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Representation 9718 on BMSDC Joint Local Plan Consultation Document (Interactive) by Miss R P Baillon

Support / Object: COMMENT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - HOUSING, Rural growth and development, Q27
Representation: Yes. Open meetings together with Parish Councils should be held in the settlement concerned to obtain the views of the inhabitants and the results of these meetings should be presented to the Councillors who come to the settlement in question. Even if Council members visit settlements on several occasions they will never be in a position to imbibe the current situation as seen by the inhabitants.

Original submission

It is hoped that Mid Suffolk residents' opinions will be taken into account when finalising the Joint Local Plan particularly as it is well known that, in the past, little notice has been taken of the comments made by the Parish Council and individuals regarding the developments taking place in Debenham.

In the case of the named development, 'Market Pyghtle', comments from the Parish Council and individuals were not taken into account and four large houses which are out of all proportion to the size of the site involved have been built with minimally sized gardens. This is interesting when the word 'pyghtle' is an Anglo-Saxon word meaning a 'small plot of land'. So presumably, the developer realised the site consisted of a small area and yet submitted plans for comparatively large houses and was granted permission to build them. In relation to this, I understand there was a competition in the Primary School to provide a name for the site and residents from the village also contributed. Despite these suggestions, the developer appears to have had his way regarding the name of the site. Also, of course, one house is in Chancery Lane, another in Great Back Lane and two in The Butts, each could have been given a number in its respective road.

No suitable houses or apartments were built for first-time buyers on this plot. Not only that, a flint wall of several hundred years was knocked down with the statement that its foundations were not safe. This must have been obvious given that the developers had had to clear the site of contamination and thus inevitably made the wall unstable due to the necessary work carried out on the soil adjacent to it. Instead of this historic wall being replaced, a brick wall with some flint inlay and railings have been built which in no way represents the original wall. This not only does not respect historic constructions but indicates that developers can get away with what is not possible for a householder and is inappropriate in the circumstances. Also, in this case it enables the developer to sell the remaining flint. Thus the developer will make several thousand pounds due to the reduced skilled labour involved in the construction of the new wall and railings and the flint sales. Also, the fact that the gardens are extremely limited and there is a large paved area, there is no immediate drainage and therefore rainwater will tend to collect and create the possibility of flooding.

With regard to The Cherry Tree development, again the developer has not adhered to the planning permission. For instance, the cellar, an integral requirement for a pub, has been filled in and cemented over and yet nothing has been done by the Council about this.

There have been strong comments about the proposed development off Little London Road and one wonders how much notice will be taken of both the Parish Council's recommendations and the comments from residents who know the area well as they live near the site. It would be interesting to know how many staff in the Planning Office of Mid Suffolk Council have been to the site and researched the area carefully over several days and at different seasons of the year. Also, it was extraordinary to see that some of the accompanying reports to the planning documents contradicted one another. On 12 October there was an accident outside the school between the school bus and a Land Rover and a child had to be taken to hospital. This demonstrates the traffic problems in this area which many residents have commented upon.

1. What do you think the vision should be?
The Council does not state what their vision is for Mid Suffolk, only mentioning that the Joint Local Plan needs 'to set a spatial vision'. A 'spatial vision' is very restrictive as there are major historical and ecological components which should be included in the vision. The identified objectives must be based upon the vision. Therefore, it is paramount for the Council to state their vision if the objectives and the rest of the document are to relate to it.

Mid Suffolk is a rural area with many of the towns and villages containing significant historical buildings and areas of natural habitat. It is important that these aspects of the county are maintained and cherished as an asset to the region and be seen as a backdrop to the Joint Local Plan. The vision for the area should be to enhance the current settlements, to regenerate some regions, eg Stowmarket town centre, within Mid Suffolk, and to create more housing in the style of the region, avoiding despoiling current towns, villages and hamlets and encourage innovative businesses with the necessary incentives to provide local employment and to enrich the countryside with its many areas of environmental biodiversity. At the same time, pioneering ideas should be developed to provide the necessary amenities and infrastructure within the region; this is being recognised as an important element for the wellbeing and health of the inhabitants.

