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Representation 3402 on BMSDC Joint Local Plan Consultation Document (Interactive) by Mr John Kitson

Support / Object: COMMENT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - Duty to Cooperate, Q6
Representation: None identified

Original submission

I would like to lodge my response to the BMSDC JLP consultation document. Could you please confirm receipt of my submission and include me in the mailing list for updates on the progress of the JLP.
SECTION: STRATEGIC
Sub-Section; VISION AND OBJECTIVES

Q 1. What do you think the vision should be?
Generally as stated but with emphasis on certain areas outlined in the following text.

Q 2. Do you agree with the identified objectives? Please explain reasoning.
The Objectives seem to be appropriate but concerns exist regarding;
* Housing
Particular emphasis must be placed on providing housing that the local residents need and can afford to buy. Developers must be made to provide the Affordable Homes Tariff agreed at the planning stage.

* Economy
-In addition to supporting the "Ipswich Northern Route", steps must be taken to radically improve the road network in and around Sproughton, especially the junction of the A1071 and B1113, and the junction of the A1071 and Hadleigh Road. The designation of the B1113 as an Off Network Diversion Route serves to increase the importance of the need for these improvements.

-Any increase in the number of new homes and business premises in the locality, and indeed from further afield such as Hadleigh and Sudbury, will result in further increases in traffic volumes and delays at these junctions for both personal and business users especially at peak travel times.

* Environment
-Regarding the second bullet point; new development must avoid areas which are formal flood plains or have historically acted as flood plains. An example being the land between the A14 at Sproughton and the river Gipping, and the so called 'Island Site' behind the ex British Sugar site.

-We also believe the words "where possible" should be deleted to emphasize the importance of avoiding any increase to the flood risk that will undoubtedly arise if such areas are built on.

* Healthy communities & infrastructure
-It is essential that all necessary infrastructure services required to support proposed developments are delivered in good time and especially address the cumulative requirements arising from proposed developments in and around the Sproughton area.

-Whilst the District council themselves may not provide the infrastructure services, as the planning authority it should work pro-actively with providers to ensure that infrastructure needs are clearly understood and formal commitments are made to deliver them in good time.

Q 3. Are there other objectives which should be added?
o The road network in and around Sproughton is long overdue improvements to address the issues at the junctions of the A1071 with the B1113 and the A1071 with Hadleigh Road. The designation of the B1113 as an Off Network Diversion Route serves to increase the importance of the need for these improvements.

Any increase in the number of new homes and business premises in the locality, and indeed from further afield such as Hadleigh and Sudbury, will result in further increases in traffic volumes and delays at these junctions for both personal and business users especially at peak travel times.


o -To ACTIVELY protect and enhance the existing environmental assets.

o Whilst agreeing 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.

o Greater attention needs to be given to avoiding the 'swamping' of existing communities with excessive developments. More emphasis needs to be given to ensuring that any necessary developments are spread more evenly over the District as a whole, rather than being concentrated in particular communities.

Consideration needs to be given to adopting small scale developments as they create stronger communities and create opportunities for local builders employing local trades people using locally supplied materials and services.

o Broadly support Policy OS2 but are concerned that this does not lead to the 'watering down' of existing open space provision existing within communities.

Q 4. What should be a priority across the district area? (please state which district)
District = Babergh (Sproughton)

o The more pragmatic apportionment of the location of the required housing across the whole of Babergh.

o Ensuring that the infrastructure requirements associated with any new developments are formally identified, agreed and in place at the right time.


Q 5. What is most important for your town or village?
o The provision of the necessary Schools/ school places to serve the existing and increases in demand.
o Ensure that the necessary Healthcare services (GP, Home care, Optician, Dentist etc) are identified and in place as the demand for them increases.
o That the necessary improvements are made to the Highway infrastructure to mitigate the existing and future traffic volumes.

Sub-Section; DUTY TO COOPERATE

Q 5 (A). Do you agree or disagree with the identified key issues for compliance with the Duty- to-Cooperate for the Babergh and Mid Suffolk Joint Local Plan? Please explain why.
Generally agree with the issues for the reasons outlined in the consultation document.

