrs V Aitken

Agent: Savills

Representation:

We welcome that the Councils are taking steps to ensure for close working between the two local authorities with partnerships and neighbouring authorities under the 'Duty to Co-operate' bound upon the Council by the Localism Act of 2011. Clearly, this is a very important aspect of developing a new Local Plan and in doing so, the Council must ensure that sufficient growth is planned for within Suffolk Coastal, to account for housing requirements arising across boundaries with neighbouring authorities.

Full text:

See attachment

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11320

Received: 23/11/2017

Respondent: Sproughton Playing Field

Representation:

* 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.

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?

Support

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11354

Received: 10/11/2017

Respondent: Stour & Orwell Society

Representation:

We agree, in general, but hope that the placing of "Environmental Protection" as Issue No. 9 does not suggest that it is an "also ran".

Full text:

See attached for full representation.

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11537

Received: 10/11/2017

Respondent: Annette Powell

Representation:

* Ipswich say they have insufficient land to meet their projected housing numbers which means under the 'Duty to Cooperate' surrounding district councils must assist in finding land to accommodate Ipswich housing overspill. In this case around 4000 dwellings - how are Babergh proposing to help meet this requirement? Babergh should NOT be picking up all 4000.
* Why have Fringe Parishes been excluded from the Ipswich Fringe Policy Forum. Duty to Cooperate is under NPPF supposed to go down through the government hierarchy not just sideways and up. This surely is a massive failing the imposition of the consiquences unacceptable.

Full text:

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

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

Housing Requirement, Settlement Hierarchy and Housing Distribution

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Healthy Communities
* Whilst we agree with the policies outlined here, we are concerned that any existing individual communities should not lose their community identity and cohesion as a result of 'creeping coalescence 'arising from the inappropriate location of new developments.
* We consider greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. We suggest that more emphasis is given to ensuring that any necessary development is spread more evenly over the District as a whole, rather than being concentrated disproportionately in particular communities.
SECTION 3 - PLACE
Functional Clusters
* The approach is not appropriate. Planning policy should not be based on artificial constructs, which over emphasise the role of larger settlements. Planning policy should ensure a proportional allocation of housing and employment land across the Districts in support of the characteristics and needs of existing communities.

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

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

Withn Respect to Specific Sites

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

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11625

Received: 10/11/2017

Respondent: Bloor Homes Eastern

Agent: JB Planning Associates

Representation:

Whilst key evidence sharing amongst neighbouring is to be welcomed, the Joint Local Plan will need to be able to identify clear decisions and definitive outcomes arising from its duty-to-co-operate activities.

We have not been able to find any references regarding the process for identifying and addressing any specific level of unmet housing need from Ipswich. Quite evidently, moving forward in the Plan making process, the Councils will need to demonstrate they have properly taken on board any requirement to help address Ipswich's unmet housing needs, given the constrained nature of the tightly drawn Ipswich Borough boundaries.

Full text:

See attachment

Comment

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11657

Received: 10/11/2017

Respondent: Haughley Park Consortium

Agent: Boyer Planning

Representation:

It is recognised that housing, employment and environmental protection (including the historic environment), are included as key planning issues. This is agreed.

It is imperative that the Councils' unmet housing need is identified prior to the emerging Local Plan progressing further. This should include unmet need from other neighbouring authorities.

Full text:

See attachment

Object

BMSDC Joint Local Plan Consultation Document (Interactive)

Representation ID: 11662

Received: 10/11/2017

Respondent: Lady Valerie Hart

Representation:

Environment protection section needs to include another statutory consultee namely Historic Gardens Trust which is statutory consultee for historic parks and gardens as well as Heritage England.
I consider also that it is very important for BDC to cooperate closely with parish councils where the parish council has expressed a wish to be involved on development proposals in its parish, especially with regard to planning obligations and Section 106 provisions.

