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Representation 11666 on BMSDC Joint Local Plan Consultation Document (Interactive) by Lady Valerie Hart

Support / Object: OBJECT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - Duty to Cooperate, Q6
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.
Complies with the duty to Co-operate?No

Original submission

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.
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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.
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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.
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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.
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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.
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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.
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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
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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.


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