Q 6. Are there any other key planning issues which need to be considered in accordance with the Duty-to-Cooperate? Please explain why.
None Identified

SECTION: - DELIVERY
Sub Section; HOUSING / HOUSING REQUIREMENT

Q7. Do you agree with the proposed approach set out under Option HR1? If not, please explain why and what alternatives you propose.
Not comfortable with this as the housing need identified in the Strategic Housing Market Assessment 2017 (SHMA) may well be overstated for the District during the life of the JLP. The report methodology uses historic patterns of migration, extrapolated forwards to arrive at a projected population growth, but no regard seems to have been had for the likely effects of BREXIT;
o Both domestic and overseas migration as a result of the UK leaving the EU in 2019.
o The intended tightening of immigration controls, which is likely to quickly and significantly reduce the amount of inward migration and significantly increase the amount of outward migration in the District further, almost at the same time as the JLP itself is adopted. These effects are likely to reduce the forecast need for new housing during the life on the JLP.
o Additionally, the potential relocation of major industries to continental Europe if a "hard" Brexit is the outcome of current negotiations is likely to further reduce demand for housing in the District and surrounding areas.
o Projected employment growth in the District is in the Professional and Business services sectors which may be especially vulnerable to relocation.


Given the uncertainty on Brexit and levels of overseas migration, and with emphasis on the "Northern Powerhouse" and HS2, outward domestic migration could increase significantly with employment opportunities being created along the HS2 corridor rather than in East Anglia. This would reduce demand for housing in the District still further.
These potential impacts are real and significant. The JLP must take the most likely possibilities into account and be based on revised data.


Q 8. When allocating sites what scale of contingency should be applied? Please explain why.
HD1 (Contingency)
It makes sense in a plan that is expected to span such a considerable period of time for there to be some contingency provision against identified sites that cannot, for whatever reason, be developed within the specified time. In such circumstances, the activation of a contingency site should permanently remove the original intended site from the plan. In other words, each contingency activated should be a replacement within the plan for an original site that could not be developed as planned, NOT an additional site for development.

Q 9. Are there any specific measures that could be included within the Joint Local Plan that would assist with delivery?
There should be a clear commitment to a regular review of the actual demand for housing against the forecasts for housing need and the JLP should be adjusted accordingly in light of this evidence.
The stated objective of delivering "the right type of homes, of the right tenure and in the right place meeting need" must be a guiding principle for every decision made by the council before and during the life of the plan. These words must be translated into action at every stage of the preparation and implementation of the plan, and used as a test at each stage of development. All four elements of the objective: type, tenure, place and need must be satisfied if the council is to hold true to its stated objective.
Regarding need, the council must be totally committed to providing only housing that meets the genuine needs of the residents of Babergh, not the needs of the housebuilders and their desire for profit.

Q 10. What factors or priorities should be set as triggers for reserve sites to come forward?
Replacement, not addition
Reserve sites should be considered when something prevents an originally-identified site from being developed within the intended time scale. If there is a need to bring reserve site(s) forward, these should be instead of, not as well as, the originally-intended site(s).
* Reserve sites should be considered when something prevents an originally-identified site from being developed within the intended time scale.
* If there is a need to bring reserve site(s) forward, these should be instead of, not as well as, the originally-intended site(s).


Sub Section; REVIEW OF THE SETTLEMENT HIERARCHY

Q11: Do you agree with the proposed criteria approach to rank settlements in the hierarchy? If not, please explain a suggested amendment or alternative.
In principle, the approach seems appropriate. However, it is unclear from the evidence whether account has been taken of the capacity of each Key and Supporting Service to deliver services in a community, or whether it is simply the presence of such services that has been scored when compiling the hierarchy. An example would be primary schools: the mere presence of a primary school in a community does not give any guarantees regarding availability of places at that school, as it may already be at capacity. This factor is especially important in the case of Sproughton which has few Key Services of its own. Here the assumption is that services located in Ipswich and elsewhere within 5 km are available to Sproughton residents, and a score of 2 and 1 is given for being within 5km of a Town and Core Village respectively.

Scoring for the hierarchy based purely on measured distance (i.e. 5 km) does not make sense. In many places, the time it would take to actually travel that distance would preclude the use of the services and facilities that might be there. A measurement based on time to access neighbouring facilities would be a more realistic measurement of how accessible such facilities were in practice.
Furthermore, accessing neighbouring facilities in the case of Sproughton would nearly always require the use of a car due to the lack of sustainable alternatives: safe cycle lanes, pedestrian footpaths and the frequency of public transport.