It is noted that in Mid Suffolk, the main towns are designated as Eye, Needham Market and Stowmarket. However, elsewhere in the document, Appendix 1, under the Town Centre Maps, Debenham is classed as the main settlement in a 'Functional Cluster', with 19 settlements classified within this cluster. This is many more than other settlements, eg Framlingham which is a town. In no way can Debenham be classified as a town; it has few shops and increasingly inadequate amenities and infrastructure given the developments in recent years.

2. Do you agree with the identified objectives? Please explain reasoning.
I do agree with the objectives that have been identified. However, I do not feel that these objectives have been met until now so I hope they will be in the future. To fulfil these objectives, considerable research needs to be carried out to identify ways of fulfilling them within the culture of the towns, village and hamlets. Appropriate people need to be consulted - not large consultancy firms whose staff are often not skilled in the type of research which is required in these circumstances. With regard to the environment, far more care and action needs to be taken. In some areas of the country, Councils and developers are working with the Wild Life Trusts to provide a holistic way of building to avoid damage to protected sites and working with the natural surroundings to create gains for nature and better health and well-being for residents. (See www.wildlifetrusts.org/housing)

Recent research at the universities of Illinois and Glasgow has confirmed that natural scenery can be a useful tool to help reduce psychological stress and that spending time in natural environments have positive psychological benefits by stimulating relevant hormones. Particularly being around trees and grass lowers brain stress levels. This should be taken into account when planning developments. The way in which the 'Market Pyghtle' in Debenham has been developed does not allow for trees to be planted and there will be minimal space for grass to be laid down thus providing a sterile environment for the inhabitants and those living in the vicinity.

3. Are there other objectives which should be added?
Yes. Education; nursery, primary, secondary and tertiary. Currently, in Debenham there are parents who cannot obtain a place for their children in the senior classes of the primary school and have to travel elsewhere for their child's education.

Also, within the environment objective, the aspect of flooding needs to be addressed continually. This is especially the case as since the last big flood in the village in 1993, more houses have been allowed to be built in low lying areas of the village and there are 248 properties officially assessed as at risk of "fluvial floods". I know that the Debenham Holistic Flood Alleviation Project has been set up with collaboration between the Environment Agency, East Suffolk Drainage Board, Essex and Suffolk Rivers Trust and SCC. However, this is dependent upon more Deben Valley landowners becoming involved in the project (Debenham Parish Magazine, November 2017, page 5).

In Debenham due to the previous severe flooding and the pressure of new building sites, particularly in flood plain areas, eg at the lower end of Little London Road, flood risk needs to be researched further before further building takes place. I do not agree with the statement: '...and reduce future flood risk where possible.' Any development must ensure that flood risk is reduced. Professor David Balmforth of Imperial College and President of the Institute of Civil Engineers has spoken about sustainable drainage systems. Indicating that paved over areas prevent drainage and therefore water collects with the result of the greater possibility of flooding. This is likely to be the case in Caterham, Surrey, where flooding has taken place in the lower slopes of hills where new developments have been built higher up the hill. Professor Balmforth stresses the need for full investigations to be undertaken and old sewers and surface water drainage systems to be replaced.

Paul Cobbing, Chief Executive of the National Flood Forum, has also reiterated the importance of thorough research in the planning of developments to avoid flooding in areas that have been free from flooding for years due to measures that have been implemented in the past.

While water quality is mentioned, there is no indication concerning increased requirements for sewage, electricity, telephone and broadband connections. These are vitally important aspects of development which should be considered at the planning stage.

In conjunction with this, all brown field sites need to be investigated and used for development and long-term empty dwellings need to be utilised.

4. What should be the priority across the district area? Please state which district.
Debenham core village: As I live in Debenham, I can best contribute an opinion about this village. Due to past building projects and current building developments the population of the village has grown significantly resulting in the village being in dire need of improved amenities and better infrastructure. Maps of the village depict the enormous development on all sides of the historic, core village which demonstrates an imbalance of development.
* the schools are oversubscribed;
* the doctors surgery is in need of expansion due to the number of patients. Regularly, one has to wait several weeks for an appointment;
* traffic needs to be controlled within the village: huge lorries thunder through the village, often at speed; there are insufficient parking facilities near the Coop and, during term time, there is parking near the schools which daily causes significant problems on weekdays.

Also, the issue of potential flooding with further building projects needs to be addressed by carrying out thorough research. See comments under No.3.

