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Representation 11578 on BMSDC Joint Local Plan Consultation Document (Interactive) by Annette Powell

Support / Object: OBJECT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - Sproughton , SS0711 - Land east of Loraine Way
Representation: 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.

Original submission

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.


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