Note: Sproughton is classed as a "Core Village" in Table 2 (p6) of BMSDC Topic Paper: Settlement Hierarchy Review - August 2017, but as a "Hinterland Village" in the Appendix (Services and Facilities Matrix) to the same document.
There is no post office in Sproughton, yet it scores 1 for having a post office.
Overall the status of Sproughton is unclear and the actual facilities located within it and genuinely accessible in neighbouring settlements are overstated, casting doubt on the scoring in the hierarchy.

Q12: Do you agree with the proposed joint settlement hierarchy? If no, please provide further details as to how the hierarchy should be amended.
Please refer to comments @ Q11 above.


Sub Section; SPATIAL DISTRIBUTION

Q13: Which option(s) for housing spatial distribution is best? Please explain your answer.
Option: BHD4
The production of a JLP covering over 25 years of planning and development presents the Council with an opportunity to be bold, innovative and creative in its thinking. The consultation document acknowledges that national planning policy "encourages councils to consider whether growth could be accommodated through the planning of new settlements - either garden towns of villages.", and that "opportunities are available to bring in enhanced government investment funds to help plan and support these areas".

Simply continuing the urban sprawl, and relying on shoring up already overstretched local services in the hope that they can cope with increased demands lacks imagination. The creation of a new purpose built settlement or settlements, carefully planned with adequate and modern services and infrastructure, allows that community to establish its own unique identity rather than adopting someone else's, adding to diversity of the District's communities. It also adds greater value and attractiveness to those seeking new homes in Babergh. The creation of new settlements may not, of itself, lead to improvement of services, infrastructure, environment, biodiversity, etc. elsewhere in Babergh, but it is less likely to damage it whilst at the same time preserving as much as possible of what is already here and valued for what it is.

Q14: Are there realistic other broad distribution options which should be considered? Please explain your answer.
Carefully-planned organic growth of existing communities across the District.
This approach would provide the necessary additional housing without impacting so heavily or disproportionately on existing communities, preserving rather than destroying their unique identities. It could act as a catalyst to improve and update existing services, infrastructure and facilities for all Babergh's residents, on a scale that would be both acceptable and sustainable. It could accommodate new employment opportunities through small local enterprises, reducing the need for people to travel long distances to work, encouraging cycling and walking and reducing emissions. Such an approach, carefully managed, would enhance all those things which make Babergh a desirable place to live and work

Having more but smaller development projects would also impact positively on local employment, providing opportunities for local developers and associated construction tradespeople to bid for contracts to build.

Q15: If a new settlement was to be planned in the area, where should it be located? Please explain your answer.
* South of the A14, close to the A12 and rail links to London (e.g. Great Blakenham)
* For Mid Suffolk: North of Hadleigh towards Wattisham
* As close as practicable to a major trunk road and rail services
* Preferably on a "brown field" site





Sub Section; HOUSING TYPES & AFFORDABLE HOUSING

Q 16.Should the Joint Local Plan include a requirement for new dwellings to meet the Nationally Described Space Standards?
As the Nationally Described Space Standards are an updated version of the previous LA Space Standards then yes they should be followed. This should included built in storage space.


Q 17. Do you have any views on the proposed approach towards self-build and custom build dwellings?
If BDC encouraged those with existing planning permissions to build it would reduce the overall number of houses required. Some of these existing planning permissions will include self builds so should be supported.


Q 18. What should the Councils' approach to Starter Homes be?
As the government expect starter homes to be sold at a discount of at least 20% below market value and be on brownfield sites so must be part of the range of houses built. BDC need to ensure that just because they are started homes with a maximum sale cost of £250,000 they don't need to be built on substandard sites or sites less attractive to the developers.


Q 19. Should the Councils be prioritising the provision of any particular types of homes?
Well designed, well constructed affordable homes at mid to low range prices. The developers should not be supported or allowed to only build houses that provide them with the greatest profit.


Q 20. Are there any other types of housing that should be planned for / required?
Single storey homes for older people, wheel chair users and disabled people. These require ease of access both inside and outside.


Q 21. How can the Councils promote / facilitate development of homes for private rent?
Encourage and support housing associations, particularly for people with mental health, learning disabilities or other special social needs. Homes for social rent (rents set about 50% below market rents) should also be encouraged.


Q 22. In relation to affordable housing, do you consider the requirement should be set at a percentage other than the current 35%? If so, please provide reasons.
BDC have previously planning permissions for much lower % of affordable housing. This practice must cease and the 35% adhered to.