5. What is most important for your town or village? (page 13)
For the core village of Debenham the most important aspect for the future is the development of an adequate infrastructure and facilities for the current population and those who come into the village from neighbouring villages and hamlets where there are no facilities at all. This needs to be addressed if further developments are to take place. The amenities and infrastructure for the area needs to be planned carefully to allow for a positive quality of life for the current residents and should new residents come to the village in the future.

There needs to be continual upkeep by the Council and Highways Agency in their various spheres of responsibility to maintain the village adequately.

5a. Do you agree or disagree with the identified key issues for compliance with the Duty to Co-operate for the Babergh and Mid Suffolk Joint Local Plan? Please explain why. (page 16)
I agree with the strategic polices listed (1-5) on page 14. However, it is the responsibility of the Council to ensure that there is full compliance with the Duty to Co-operate.

6. Are there any other key planning issues which need to be considered in accordance with the Duty-to-Cooperate? Please explain why.
Different areas of Mid Suffolk need to be analysed so that aspects of the Duty to Co-operate that have not been fulfilled are dealt with fully before new projects are undertaken.

7. Do you agree with the proposed approach set out under Option HR1? If not, please explain why and what alternatives you propose.
I do not agree with the Option HR1. The allocation of sites should be carried out with due research. Reserve sites could create problems if the general infrastructure is not addressed prior to any further development. Where houses are currently being built in some towns and core villages considerable problems are arising due to lack of facilities and infrastructure thus ruining the places, eg Alderton, Gloucestershire, Framlingham, Suffolk/.

8. When allocating sites what scale of contingency should be applied? Please explain why?
This would be dependent upon the area in question. In some environments there will be greater capacity than others. For the core villages such as Debenham there are a very limited number of sites for development given the historic core village, the comparatively new developments and the current infrastructure.
To cope with the problem of contingency and having an adequate number of sites, perhaps a new garden city should be considered. This garden city could be built near the centres of work and be planned with innovation and flair. Not only could the building of a new town address the number of houses required to be built but would also preserve the current towns, villages and hamlets which are steadily being spoilt. The Ebbsfleet garden city in Kent is a current example and plans are depicted on the website www.kentonline.org.uk. Any such development would need to located near to rail and road links.
9. Are there any specific measures that could be included within the Joint Local Plan that would assist with delivery?
Yes, as mentioned in No.8, the building of a new garden city. Perhaps the Babergh and Mid Suffolk Councils could collaborate to explore such a suggestion.

10. What factors or priorities should be set as triggers for reserve sites to come forward?
Brownfield sites should be explored for reserve sites and possibly run-down industrial sites and disused airfields. In some cases, perhaps airfields with limited current use could be amalgamated and the land used for building a village or town from scratch. This would allow the amenities and infrastructure to be incorporated at the start of the development.

With regard to the building of more houses and generating employment opportunities it might be worth considering more inventive ideas. During the programme on Channel 4: Is Britain Full? Michael Buerk investigated the differing population percentages in the south, particularly London, and in the north, particularly Liverpool. London is becoming over-populated while Liverpool has whole streets with houses boarded up and a decreasing population. The northern towns need radical redevelopment with employment opportunities being created. In conjunction with this, good transport links between northern towns and southern towns, especially London, need to be created. Perhaps councils from the north and the south need to co-operate and explore ways of making positive conditions out of this discrepancy in the population distribution. Suitable 'twinning' between councils could be investigated which could benefit both areas of the country. Collaboration between councils and genuine research institutions as in universities rather than consultancy firms could well help to propose some inventive ideas to help solve the problems.

11. Do you agree with the proposed criteria approach to rank settlements in the hierarchy? If not, please explain a suggested amendment or alternative.
Generally yes.

12. Do you agree with the proposed joint settlement hierarchy? If no, please provide further details as to how the hierarchy should be amended.
I agree that Debenham should be classified as a core village. I am not in a position to comment of many of the other designated core villages.

13. Which option(s) for housing spatial distribution do you think is the best? Please explain your answer.
The percentages given in each area appear to be arbitrary. While one can classify the variously sized settlements, this is just a manmade classification. Urban areas, market towns, core villages, hinterland villages and hamlets all vary in their composition and this needs to be taken into account with careful consideration so as not to destroy the individuality of the settlements.

