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Representation 11321 on BMSDC Joint Local Plan Consultation Document (Interactive) by Sproughton Playing Field (Damian Lavington)

Support / Object: OBJECT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - HOUSING, Housing Requirement, Q7
Representation: * 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
Complies with the duty to Co-operate?Yes

Original submission

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?


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