Full text:

Q1: Object & Comment
The vision should more directly reflect the economic sectors identified on page 10 of JLP as
achieving growth namely tourism, hospitality, leisure and creative industries. Unfortunately,
frequently, B8 uses are widely allocated which are not suitable for the area and create little
employment.
Q.2: Object
Environment: The Environment definition should include heritage assets.
Healthy communities: "Supporting communities to deliver plans and projects:" CPC's
experience unfortunately has been that the views of parish councils are not welcomed nor
taken account of by BDC and opportunities to involve us as a parish council are resisted.
9 "To work with the communities of Sudbury" ... account needs to be taken of the views
of nearby communities which are affected e.g. Chilton. With regard to Chilton Woods
insufficient account has been taken of the impact upon Chilton parish, Sudbury and
surrounding communities.
Q.3: Comment
Yes. I consider that Babergh DC ("BDC") needs to work much more closely with the parish
councils. Lip service is paid to the Statement of Community Involvement.
1
The protection and enhancement of heritage assets which are an attraction to tourism should
be added as an objective.
Q.4
That housing and employment areas are allocated in areas where there is a proper need
rather than being allocated when land is offered or a planning application made. In the last
local plan the plan was 'jobs led'. Recognition needs to be given by BDC that not all the
housing and employment areas can be lumped around Sudbury. There is already a
substantial excess of employment land over forecast growth needs. These areas need to be
allocated in the Ipswich area.
Q.5: Comment
That our parish of Chilton be given proper recognition as a parish in this JLP. Further, that
BDC comply with its duty to cooperate as set out in Policy CS4 and consult and work
cooperatively with CPC with regard to the planning obligations and Section 106 provisions for
Chilton Woods. Despite our requests for such involvement they are ignored or rebuffed.
DUTY TO COOPERATE
Q.5 and Q.6
Environment protection section needs to include another statutory consultee namely Historic
Gardens Trust which is statutory consultee for historic parks and gardens as well as Heritage
England.
I consider also that it is very important for BDC to cooperate closely with parish councils
where the parish council has expressed a wish to be involved on development proposals in
its parish, especially with regard to planning obligations and Section 106 provisions.
HOUSING REQUIREMENT
I support Option HD2.
REVIEW OF THE SETTLEMENT HIERARCHY
Q.11: Object: See answer to Q12.
Q.12: Object
I refer to Chilton Parish Council's letter dated 10 November dealing with the inclusion of part
of the Parish of Chilton is included within Sudbury. I disagree. Chilton needs to have
separate recognition as a parish and I consider it should be included as a core village with
Great Waldingfield, Long Melford and Acton. The hierarchy should be amended to reflect the
above. It is totally unclear from JLP what is intended to occur to the remainder of the Parish
of Chilton which is not included in Sudbury.
SPATIAL DISTRIBUTION
Q.13: Support
The best option is BHD1. This is because the Ipswich fringe area is the area which can
contribute most to the economy and will provide opportunities for employment services and
facilities. There is too much development already coming forward on sites which are not
allocated.
2
Q.14: Comment
Option BHD3 - transport corridor focused could be considered although I consider the
allocation of 25% to the Ipswich fringe area is too low and should be increased to 50% and
allocation of 30% to the urban areas and market towns and to core villages is too high and
should be decreased. Settlement needs to be around the A12 and A14 routes.
Q.15: Object
No suitable area: Chilton Woods was originally planned as a standalone new "garden town"
in past Local Plans. However, with the Illustrative Master plan it is clear that it falls far short
of a garden town. Too much development is being allocated already to the Sudbury area
and the infrastructure to support such large developments is lacking and not provided for
sufficiently in proposed developments. Any new settlement should be in the Ipswich fringe
areas but I consider option BHD4 needs a much higher percentage for the Ipswich fringe
area.
Housing Types and Affordable Housing
I support options HM2 and HM3.
Q.16: Support: Yes
Q.17
I agree no alternative planning policy is necessary for self-build and custom-build properties.
Q.18: Comment
I support requiring a certain proportion of Starter Homes on strategic housing allocations.
Q.19: Comment
Given the identified increase in the older population i.e. that the number of people aged over
65 is expected to rise by 59% by 2036, I suggest BDC should be prioritising the provision of
housing that would help enable people to live in their homes for longer and/or live in their
homes more easily.
Q.21: Comment
The Council could promote or facilitate development of homes for private rental by using land
owned by the county council or other councils which could be provided at a lower than
market price in order to benefit local residents.
Q.22: Obect and Comment
No, I consider the requirement for affordable homes should remain at the current 35%.
Q.23
