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Representation 11215 on BMSDC Joint Local Plan Consultation Document (Interactive) by Bildeston Parish Council (Mr David Blackburn)

Support / Object: OBJECT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - HOUSING, Housing Requirement, Q7
Representation: We consider that insufficient allowance has been made in the housing need calculation for windfall sites, taking into account the historic contribution which these have made. We also question why the housing requirements appear to substantially outstrip the projected population growth.

Original submission

Babergh/Mid Suffolk Joint Local Plan Consultation
Bildeston Parish Council Response

General
We are pleased to respond to your consultation as below. We have chosen to respond in this form as we believe the on-line consultation is too constraining in some areas, although we have referenced our comments to individual questions where possible.
You will appreciate that we have recent experience of the application of current planning policy in Babergh, and this experience has been very negative. However, the intention behind our response is not to look back, but to help create a better, more transparent and more participative planning system in the District for the future.

Vision and Objectives
While the consultation covers many aspects of the eventual draft local plan, it appears the vision is intentionally left as a clean sheet for consultees to respond to.
The section on Vision is therefore confined to a brief statement of the policy context followed by the list of objectives. It seems to us that this approach is fundamentally flawed and that the absence of an initial vision is then all too apparent throughout the remainder of the document. Consequently, the draft comes across as an exercise driven predominately by an academic calculation of future housing numbers, rather than a real world vision of what should be delivered for the people and communities in Babergh and Mid Suffolk by the end of the plan period.
In our view, a vision with wide community support should have been developed first. This vision should then have been a golden thread, evident throughout any subsequent consultation drafts on the joint local plan.
Despite that, we suggest that any vision should include the following (although some of the detail may be more appropriate as additional objectives):
Through the plan period to 2036:
* Babergh and Mid Suffolk will remain attractive largely rural areas with thriving towns and villages and an attractive, varied landscape.

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

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

* The adverse impact of development on the environment will be minimised by locating housing development in proximity to centres of employment or to good transport links to centres of employment.

* Wherever new housing is provided, it will respond to identified local needs including in relation to type, size, and tenure.

* All new housing will be to the highest design standards both visually, in the context of local character, and in environmental performance.

* The adverse impact of new housing developments on areas such as traffic congestion, air pollution and social cohesion will be minimised through the scale and location of developments and the enhancement wherever needed of physical, social and environmental infrastructure.

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

Duty to Cooperate
No comments.

Housing Requirements
We consider that insufficient allowance has been made in the housing need calculation for windfall sites, taking into account the historic contribution which these have made. We also question why the housing requirements appear to substantially outstrip the projected population growth. (Q7)
No contingency should be applied. This is likely to result in an over allocation of large sites at the expense of brownfield and infill sites, and hence unnecessary development in the countryside. This is double so if the allowance in the calculation for windfall continues to be under-estimated. (Q8)
Giving due priority to brownfield and infill sites would aid delivery as these are likely to have greater local support. (Q9)
Triggers for reserve sites should be focussed on specific local need, including local employment, rather than on a generalised calculation of housing numbers across the district. (Q10)
Review of the Settlement Hierarchy
We consider that the approach is too simplistic and does not, for example, reflect the very different characteristics of the large number of core villages. There is a fundamental difference between being the largest village in an area and having local facilities and service, compared to being well placed for growth by having good access to a range of employment opportunities. We suggest that these two issues are currently conflated and should be separated. In creating a hierarchy for development, employment opportunities and transport links should be given a much higher weighting than currently. (Q11 and Q12)

Spatial Distribution
The consultation presents four different options for the distribution of housing development over the plan period. This appears to us to be a divisive approach, inviting consultees to express a preference for one set of seemingly arbitrary numbers over another. This encourages subjective responses, rather than a more strategic and objective approach.
What is needed, and appears to be notably absent, is a thorough and objective analysis underpinning both the four options put forward and the percentages within them.
Most importantly, there should be an analysis of the employment trends predicted over the plan period. This should identify the amount and likely location of new employment, and changes in existing employment, and should include trends in the rural economy and in home or mobile working as well as traditional fixed employment.
A key part of this should be a projection of the future trends in out of area commuting by road or rail.
Similarly, a better understanding of projected trends in the rural economy and home based working would enable informed choices to be made on whether more rural areas of the district(s) can sustain any significant growth without simply creating unsustainable increases in car based commuting to traditional employment centres. (Qs 13 and 14)
The option of a new settlement should be properly evaluated and subject to public debate. Again, it is divisive to invite speculation on specific locations at this stage and there needs to be some objective analysis to support debate. But it is logical that such a settlement would need good transport links and access to employment. (Q15)