Q 23. To what extent should affordable housing be (or not be) prioritised over provision of other infrastructure where viability is an issue?
The infrastructure, schools, roads, GP and dentists, health, care and leisure facilities should be a priority regardless of the type of houses being build. Village communities should be encouraged and maintained.


Q 24. In relation to affordable housing, should there be any preference for housing to accommodate key workers?
No not necessary if an appropriate range of houses is provided.

Q 25. If Option RE2 is supported, what maximum percentage of market housing should be acceptable?
35% affordable housing 10% starter homes, as for planning purposes these cannot be considered as affordable housing....leaving 55% for the market.


Sub Section; RURAL GROWTH AND DEVELOPMENT


Q 26. Which option for the policy approach to rural growth do you think is most appropriate?
* Possibly RG2. However, it could go further if you support rural development at a proportionate level.

Q 27. Are there any other approaches to distributing development in rural areas that we should consider?
* Why limit development to Hamlets of 10 or more.
* One new home in every ten is close to the 9% housing need identified.
* Provided proportionality and design sympathetic to the character of other buildings and the landscape was employed proportionate development would appear to be what is fair and needed.
* Families have children who grow up and start their own families.
* Generally that happens to us all so why should the burden of development not equally fall on us all.
* But wherever it falls it should be done with every effort made to preserve the best of the local landscape, views and ecology.

Q 28. Do you support the approach proposed for hamlets? If not please explain?
* Yes, but as in Q27 above it may be better not be restricted to Hamlets of 10 houses or more.


Sub Section; ACCOMMODATION NEEDS OF GYPSIES AND TRAVELLERS


I have no observations to make in respect of questions 29 - 32
Q 29. What should the Councils' approach to provision of negotiated stopping places be?
Q 30. Please submit details of any sites, or extensions to existing sites, which you consider are suitable for allocation as Gypsy and Traveller sites or Travelling Showpeople sites.
Q 31. Should the Joint Local Plan include a policy which identifies areas where moorings would be acceptable in principal?
Q 32. If so, are there any specific locations where additional moorings could be located?

Sub Section; ECONOMIC NEEDS

Q 33. Should we continue to identify existing employment areas and protect land and premises in these areas from redevelopment/conversion to other uses unless marketing evidence demonstrates there is no demand for employment use?
Within Babergh District, Option ECON1 would appear to be appropriate given the ample employment land at the former Sugar Beet site in Sproughton. Not sure of the situation in MSDC area.

Q 34. If we continue to protect existing employment areas, which areas should be identified?
Sites that are strategic in respect of anticipated commercial need. There have been huge changes in industrial practices in recent years and this will undoubtedly be the case going forward. Consequently, it will be difficult to predict need

Q 35. Are there any existing employment areas that could be reallocated to other uses?
Brownfield sites which are unlikely to be used in/suited to the needs of new technologies or where the lan would be more appropriate for residential development


Q 36. Should we identify areas where non-B class uses, such as car showrooms, tyre and exhaust centres and building material stores, can be located?
Probably best located in out of town retail park areas which would help reduce congestion in town centre retail areas.

Q 37. Should there be a policy that allows a wider range of uses than just B class on all employment sites or selected employment sites?
We are living in a changing world with many unknowns ahead of us. As a nation we are going to have to become more adaptable to meet the challenges; aspects of planning are going to have to become more flexible.


Q 38. Should we allocate more than enough land to meet the forecast needs to enable more choice in the market and give flexibility to changing circumstances?
Yes, flexibility and adaptability will be key in the coming years. A modest surfeit would seem sensible.

Q 39. Should we make specific employment provisions for small and medium sized enterprises? If so, how and where?
Yes. Re-purpose existing unoccupied commercial/industrial units with a view to making modifications to meet the likely needs of SME businesses. There will need to be a strong infrastructure in place (telephone and broadband, transport for employees and goods, etc)

Q 40. If we expand, or allocate additional employment land where should these be?
This would depend very much upon why you want to expand and what market you are trying to support.

Q 41. What approach should we take to supporting new business formation across the Districts?
New businesses often need assistance to locate buildings or sites that are available. District councils are in a position to provide a support service (say through Planning ) to help identify appropriate premises in different locations and possibly more (e.g. suppliers, support services).