I think that a new settlement area would be the best option, ie a garden city development. This avoids over-development in core villages, hinterland villages and hamlets. One is seeing the destruction of the character of towns such as Framlingham (not mentioned in the lists on page 25) with the overdevelopment of building projects where houses are being built extremely close together with practically no gardens and a considerable area of road/pavement which does not allow for infiltration into the soil. Also, there appears to be no development of amenities and infrastructure. The current build indicates the need for recreation areas etc.

14. Are there other realistic broad distribution options which should be considered?
Yes. There needs to be greater flexibility as to where new developments are to be located, taking into account the region and established settlements. Settlements listed as Settlement Categories are not all similar so percentages for district growth should be explored for each settlement.

15. If a new settlement was to be planned in the area, where should it be located? Please explain your answer.
If a new settlement is to be planned there needs to be considerable research carried out to ensure that it is placed in a viable area, near to transport facilities and job opportunities. If there is a comparatively large brownfield site, this could be a starting point. Careful planning would need to take place to ensure that the town had good facilities and transport links covering the needs of the intended population with good transport links. If there was a brownfield site, eg disused airfield, run down industrial area, this could be utilised. A good example is the current large-scale development in the City of York. Ideas could be gleaned from the www.kentonline.org.uk website concerning the Ebbsfleet Garden City.

16. Should the Joint Local Plan include a requirement for new dwellings to meet the Nationally Described Space Standards?
These standards should be enforced. In the Space Standards for Homes RIBA Report a variety of problems are given, eg Local Authorities will struggle to set the new space standard as it is over complicated, costs too much and will take too long. They have suggested that the government should create a fair housing offer by embedding the Nationally Described Space Standard in building regulations. However, it is important that new dwellings have reasonably sized rooms rather than the occupants being cramped which is not compatible with stress-free living.

17. Do you have any views on the proposed approach towards self-build and custom build dwellings?
It is not clear what the proposed approach is towards self-build and custom built dwellings. Where permission is granted for these dwellings the plans need to be rigorously explored and then the development needs to be monitored carefully so that the plans are adhered to and that the buildings are of a design that is appropriate in the designated area.

18. What should the Councils' approach to Starter Homes be?
The Council should be promoting the building of Starter Homes for first-time buyers under the age of 40. It seems extraordinary that when the Parish Council proposed the building of starter homes on the now named site 'Market Pyghtle' in Debenham, the developer was given the go ahead to build 3 and 4 bedroom houses with practically no gardens. It is important that Starter Homes are built and an arbitrary percentage figure should not be used across the board. There should be a mechanism whereby first-time buyers from each settlement could put their names forward so that at least a realistic number of homes could be considered. There are some young people who would ideally like to have a home with a reasonable garden in a hamlet whereas others might prefer to be in a larger settlement with amenities and good public transport links.

19. Should the Councils be prioritising the provision of any particular types of homes?
Yes, both starter homes and homes for the elderly who are having to move to more appropriate housing should be prioritised. The latter should be custom-built.

20. Are there any other types of housing that should be planned for/required?
Yes, there should be homes similar to those built in Chelmsford city centre for the homeless as interim homes. Suitable sites could be chosen in towns and they would help to prevent vulnerable people having to sleep on the streets. This would enable organisations that help the homeless to be in a position to help and monitor the occupants. In a country such as ours, it is scandalous that we have people sleeping on the streets particularly when we have a section of society who are vulgarly rich, many of whom have several luxurious properties both in the UK and abroad.

21. How can the Councils promote/facilitate development of homes for private rent?
Contracts with the developers should stipulate that some homes for rent must be built. These should be a 'gift' to the Council. There should be strict rules to which developers have to adhere if they are given contracts to build houses. Currently, they appear to be getting away with far too much and the Council needs to have control which implies checking on the progress of developments and ordering the developers to rectify situations that go against the planning agreement.

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.
It depends upon how 35% is calculated. Presumably, there are different needs in different parts of the Mid Suffolk area. Each area requires research and, as far as possible, the percentage should depend upon need.

23. To what extent should affordable housing be (or not be) prioritised over provision of other infrastructure where viability is an issue?
In every case, all aspects of infrastructure where viability is an issue should be dealt with prior to building new houses. Currently, the situation is untenable where houses are being built with no development of infrastructure. However, affordable housing should take precedence over other housing.