My experience has been that BDC do not prioritise affordable housing over the provision of
other infrastructure where viability is an issue e.g. the acceptance of 20% - 25% affordable
housing element at Chilton Woods rather than an insistence on 35% where the county
council could have made less profit.
3
Q.24
Yes, keyworkers should be given priority.
ECONOMIC NEEDS
Q.33: Comment
I prefer option EC0N1. To have a forecast jobs growth need of 2.9 hectares of employment
land in Babergh during the JLP period, whereas as at 1 April 2015, there was already 86.06
hectares in Babergh, including 20 hectares at Chilton Woods, allocated for employment
uses, there is clearly a substantial excess of employment land over forecast needs.
Accordingly, I support option EC0N1. Given the surplus, any employment land allocations
which have adverse impacts on the environment or heritage assets should be re-evaluated.
Q.34: Comment
Areas which do not have constraints on development or which, if developed, would not have
adverse impacts on the environment and/or heritage assets.
Q.35: Yes.
Consideration should be given to professional services, computing and technology,
hospitality and leisure and advanced manufacturing and engineering rather than the existing
focus on B2 and B8 uses.
Q.36: Support: Yes.
I would support non B use classes being, located away from town centres, residential areas
and rural villages.
Q.38: Object:
Given the substantial excess of employment land already available over the forecast needs, I
consider that further land does not need to be allocated.
Q.39: Support: Yes.
There are, for example, clusters of specialised professional services such as acoustic sound
engineers in Babergh.
Q.40: Comment
Any allocation of additional employment land should be in the Ipswich fringe area where
there is a demand.
BIODIVERSITY
Q.51: Support
I support option BIO 2 over option BIO 1.
LANDSCAPE, HERITAGE and DESIGN
Q.55: Support: Yes. I support Option L2.
4
Q.57: Comment
LPAs have already a statutory duty to protect and enhance heritage assets. Evidence
suggests that 9 out of 10 people agree that when improving local places it is worth saving
their historic features.^ The historic environment has an important role to play in providing an
attractive, safe and sustainable place and should be regarded as a vital contributor to
improving the quality of place and quality of life. Insufficient recognition is given to this in
past local plans. Further, the JLP could pay more attention to the wishes of the local
community and also to the views of regional heritage bodies such as Suffolk Preservation
Society, The Sudbury Society and Suffolk Garden Trust. In my experience, advice from
English Heritage is not given sufficient weight and the in-house heritage advisers at BDC
should be consulted more often. A well cared for historic environment is one of the keys to
making a locality attractive to people and to encourage the retention of workers and
attracting inward investment.
Councillors sitting on the planning committee should be given more training about heritage
issues.
Q.58
A policy approach consistent with the weight afforded to non-designated assets in the NPPF
should be applied.
Q.59: Support: Yes.
Q.60: Object and Comment
There should be a design code applied to Master Plans for large developments. Master
plans need to conform to the criteria and so called "illustrative master plans" should not be
acceptable as they have no commitment to future design or layout. Therefore Master Plans
as properly defined in past Local Plans must be required.
Q.61: Comment
Yes. The Suffolk Design guide for residential areas is 16 years old now. It should be
reviewed and updated. A Design Code or design requirements should be added to the
Council's policies.
Q.62
Yes: by way of example, it was resolved to grant the Chilton Woods development outline
planning permission when in my view it fails to conform to its specific governing policy CS4 in
that a master plan has not been provided only an "illustrative master plan" which provides no
commitment as to the future design. An integrated standalone development was required.
As the Parish Council most affected I and others fear that what will happen is a piecemeal
development of some 500 houses with none of the required community facilities.
INFRASTRUCTURE
Q.63: Comment
The draft policy for managing infrastructure provision is well meaning. However, actual
experience during the period of consultation is that BDC's actions do not accord with this
intent. At the Chilton Woods proposed development where clearly a new access road into
^ Taking part: national survey of culture, leisure and sport.
5
this site at the Western Employment area needed to be provided so to avoid construction
traffic going through residential areas. I hope in the consideration of planning conditions and
SI 06 obligations it will be so imposed.
Q.64
» Traffic congestion due to the inadequate road structures and the requirement in
Sudbury to cross Ballingdon Bridge.
® Traffic frequently tails back from the bridge to the top of Ballingdon Hill causing delays.
^ HGV vehicles using B1115 which is a narrow road where there have been fatal road
traffic accidents.
® Need for new permanent school buildings rather than temporary porta-cabins.
® General lack of investment in infrastructure required when planning permissions are
granted.