Sub Section; Town Centres and Retail

Q 42. Do you consider that any of the sites put forward as part of the Call for Sites should be allocated for retail or commercial leisure use? Please state why
With regard to the Sproughton area, I would say probably not. It is, however, interesting that this group includes leisure activities like gyms. There are a number of such businesses around Ipswich on out of town sites which seems to suggest that as being the preferred position

Q 43. Are there any other sites that should be considered for retail or commercial leisure use?
No

Q 44. If you consider allocations for retail development should come forward as mixed use, please provide details.
No comment offered

Q 45. Do you agree with the proposed Town Centre boundaries, Primary Shopping Areas, Primary Shopping Frontages and Secondary Shopping Frontages? If not, please explain why.
Yes but perhaps D1-D2 should be grouped outside these areas in leisure parks or Retail Parks

Q 46. Do you agree with the approach to not define Primary Shopping Area boundaries within settlements other than the three main towns? If not, please explain why.
No at least not where a primary shopping area is already developing and has the potential to develop both with suitable buildings and parking/transport to support its development.
Where there is no defined shopping areas in smaller towns etc perhaps it is best for enterprise to be allowed to develop and find its own best shopping centre.

Q 47. Do you agree with the approach to maintain and increase retail provision within the District Centres? If not, please explain why.
Yes, but as retail needs to develop the type of retail that people want. Should be subject to local requirements.

Q 48. Do you agree with the proposed thresholds relating to the mix of uses within Primary Shopping Frontage? If not, please explain why.
D1-D2 activities would probably be better grouped outside the main retail centres of towns to create Leisure park areas etc

Q 49. Do you agree with the proposal to require an impact assessment for all edge of centre and out of centre retail proposals that are 400sqm gross floorspace or more? If not, please explain why.
Yes an impact assessment should be undertaken due to traffic and impact on ensuring the prosperity and provision of a good town centre. But perhaps the level of 400m2 should be set to be proportionate to the size of the town centre. So for instance in a small town 400m2 may have a dramatic impact but on the outskirts of Ipswich the NPPF threshold of 2,500m2 gross floorspace would be more appropriate.

Q 50. The Councils propose to protect A1-A5 uses in Core Villages and Hinterland Villages, and in local centres within towns. Do you consider this to be the correct
This would appear to be an appropriate policy

Sub Section; BIODIVERSITY

Q 51. Do you have views on the Option BIO 1 and / or BIO 2?
* BIO2 appears, with some reservations, to be the better option.
* The concept of linking biodiversity at a landscape level in the context section is encouraging. Too often green corridors are nothing but a narrow footpath.
* Most of Babergh is private land without public access. Biodiversity often only comes to notice once access to public or detailed surveys are undertaken. A prime example is Wolsey Grange where the Suffolk Biological Records Office had 5 recorded wildlife sightings in 20 years which is clearly farcical.
* Local area/spot designations like Special Landscape areas, view points, wildlife, flora and fauna reserves etc. have evolved from many years experience, 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.

Sub Section; CLIMATE CHANGE

Q 52. How should the local plan consider the impact of renewable technologies? What types of effects should be assessed within the policy criteria?
Visual impact and avoidance of intrusion (e.g. noise, reflection/glare/flashing) are major considerations & most frequently associated with moving machinery typically wind turbines. Steps should be taken to avoid equipment that can produce these unwanted effects.

Solar Farms can be sited where they have little or no visual impact on the landscape but there is a downside from the potential loss of food production.

The consultation document recognises that: local planning authorities are required to '... adopt proactive strategies to mitigate and adapt
to climate change'; and that the planning system should 'support the transition to a low carbon future in a changing climate...and encourage the use of renewable resources (for example, by the development of renewable energy)'.

These principles should be at the core of any policy criteria. That is to say the Policy should take a proactive approach to the development of renewable energy, not only in terms of stand-alone sites, but also to retrofitting on existing buildings and integration into new build. It is quite right that renewable energy installations need to be sensitive to the landscape and minimise visual impacts. However, such matters should not be used to override the required "proactive approach".

When considering the new build of larger groups of houses and other buildings there are many benefits from collective energy (power and heat) schemes. This can involve community heating schemes and, through small scale micro-grids, localised electricity generation, storage and distribution schemes. The technology is changing fast here, as are the cost / benefit ratios, and the Policy needs to be flexible to recognise this.