24. In relation to affordable housing, should there be any preference for housing to accommodate key workers?
It is important that key workers are given some preference. However, if there is an influx of key workers into an area it could mean that some individuals/families are continually being moved down the waiting list. Therefore, a reasonable arrangement should be made dependent upon the circumstances. If key workers such as nurses are considered then affordable housing for them should be within a reasonable distance of good transport and/or near the place of work.

25. If Option RE2 is supported, what maximum percentage of market housing should be acceptable?
It is not clear what is meant by 'to bring the site forward'? However, so much is dependent upon the circumstances and, again a maximum percentage of market housing would not be appropriate. In general, rural areas should be maintained but, if this refers to rural towns and villages, then the individual settlement needs to be researched for appropriate building projects with a significant number of houses being built for first-time buyers who are being squeezed out of the market.

26. Which option for the policy approach to rural growth do you think is most appropriate?
RG1 as this should mean that each case in judged individually.

27. Are there any other approaches to distributing development in rural areas that we should consider?
Yes. Open meetings together with Parish Councils should be held in the settlement concerned to obtain the views of the inhabitants and the results of these meetings should be presented to the Councillors who come to the settlement in question. Even if Council members visit settlements on several occasions they will never be in a position to imbibe the current situation as seen by the inhabitants.

28. Do you support the approach proposed for hamlets? If not please explain.
As it is stated that 'National policy sets out that development should be distributed in a way which reduces the need to travel, supports the retention of existing services and helps to sustain rural areas' it would seem that neither HG1 or HG2 are sensible. However, if suitable sites are available to be purchased by individual families, building consent could be considered.

29. What should the Councils' approach to provision of negotiated stopping places be?
If 'stopping places' refers to families/groups with caravans etc, then the existing caravan sites should be adequate. Presumably, families/groups plan their journeys with these sites in mind.

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.
I do not have the knowledge to answer this question.

31. Should the Joint Local Plan include a policy which identifies areas where moorings would be acceptable in principal?
32. If so, are there any specific locations where additional moorings could be located?
I do not know enough about the appropriate areas to comment.

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?

34. If we continue to protect existing employment areas, which areas should be identified?
I do not know enough about the existing employment areas throughout Mid Suffolk, except that in Debenham the current area, Meadow Works Business Park, should be protected.

35. Are there any existing employment areas that could be reallocated to other use?
I do not know of any.
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?
Yes. Careful placement of these kinds of employment areas is important as they can totally destroy the historical and aesthetic aspects of a settlement. They are not the kind of employment areas suitable to be located in villages and hamlets.

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?
Careful consideration should be given in every case. Local skills and appropriate sites should be taken into account without exception together with the views of the population adjacent to the site.

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?
Only where there is significant development and local manpower. Land should not be allocated in inappropriate places such as near/in villages and hamlets which do not have this kind of facility already. It is inappropriate to continually add buildings to a settlement without restrictions. The choice of sites should be made by the Council and not be developers.

39. Should we make specific employment provisions for small and medium sized enterprises? If so, how and where.
Yes, especially high-tech. However, this employment provision should be carefully researched and the businesses placed in appropriate places, eg near centres of research and other high-tech businesses so that meaningful collaboration can take place.

40. If we expand, or allocate additional employment land where should these be?
Near existing centres of research, engineering etc. This would allow interaction between research and development. Examples of this type of development are taking place in Cambridge and Norwich.

41. What approach should we take to supporting new business formation across the Districts?
Realistic consideration of applications for new business formation should take place, with possible financial incentives being given, eg lower rent. It is important that the population have adequate local employment that is relevant to the area in which they live and is not duplicated.

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.
It is extraordinary that Debenham, which is designated as a core village, is grouped with Eye, which is designated as: urban areas and Market Town. While Debenham can be seen as a Core Village/Functional Cluster, and seen to have a District Centre role, in no way can it be classed with the other centres mentioned in this section. Its dependent villages and hamlets have been listed as 19 in number, whereas towns such as Framlingham have 3 in its cluster. The retail provision in Debenham is limited when compared with somewhere like Framlingham and Eye and there is nowhere in the heart of the village that further retail development can take place. It would seem sensible to increase the retail opportunities in places like Stowmarket where the town centre is rundown, inadequate and depressing. Retailers with smaller floorspace should be encouraged, perhaps financially, together with what is being classed as commercial leisure facilities. Out of town retail should be discouraged as this tends to deplete the viability of the town centres and encourages the use of private transport. In all cases there needs to be an increase in public transport.

