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Representation 11906 on BMSDC Joint Local Plan Consultation Document (Interactive) by Mrs Julie Clark

Support / Object: OBJECT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - Sproughton , SS0223 - Land north of Burstall Lane and west of B113
Representation: 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.
Complies with the duty to Co-operate?Yes

Original submission

As a resident of Sproughton I would like to put forward my points of view on the proposals


SECTION 1 - STRATEGIC
Objectives
* Development balanced between homes and employment. Encourage inward investment, protect and enhance environmental assets, provision of necessary infrastructure and services, but emphasise provision of 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 junctions, and an access onto the A14. The B1113 is an Off Network Diversion Route but the road through the village is inadequate for that purpose.
* Ensure delivery of all necessary infrastructure / services (transport, schools, medical, open space etc) in good time and without back paddling -Planning needs to be pro-active on this.
Priorities
* Development shouldn't lead to communities losing their identities by swamping and creeping coalescence (merging of communities). i.e. Sproughton not totally joining boundaries with Ipswich,Bramford,Washbrook etc.

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.
o DON'T AGREE WITH THIS - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
o Relocation of major industries, effects of 'Northern Powerhouse and HS2.
o 10% uplift to increase supply/reduce sale price/increase affordability.
o 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
o Current 'stuck' sites with permissions and no building suggests need for contingency going forward - replace 'stuck' sites with others.
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.


Hierarchy
o Village status distorted by scoring system, influences development location.
o Sproughton classed as CORE and also HINTERLAND village, can't be both.
o DON'T AGREE WITH APPROACH TAKEN - scoring based on distance to services and facilities; should be based on travel time as accessibility overstated.
o No account taken of capacity of a service in scoring (eg Primary School/shops (Sproughton identified as having a P.O.!)
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.
o We would support reconsideration of the scoring criteria adopted to include fairly balanced negative scores for the threat of Creeping Coalescence.

Spatial Distribution
o 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%.
o 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.
o JLP to 2036 gives opportunity for bold, innovative and creative thinking but continuing the urban sprawl / welding / merging communities not the answer.
o Creating well planned, self-sufficient purpose built settlements with their own identities is and thereby preserving the qualities of existing communities.


Other Distribution Options
I would support an option for proportional distribution
o Propose carefully planned 'organic growth' of existing communities.
o 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.
o 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 question relates to Option 4 (New Settlement Focused) of Spatial Distribution
o It 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.
o 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.
o
o Some suggestions: Near Gt Blakenham, South of Sudbury close to rail link, Somewhere between Belstead/Bentley and A12/Main Railway.


* 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.

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 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). Does anyone know of a famous local artist?

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 i 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.
* I 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 developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities.
* I broadly support Policy OS2 but are concerned that this does not result in the 'watering down' of existing open space provision existing within communities.
* I support Policies NROS2 and POS2 in the protection of our Open Spaces.
* -In the case of Policy CF2 whilst fully supporting this, it is considered essential that any proposals to remove existing community facilities is supported by an appropriate formal assessment carried out in conjunction with the local community.
SECTION 3 - PLACE
Functional Clusters
* Functional clusters is a way of looking at the existing spatial geography based on how communities interconnect. The functional clusters then inform the settlement hierarchy. Classification for these purposes is relevant to determining the approach to planning.
* 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
* Settlement boundaries are used to identify where the principle of development has been established, a threshold of ten related dwellings is applied. land outside of this settlement boundaries is countryside.
* The JLP view is that they need redrawing to allow rural growth opportunities.
* 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.
* 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 simplisitic 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 abosrobed 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. 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 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:
Some observations to help inform any responses to individual sites in Sproughton.
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
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.

I look forward to your response.


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