Q 53. Do you support the Council's initial preference to include water efficiency measures in new build? If no, please explain why?
Yes, especially given the fact that this area has one of the lowest rainfalls in the UK.

Q 54. Are there any other additional environmental standards Babergh and Mid Suffolk should be requiring? If so, please provide details and reasons why.
The consultation states that: when setting any local requirement for a building's sustainability, do so in a way consistent with the Government's zero carbon buildings policy. My understanding is that the Government's zero carbon buildings policy no longer exists.


The consultation recognises the March 2015 Ministerial Statement that enables local planning authorities to require energy efficiency standards that exceed Building Regulations provided these do not exceed the requirements of the level 4 of the former Code for Sustainable Homes. Perhaps this option should be incorporated into the Local Plan.


Whilst Babergh and Mid Suffolk may not be a major flood risk area, there have been recent examples of localised "flash" flooding and this feature must be taken into account. More extreme weather conditions can be expected as a result of climate change and everywhere is going to be more susceptible to localised 'flash' flooding. This can be ameliorated through the use of sustainable urban drainage (SUD) schemes which should be incorporated in the Local Plan.


The possibility of significant attenuation ponds, capable of holding weeks or months of rainfall rather than daily events would not only reduce flooding risks but provide flow to rivers during dry seasons and could also be feeds for pumping to reservoirs either directly or indirectly from river pumping points. This would improve the critical water supply capability of this area.


Like reservoirs these larger attenuation pools have all the possibility of supporting new biodiversity, fishing and other activities as a social benefit. As such the provision of new green activity facilities like this would help to reduce the public need to visit the SSSI / AONB sites which would be a benefit to them.

Q 55. Are there any other approaches that the Joint Local Plan could take to protect the landscape?
Yes. It could agree:
* to consult specifically on landscape impacts of developments more closely with local parishes at an early stage.
* to apply the policies even-handedly regardless of developers size or financial influence.


The size of the business should not be the criteria, but rather the impact. It is a simple fact that a single house may add to the richness of a landscape whereas an estate could completely destroy it no matter how well it is integrated. It would be inappropriate to enforce landscape policies on small or single builds that have little impact but apply different criteria for a big developer.

Q 56. Should additional protection be given to areas which form part of a landscape project area but which aren't designated?
It should be judged like any other landscape and, if appropriate, given the appropriate designation.


Q 57. How can the Joint Local Plan make the most of the heritage assets?
By ensuring the Planning Departments have the necessary policies together with the authority to apply and enforce them (in spirit as well as word).


Q 58. What level of protection should be given to identified non-designated assets? Are there any specific situations in which the balance should favour or not favour protection of identified non-designated assets?
I suspect in most cases these will be identified via Parish Councils. Each individual asset would probably be different and it would be best to consult and negotiate with the Parish Council involved.


Q 59. Should a more flexible approach toward climate change objectives be adopted where this would assist in protecting a heritage asset?
If there is a clear defined heritage asset that may be compromised by enforcing some climate change policies then the planning department should have some scope to ensure the asset is not spoiled.

Sub Section; LANDSCAPE, HERITAGE AND DESIGN

Q 60. Is there any aspect of design that priority should be given to?
The typical Suffolk country side is dominated by diversity in design. This has occurred due to the passage of time but also because most building has taken place on small scales. The Suffolk Design guide does not really address this aspect of the counties character and it is at odds with the objectives of large developers who wish to standardise most of their designs and materials based maximised returns. Typically you can drive into any developer's estate in England and they all look the same.

Even in an estate development much more could be done to preserve the local character and provide visual interest and a village atmosphere. Perhaps a design policy worthy of inclusion would be for estates to be divided up into small design cells of around ten homes like hamlets, and each cell should be sufficiently different as to give the impression of being built by a different developer, and even built in a different period. This would match the character of our county.

Q 61. Is there any aspect of design that should be introduced to the Councils' policies?
All development should be designed to blend into the countryside, protected or not, the dominant visual features should always be the landscape that existed before the development, not the development itself.
As suggested in Q60 developments of more than ten houses should be grouped into cells of ten homes like hamlets and each cell should be of such construction and design and separated sufficiently as to create the visual impression each cell was built by a different developer at a different time. The effect is to create small but strong social groups but specifically a housing mix that matches the character and typical disposition of homes in the Suffolk Countryside.