43. Are there any other sites that should be considered for retail or commercial leisure use?
I do not know the full area of Mid Suffolk to suggest sites. If the town centres such as Stowmarket were reinvigorated this would make a difference to the situation. However, building developments such as the current ones in Framlingham do not solve these problems but destroy the ethos of the town and put to great a strain on the infrastructure. Brownfield sites should be utilised and the possibility of a new garden city should be considered as this could be custom built with amenities and infrastructure developed to suit the number of dwellings and house a significant number of people. It would also cut down the imposition of developments in towns and villages that have reached capacity.

44. If you consider allocations for retail development should come forward as mixed use, please provide details.
I do. As mentioned in Para 3 in the section headed 'Retail capacity and allocations'.

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.
Debenham listed in the Settlement Hierarchy it is classed as a core village. Therefore, it is not clear why it is included here. On the map there is a darker pink area depicted but no indication as to what this is. For Eye, Hadleigh, Needham Market and Sudbury I do not have the necessary information to answer the question.

Map 4: Debenham has the largest number of cluster villages. As Debenham itself is a core village this cannot be right or sensible. Given that the retail outlets of Eye, Framlingham and Stowmarket are greater in number, the boundary of Eye should extend further south, the boundary of Framlingham further west and the boundary of Stowmarket further east.

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.

47. Do you agree with the approach to maintain and increase retail provision within the District Centres? If not, please explain why.
Retail provision should be maintained. However, in Debenham there is no area in the centre that could offer increased retail provision. The current developments have already far outstripped the possible retail provision in the heart of the village and the capacity of other amenities.

48. Do you agree with the proposed thresholds relating to the mix of uses within Primary Shopping Frontage? If not, please explain why.
Thresholds have been given but there is no reasoning behind the suggested percentages. Explanation is required for an answer to this question.

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. It is apparent that where there are retail developments outside the town centres it has taken the heart out of the town. Very careful research and subsequent consideration needs to take place so as not to destroy vibrant and thriving communities.

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 approach?

51. Do you have views on the Option BIO1 and/or BIO2?
I prefer Option BIO2 as it includes the 'enhancement' of the areas. In no way should these areas be encroached upon and if development takes place nearby then this should not impinge on the habitat and biodiversity of the designated area.

52. How should the local plan consider the impact of renewable technologies? What types of effects should be assessed within the policy criteria?
Research institutions including universities involved in work on renewable energy and sustainable construction should be consulted so that the most appropriate schemes are introduced. These experts would be able to give full details of the types of effects that would occur. Also, the population in the vicinity of the proposed introduction of the new technologies should be consulted. It is important not to involve organisations with a financial interest at the stage of research as they often do not have the expertise required and have to buy in assistance. Sub-contracting always involves increased financial costs.

53. Do you support the Council's initial preference to include water efficiency measures in new build? If no, please explain why?
54. Are there any other additional environmental standards Babergh and Mid Suffolk should be requiring? If so, please provide details and reasons why.
While water efficiency is mentioned, there is no indication concerning sewage disposal capacity and surface water drainage. Air pollution needs to be addressed in hinterland villages as huge vehicles are tending to use the country roads which are totally unsuitable. They need to be prohibited. If deliveries need to be made rather smaller vehicles should to be used.

55. Are there any other approaches that the Joint Local Plan could take to protect the landscape?
Yes. Have stricter regulations for the developers and ensure that inspections take place at regular intervals during the development of a given site. If the developers are not complying with regulations and the permissions given, they should be made to comply. A holistic way of building should be adopted to avoid damaging protected and historical sites. Working with the surroundings to create gains for better health and well-being for resident and improvements for wildlife should be adopted. See www.wildlifetrusts.org/housing. The developers should be required to rectify all surrounding areas before they leave the area.

With regard to landscape surrounding settlements, conservation is important so that the biodiversity is maintained and depletion of species is curtailed..

56. Should additional protection be given to areas which form part of a landscape project area but which aren't designated?
Yes. This is most important in order to maintain the character of the landscape and historic towns and villages. Environmental habitats need to be protected so that the biodiversity of the region does not become depleted.

The diverse landscape of the area needs to be maintained and cherished. The non-designated areas which have a rich environment need to be protected. Possibly a reappraisal of non-designated areas needs to be carried out.