® The need for SI06 provision of green open spaces and community woodland in
particular, the green buffer zone.
Q.65
Transport and traffic congestion. Increased usage of the rail line between Sudbury and
Marks Tey. More schools as there is already a shortage in the area. Given the ageing
population in Babergh increased demands on medical care and healthcare services are to be
expected.
Q.66
I consider BDC should recognise that substantial improvements to roads and transport are
needed. The housing in an area cannot keep expanding without there being equal
investment in infrastructure to support housing and economic growth.
Q.67: Comment
I regard the policy as well intentioned but Chilton Parish Council have already experienced a
complete disregard for this requirement with regard to the resolution to grant the recent
outline application for Chilton Woods.
Q.68: No
HEALTHY COMMUNITIES
Q.71
I support option NR0S2. Babergh has insufficient green open space. I also support option
CF2. I prefer Option 0S1. The weakness in 0S2 is that it will be described otherwise as an
aspiration rather than a requirement. I am concerned, in the Chilton Woods development;
insufficient protection is being effected through Section 106 and planning obligations to
protect open space, sports' facilities and the community facilities. Policies must be followed
rather than ignored when a proposed development pleads that the provision of those facilities
affects the viability of the proposed development. If not viable it should not go ahead.
Q.72: Yes, please see Chilton Parish Church letter dated 9 November.
6
Q.73: Comment
i suggest village hall, community playing fields, sports' facilities and allotments.
SETTLEMENT BOUNDARIES
Q.75
I refer to Chilton Parish Council's letter of 9 November regarding the failure to classify Chilton
Parish as an independent settlement within pages 25 to 27 of this document. It has only
been referenced within the Sudbury settlement "(including part of Chilton and part of
Great Cornard)". Parishioners and other parties seeking to comment on Chilton will fail to
find Chilton listed as a Parish which is misleading. It is noted that Great Cornard does not
suffer the same fate as Chilton.
I object to the proposed new settlement boundaries as shown on the Sudbury (including part
of Chilton and part of Great Cornard - map shown in Appendix 2 on page 179).
POTENTIAL LAND FOR DEVELOPMENT
Q.78: Object
Within the document two SHELAA sites are attributed to Sudbury:
® SS0590 - Land to the east of Waldingfield Road and North of Church Field Road,
Sudbury
» SS0933* - Land to the east of Waldingfield Road and North of Church Field Road,
Sudbury
This is incorrect. Both these sites are in the Parish of Chilton. The comments about
mitigation fail to include Chilton Church, a grade I listed building or the historic park and
gardens at Chilton Hall.
Generally, I consider that allocating all the land between Chilton airfield and the beginning of
Great Waldingfield along the B1115 roadside is unsuitable, in particular, the allocation
SS0948. What in effect will happen is that Great Waldingfield loses its distinctiveness and
becomes in effect part of the Chilton Woods' development. This land should form part of the
green buffer zone.
The B1115 is a narrow winding road. It has been subject to a number of road traffic
accidents some causing fatalities. It is unsuitable for heavy goods vehicles of which there
are already a number traveling to and from Chilton Grain. Adequate road structures will
need to be constructed within the airfield to cope with the increased traffic.
As to SS0590 and SS0933, as stated, both these sites are in the parish of Chilton. Site
reference SS0590 indicates that the part of the site owned by the NHS which is currently
allocated to C2 usage would be developed for residential use. Given the ageing population
and the need for nursing and/or care homes, I consider the existing C2 use allocation should
be maintained. I regard the suggested density of 40 houses as far too high.
Given the substantial excess of already allocated employment land being 83 hectares of
which 20 is at Chilton Woods and the constraints of this site, if development is to be allowed
on this site, which I submit should not occur, that only the part of the site fronting Church
Field Road should be developed in accordance with BDC's heritage officer's report. The
7
description of employment use refers in SS05902 to B1 only, whereas on SS0933 the
reference to the proposed land use description is B1/B2/B8. I consider B2 and B8 uses are
incompatible with the nearby heritage assets and other residential properties.
However, careful consideration would need to be given to the adverse impacts of
development and whether appropriate mitigation was possible with regard to nearby heritage
assets including Chilton Church (Grade I) listed building, Chilton Hall (Grade IT), the walled
garden (Grade II) and the historic park and gardens. Any development on this site needs to
protect and enhance the heritage assets. There are alternative employment sites allocated
nearby.
There is an existing cycle way - footpath on the site which is in very poor repair and needs to
be designated for public use.
Overall, the lack of attention to detail and consideration of Chilton Parish in the JLP is very
disappointing. The defects should be remedied as soon as possible.