Housing Types & Affordable Housing
Housing types and tenure should be driven by local need, which may be different from place to place. This should take into account the local demographic (e.g. older people in the community wishing to move from a family home to a bungalow or young people brought up in the community wishing to get their first home of their own). It should also take into account the issues faced by local employers in recruiting and retaining staff with the reasonable prospect of being able to find local housing.
Simply applying a formula of social housing provision to any development will not properly address these issues. There needs to be proper local engagement and identification of local need including not just type of property but also tenure.
It should be an aim of the new plan to achieve a more even geographic distribution of social housing, which is at a very low level in some communities. Where there is already a substantial proportion of social housing in a village, (e.g. 25% or more) we consider that the proportion of social housing on any new development should be no greater than the existing proportion in the settlement, and may be less, depending on the mix of other types of affordable housing provided, e.g. shared ownership. (Q22)
Given the critical importance of new infrastructure to support housing development, infrastructure provision should not be sacrificed for affordable housing. (Q23) See also our infrastructure comments.
We support the prioritisation of key worker housing, but only in locations in reasonable proximity to key worker employment. Beyond this, we consider that the needs of local employers should be given greater priority than currently in housing allocation. (Q24)

Rural Growth and Development
This section encapsulates many of the failures of a policy based approach, in Babergh at least, in recent years.
As a result of failure to deliver large strategic sites, the housing land supply has apparently dropped to less than 5 years, meaning than planning policies which should protect the countryside and special places in the area are disallowed in the planning process.
Inept planning policy has had the dual impact of allowing development where it is not wanted and there is no proven local need, but preventing development in those smaller communities which would welcome it.
Furthermore, policy CS11 is in complete disrepute following the ruling of the High Court on its (already obvious) meaning.
We have no confidence that any future approach to rural growth which relies solely on policy will be any better aligned with local needs or wishes, leaving communities without the housing they need, or with unsuitable and unsustainable development unless they have the means and resolve to mount a High Court challenge.
While not the whole answer, we believe that an allocations based approach is likely to deliver a better outcome for most communities, giving them the opportunity to challenge draft site allocations, and put forward new ones, as part of the local plan process, including examination of the draft plan by a planning inspector. (Qs 26 and 27)

Accommodation Needs of Gypsies and Travellers
No comments.

Economic Needs
No comments.

Town Centres and Retail
No comments except that we support the protection of A1-A5 use in villages and local centres. (Q50)

Biodiversity
No comments.

Climate Change
No comments.

Landscape, Heritage and Design
No comments on landscape.
Design should be sympathetic to local style. Layout design should include direct pedestrian and (where possible) cycle links to village centres and local facilities to minimise car use for local journeys. (Qs 60 to 62)
Infrastructure
We support Option INF2 to have a strategic infrastructure policy, but a policy alone is not sufficient - there needs to be a detailed infrastructure delivery plan. (Q63)
Lack of infrastructure provision must be a hard barrier to development unless it can be remedied before, or in parallel with, the development. It is not acceptable for it to be left to follow.

Healthy Communities
No comments.

Functional Clusters
The role of a village as the centre of a functional cluster (i.e. as a local hub for services) should be separated from the concept of a core village in relation to housing development, which should depend much more on employment and transport infrastructure considerations. (Q74)

Settlement Boundaries
The proposed redrawing of the settlement boundary for Bildeston is not appropriate and should extend only to the area of the Artiss Close development already constructed. Although planning permission for the remainder of the area ( "land east of Artiss Close") had been granted, at the cut of date of 31 March 2017 the permission was in abeyance due to a judicial review, and was quashed shortly afterwards. There was therefore not a valid permission at the cut off date.

Potential Land for Development
The site in the draft allocation off Wattisham Road (marked SS0278) is not suitable for development, especially on highway grounds. Closer to the High Street, Wattisham road is so narrow as to render it effectively a single track road, with passing only possible by encroachment onto private driveways. Visibility at the junction with the High Street is also very poor and the High Street itself is narrow. Improvement is not possible due to the close proximity of historic buildings. The fact that the site is some way from the village centre means there would be even more car traffic from the site. (Q78)
We suggest that an alternative site for allocation would be that of the former Taylor's Garage at the southern end of the village, which we have advocated for some time as the next sequentially preferable site for housing development in Bildeston. (Q79)

Conclusion
We hope that due account will be taken of our comments in developing a draft plan for further consultation.
We also take the opportunity to suggest that a better local plan should be accompanied by a better decision making process which is similarly visionary and fit for purpose. This should include meaningful engagement by the planning committee having proper regard to what is at stake, not just for communities but for applicants as well.

Bildeston Parish Council
8th November 2017


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