57. How can the Joint Local Plan make the most of the heritage assets?
The Joint Local Plan can do nothing by just being printed unless those responsible for it and in positions of authority within the Council are strict about ensuring that the Plan is adhered to with firm control. Heritage assets need to be preserved and protected. Those responsible should be encouraged to go for Lottery funding and other grants in order to restore buildings where necessary. If developers are making significant amounts of money in nearby areas, they should contribute financially or in kind to the upkeep of the heritage sites within the area. Many heritage sites bring income from tourism. Collaboration with the variety of trusts such as Suffolk Wildlife Trust, the RSPB etc could provide valuable information.

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?
A high level of protection should be given to maintain the uniqueness of Suffolk. HA1 is acceptable but it needs the vigilance of the appropriate departments of Mid Suffolk and research to be carried out on these assets. Collaboration with scientific organisations could help with this situation.

59. Should a more flexible approach toward climate change objectives be adopted where this would assist in protecting a heritage asset?

60. Is there any aspect of design that priority should be given to?
Developments should be in keeping with the character of the town/village/hamlet. The Council should apply stringent rules on developers and insist that they should adhere to these regulations. The information in the six bullet points given on page 64 should all be insisted upon. However, in totally new areas or in a new settlement, innovative designs could be developed.

61. Is there any aspect of design that should be introduced to the Councils' policies?
Some new sustainable and economical designs could be explored for introduction to the Councils' policies. However, these new designs should be implemented in carefully chosen sites. As mentioned previously the www.wildlifetrusts.org/housing website gives some ideas and contact and collaboration with the organisation might be advantageous.

62. Is there an area of design related to past development that you consider needs to be addressed in future development?
Yes. The size and design of the buildings are important in historic areas of settlements. The new houses being built on the 'Market Pyghtle' site are too large for the site and they have miniscule gardens which are inappropriate for a village. This arrangement is more for a town situation. Other houses built in the older parts of the village in recent years have been out of keeping with the general design. Thus the ambience of the village is steadily being destroyed by inappropriately designed new housing.

Areas of design related to past development such as the quintessential Suffolk houses should be incorporated in a sensitive and sensible manner.

63. Which option do you consider most appropriate? Please explain why.
INF1. Debenham has had significant development over the years, eg The Meadows, Henniker Road developments, but no attention has been given to amenities and infrastructure. This has resulted in an almost untenable situation with regard to medical facilities, educational provision, transport and parking facilities. Currently, far too much heavy traffic is being allowed to pass through the village and many vehicles at speeds far in excess of the limit.

64. What do you consider the key infrastructure issues in your community?
The key infrastructure issues in Debenham are the need for:
* adequate medical facilities - larger surgery and more staff for the population and nearby villages and hamlets without this facility
* adequate school places in both the Primary older children's classes and the High School
* adequate parking facilities
* adequate maintenance of the streams throughout the village
* adequate research and development with regard to possible flooding
* adequate maintenance of the highways and byroads
* control of huge vehicles passing through the village. They need to be diverted via the main roads and above a certain size should not be allowed on the minor roads. Should the contents of these vehicles need to be delivered, then smaller vehicles need to be employed
* control of the speed limit through the village. Given the straight nature of the High Street and Aspall Road, they often become a race track

65. What infrastructure issues do you consider to be a priority for the future?
This question has mainly been answered in No.64 above. Most of the key infrastructures issues have been caused by over-development over recent decades when it appears that no or little thought has been given to amenities and infrastructure.
* Health centre/GP surgery which is currently inadequate.
* Education. Local people can no longer find places for their children in the senior classes of the Primary School in Debenham. Debenham children should have priority.
* Transport. Currently, the traffic through the village is dreadful. Vehicles are breaking the speed limit and heavy goods vehicles are coming through the village when they should be diverted. Once outside the village, they cannot remain within the central road markings and therefore break up the verges. Diversions should be in place.
* Parking. Totally inadequate.
* Public transport. Inadequate with regard to frequency and destinations.
* Flood risk management. This needs to be addressed particularly with the new developments. Currently, the Highways Agency carries out an inadequate job with regard to clearing the streams around Debenham.

66. What infrastructure do you think would be needed to support the growth scenarios?
As for Nos.64 and 65. Before any further growth to Debenham village is contemplated these issues should be addressed.

