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Representation 12724 on BMSDC Joint Local Plan Consultation Document (Interactive) by Mr Bryan Fawcett

Support / Object: COMMENT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - Sproughton , SS0191 - Land west of London Road (A1214) and east of Hadleigh Road
Representation: 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.

Original submission

Hello, I am writing to you regarding the new joint local plan for the development of the Babergh District. I have tried to make comments on the web based consultation portal but found it so un-user friendly that have reverted to making comments by email. I am concerned that the web based consultation is designed to deter people from making comments or even objections as they will find it too difficult or confusing to respond. Please find below my comments and objections on the various areas of the plan to be taken into consideration as part of the consultation process.






Objectives
* Development needs to be balanced between homes and employment. There needs to be protection and enhancement of environmental assets that provide the villages with their rural identity. The identification and provision of necessary infrastructure and services needs to measured and appropriate resources allocated for their implementation before housing allocations can be made to induvial areas. There needs to be considered foresight to the plan. The provision of housing must be of the type that local residents need and can afford.
* There needs to be a radically improvement to the already strained local road networks. In Sproughton, where I live, the main through roads are severely congested every morning and evening with the village used as a cut through to the A14. At the times the Orwell Bridge is closed I cannot even pull off my own driveway. To travel to the end of my road, a distance of 50 m, can take an hour or more. There needs to be improvements to the A1071 at B1113 and Hadleigh Road junctions, and an access onto the A14.
Vision
* Development to be sustainable and this needs to take into account economic, social and environmental factors. Development needs to be in the right place, of the right type and which meets the local need. Whilst the proposed objectives appear to be sound there is a lack of clarity for their application. The vision needs to be based on the identified needs of the individual communities and villages within the Babergh district. Development must be sustainable and evidence provided as to how this be measured and applied. This must also into consideration the rights and needs of the existing residents of the district as well as the current social and economic concerns in the light of Brexit. The issue of infrastructure requires and its application across the whole of the district. Babergh is a rural district, there must not be a loss of the identity of the villages, of village life and the communities within them.
* There is a lack of clarification in how objectives will be determined and applied. Without specifics as to how the need for areas development will be measured and managed the objectives are meaningless.
Priorities
* The protection of the rural identity of the district, the protection of the villages and their lifestyle, protection or rural amenities and recreational space are objectives that all need to be defined within the plan. Development shouldn't lead to communities losing their identities by swamping and creeping coalescence.
* Location of growth to needs to be spread more pragmatically across Babergh rather than fewer large sites which will minimise the impact on individual communities and villages maintaining the rural lifestyle chosen by those who lives there.
* MOST IMPORTANT FOR MY VILLAGE SPROUGHTON - maintenance of the rural identity of the village, enhancement of environmental assets, transport infrastructure and roads , school places and accessible healthcare services.
*
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.
* Housing Requirement, Settlement Hierarchy and Housing Distribution


Housing Requirement 2014 to 2036 - Option HR1 - 7,820 new houses based on population growth.

The numbers appear over inflated, what account taken of effects of BREXIT on domestic and overseas migration?
What about the impact of relocation of major industries, effects of 'Northern Powerhouse and HS2?
The housing need has been calculated on a projected 1.03 persons per dwelling but in the past the average has been 2.3. Therefore by this calculated the figure of 7,820 is over-stated
Contingency and Delivery

Contingency sites need to be replacement and not additional, original sites need to be taken out of plan. There needs to be a regular review of demand required checking the guiding principles of type, tenure, place and local need.

Hierarchy

Sproughton is classed as CORE and also HINTERLAND village, it can't be both? Scoring is based on distance to services and facilities; it should be based on travel time as accessibility overstated. There is no account taken of capacity of a service in scoring for example capacity of the local primary school, number and nature of local shops. Sproughton has been 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. I would support reconsideration of the scoring criteria adopted to include fairly balanced negative scores for the threat of Creeping Coalescence.

Spatial Distribution

Four options have been 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. 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 will preserve the qualities of existing communities.


Other Distribution Options

I would support an option for proportional distribution and careful planned 'organic growth' of existing communities.
The expected Babergh population growth of 8000 by 2036 (9%) could be applied to each community - Sproughton to grow by 120 and therefore approx. 50 new houses to be built in the area to manage this. This will then 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. 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.

The proposition to create a new or garden town, a separate and distinct community in a new location can have minimal local impact but have the potential to improve/create improved county infrastructure/services. Obviously 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. Possible locations could include near to Gt Blakenham, South of Sudbury close to rail link, Somewhere between Belstead/Bentley and A12/Main Railway.

Housing Types

National space standards should apply with provision for storage. There is a requirement for provision of accessible homes and bungalows. Self Builds support local economy and rural outlook so should be encouraged. Provision is needed for affordable homes to include starter homes which are more appropriate to support growth of local community. With the ageing population in Babergh there needs to be policies that increase the provision of Bungalows and Accessible housing. It should be acknowledged that we are living longer, and the number of retired people selling high value houses in city areas migrating to the area. The ageing population is looking for bungalows but they will also need more care so there will be a need to increase health and care infrastructure.

Rural growth and development: Delivering growth, services and facilities in rural towns and villages.

Sustainable development needs to be 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. 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.


Economy

A clear oversight in the JLP is that the effects of Brexit has not been considered, either in trade, employment or migration calculations. The 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 this. 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.

Retail
The 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 is inclined towards town centre growth, however as a rural community this is impractical without improved parking or an efficient transport network. I 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 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. 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).


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 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 would support the retention of local landscape/environmental designations and the robust application of the present policies applicable to them. The JLP 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. This has the potential to be 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 could 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 I agree with the Infrastructure provision policy as set out. However, any developments MUST (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. It is 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. I 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.


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, 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. Greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments and more emphasis 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 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.


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

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.
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.
In relation to the identified sites and the appropriateness for allocation or inclusion within the settlement boundary- 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 however, once the net number of dwellings is calculated having taken into account planning applications granted, in progress etc. the 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. A much fairer basis for development would be a pro-rated approach with some tweaking for those settlements that are very small in size.
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.
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. This site sits on one of the busiest junctions in Suffolk and in an area of high air pollution due to the over use of the roads in the village as a means to cut through to Hadleigh and the A14.. It is a proposed development on a site of the village allotments, an amenity used by the village for recreational purposes, key in bringing together a diverse range of community for a joint purpose. Loss of this valuable area will be to the detriment of the village as a whole in terms of the loss of sense of community, the loss of a landscape key to the character of the village and loss of the rural identity of the location.
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 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.


I conclude with the fact that 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. This JLP is good for business as more housing will increase the unemployed pool making it easier and often cheaper to run a business, but that doesn't mean growth. But if house building is not matched by business growth it will not be good for the bulk of the resident population as there will be no increase in overall wealth in the community, but the community will be supporting a bigger population.


Regards
Bryan Fawcett





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