Q 62. Is there an area of design related to past development that you consider needs to be addressed in future development?
Probably the Wolsey Grange application which had three story townhouses around its perimeter which would dominate the skyline both from the Chantry Vale valley, Chantry Park and the surrounding countryside. Apparently the developer did this to make the development a statement. The Suffolk one collage is similarly dominant. These are conceited and selfish aims completely at odds with the special landscape policy for that site, and the council aims to preserve the best of our views and landscapes. It is quite a disappointment to gaze around the green Suffolk countryside and have your vision drawn to a big white square building set on top of the biggest hill.

Sub Section; INFRASTRUCTURE
Q 63. Which option do you consider most appropriate? Please explain why?.
Would fully support INF 2 for the reasons stated in the document but with the condition that all formally agreed infrastructure agreements are adhered to.

Q 64. What do you consider the key infrastructure issues in your community?
‒ Education ‒ Highway infrastructure
‒ Health services ‒ Flood risk management and resilience



Q 65. What infrastructure issues do you consider to be a priority for the future?
- Education
- Health services
- Public Transport and highway infrastructure
- Water and drainage
- Energy provision
- Improvements to digital communications
- Leisure facilities and green infrastructure
Q 66. What infrastructure do you think would be needed to support the growth scenarios?
o The Ipswich Northern Route Project
o A12 and A14 road improvements
o Highway improvements to the commuter routes into/out of Ipswich from the Districts, especially the A1071 and B1113
o Rail network upgrades
o Flood management and alleviation
o Upgraded household waste recycling provision
o Better Broadband for Suffolk, both basic and enhanced services
o School places in the form of expanded or new primary and secondary schools- location to be determined.
o Healthcare infrastructure such as ensuring there are the necessary numbers of GPs and Dentists and their associated surgeries to support both the current and the planned population increases.


Q 67. What comments do you have on the proposed strategic approach to infrastructure delivery?
The first paragraph under Managing Infrastructure Provision heading reads "Planning Permission will only be granted if it can be demonstrated that there is, or will be, sufficient infrastructure capacity to support and meet all the necessary requirements arising from the proposed development."


COMMENTARY
Planning permission should only be granted if there is some form of guarantee that the infrastructure services WILL BE delivered or the necessary funds are ring-fenced to ensure the cumulative infrastructure needs arising from existing and new developments will be completed in good time.


Q 68. Should a separate policy be developed to manage provision of education and healthcare?
Yes

Sub Section; HEALTHY COMMUNITIES
Q69. Should the strategy of the Plan be focussed on addressing deprivation?
The strategy of the Plan should be flexible enough to address deprivation and additional social issues which will arise during the lifetime of the document; for example the needs of an increasing elderly population.



Q 70. Are there any specific approaches that should be applied to address deprivation?
These should be further developed in the light of any issues that arise or change as we move through the Plan period. For example, it is impossible to predict the approach necessary to deal with any BREXIT issues and therefore the Plan needs to be flexible enough to mitigate these.


Q 71. Are there any other circumstances and / or provisions under which open space, sports facilities or community facilities should be required and / or protected?
I believe the areas highlighted in the Plan need to be protected and preserved going forward


Q 72. Through the Plan should any other areas of Local Green Space be identified and protected?
Flood plains could provide areas of open recreational space (without structures or equipment) that would be available for a majority of the time for community use.


Q 73. Are there any specific facilities that should be included in the definition of community facilities?
The work currently being undertaken by the Councils should identify the need for any additional facilities.

Sub Section; FUNCTIONAL CLUSTERS


Q.74 Do you consider the approach to identifying functional clusters appropriate for Babergh and Mid Suffolk? If not, please explain what would be your preferred approach?
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


Q.75 Do you consider the proposed new settlement boundaries to be appropriate? (please explain your answer)
No, the settlement boundaries are not appropriate. 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.


Q.76 Are there any other settlements that should be given new settlement boundaries? (please explain your answer)
Not that I am currently aware of


Q.77 Is the threshold (10 well related dwellings) for identifying settlement boundaries appropriate?
No. A 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.




Q.78 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 ie. SS0001)
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 Sproughton being absorbed by Ipswich in the same way that Kesgrave and Rushmere-St- Andrew has been. Not so much 'creeping coalesence' 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.



Q.79 Are there any other sites/areas which would be appropriate for allocation? (If yes, please provide further information and complete a site submission form)?
No additional sites within the Parish of Sproughton.


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