67. What comments do you have on the proposed strategic approach to infrastructure delivery?
Currently, the amenities and infrastructure are inadequate given the recent developments within Debenham core village. Therefore, this needs to be addressed prior to any further housing development.

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

69. Should the strategy of the Plan be focussed on addressing deprivation?
The Plan should address deprivation but should not be totally focussed upon it as there are many other issues that need to be addressed.

70. Are there any specific approaches that should be applied to address deprivation?
The Council should work with local organisations that are addressing the needs of the deprived and develop meaningful ways of coping with this problem. They should find out how this problem is being addressed in other areas of the country and see if lessons can be learned so that meaningful policies can be introduced.

71. Are there any other circumstances and/or provisions under which open space, sports facilities or community facilities should be required and/or protected?
In Debenham the Leisure Centre together with the outdoor sports facilities and playground areas should be protected and the local green spaces such as Hoggs Kiss Wood, Hoppit Wood and the lakes and the woodland area next to Coopersfield and the cemetery and opposite the playground area should be protected.

72. Through the Plan should any other areas of Local Green Space be identified and protected?
Where none are provided, then they should be found and protected so that all populations have access to these facilities. Those members of the population who can least afford them are possibly those who require them most.

73. Are there any specific facilities that should be included in the definition of community facilities?
These have already been mentioned.

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?
Identifying functional clusters could be appropriate. However, not in the way they have been identified. In the explanation under para. 4 there is no mention of Debenham and then under 'Settlement Boundaries' it is given the status of a 'core village' with the largest functional cluster. This does not seem reasonable or sensible given the amenities and facilities when compared with Stowmarket for instance. This needs to be looked at again.
Debenham is classified as a 'core village'. However, on the Map: 'Functional Clusters in Mid Suffolk', Debenham is depicted as the largest functional cluster. This cannot be justified given the facts and is totally unacceptable. For instance, Framlingham has 3 villages within its cluster, Stowmarket has 16, Diss 4 and Eye 13, all with far more amenities than Debenham which is given 18 neighbouring villages and hamlets which must be incorrect. (Debenham is also listed as a village within the cluster which presumably is a mistake.)
The boundaries should be redrawn to illustrate a more meaningful depiction.
* Eye to the south
* Stowmarket to the east
* Framlingham to the west

75. Do you consider the proposed new settlement boundaries to be appropriate? Please explain your answer.
With regard to Debenham: the depiction on the map of the proposed new settlement boundary is not clear and cannot be clearly distinguished from the existing settlement boundary. So I cannot comment.

With regard to other towns, villages and hamlets I am not in a position to comment as I do not know the settlements sufficiently well.

76. Are there any other settlements that should be given new settlement boundaries? Please explain your answer.
I am not in a position to comment.

77. Is the threshold (10 well related dwellings) for identifying settlement boundaries appropriate?
This seems reasonable.

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 number ieSS0001).
I can only comment on Debenham. I do not consider the sites identified to be appropriate. No indication is given as to the number of dwellings to be built nor is there any suggestion of the Council's intention for the development of associated amenities and infrastructure.

SS0902: Totally unsuitable as this area is within the flood plain and flooding has taken place in this area of Low Road in the past as a result of other developments in the area, eg The Meadows. With flooding being on the increase due to climate change it would seem most inappropriate to continue building in areas such as this.

SS0642: Totally unsuitable. Again building in this area would contribute to flooding around Low Road. With the huge development of houses between Gracechurch Street and Low Road, the map demonstrates the imbalance of development with respect to the core village. It does not seem that there is an appropriate nearby area to create a 'slow and flow' feature.

SS0267: Far too large an area of development. Again this will put a strain on all the systems related to house building and possibly lead to increased potential for flooding in the area of The Butts and further downstream.

The maps are generally not that easy to follow as none of the roads are named. However, looking at the map of Debenham it can be seen that the developments are massively larger than the original core village and although roads have been built within the developments, no amenities or infrastructure has been built to accommodate the large number of houses that have been built. Thus, it makes these proposals untenable for the village life of the inhabitants.

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.
Brownfield sites need to be explored, eg run down industrial sites, disused airfields etc. A more inventive approach needs to be sought to avoid spoiling the culture and uniqueness of town and villages within Mid Suffolk.

(Further letter sent 7 November 2017 in attachments)

Attached Files for this Submission

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