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Representations on BMSDC Joint Local Plan Consultation Document (Interactive) - Housing Requirement

Representation ID: 13261

OBJECT Sproughton Parish Council (Mrs Susan Frankis)

Summary:

It is felt that a primary reason for creating a new JLP is that the councils are failing to provide the 5 year supply of development sites.
What is the main problem here? Would applications based on NPPF be such a hardship when BDC is proposing policies to circumvent the environmental and social policies of the NPPF and rarely abides by their own policies if it disadvantages developers. The basic NPPF may be better.
If the council is failing to achieve the 5 year supply now and builders are failing to build (over 2000 approved home applications laying dormant in BDC area) why are they not setting an achievable Housing Need objective? If they can't achieve what they need now how can they expect to achieve even more?

More details about Rep ID: 13261

Representation ID: 13110

COMMENT Suffolk Coastal District Council (Mr Mark Edgerley)

Summary:

Suggest that the table outlining the Objectively Assessed Need should include all the authorities across the Ipswich Housing Market Area. Expanding the table to show all the authorities will demonstrate the full picture of housing need across the Housing Market Area. It is also noted that these figures may need to be revised following the government consultation "Right Homes, Right Places."

More details about Rep ID: 13110

Representation ID: 12917

OBJECT Dr Jonathan Tuppen

Summary:

The main evidence provided is the Brett Associates report. The base data has no assessment for scenarios concerning Brexit.The Councils may be forced to follow a flawed policy imposed by national government to meet its own ends, and which may also help to meet the Council's own financial shortfall, failure to engage fully with local communities on this issue will continue to undermine the credibility of the JLP and the Councils themselves.
We ask the Councils to engage with communities and Parish/Town Councils on the detail of housing requirement.

More details about Rep ID: 12917

Representation ID: 12729

OBJECT Mr Bryan Fawcett

Summary:

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.

More details about Rep ID: 12729

Representation ID: 12563

OBJECT Fressingfield Housing Working Group (Mr Paul Woodward)

Summary:

Fressingfield is currently subject to approved applications for 52 houses and pending 3 planning applications for a further 208 dwellings. This would be a disproportionate contribution to meeting housing need in Mid Suffolk

More details about Rep ID: 12563

Representation ID: 12475

COMMENT Stoke by Nayland Parish Council (Mr James Dark)

Summary:

Comments apply to villages within AONBs only.
For housing to be accessible, and to remain accessible, to local people on local incomes, it has to be subject to suitable controls. aim for new housing should be
1) minimum open market sales
2) maximum control on subsequent development of open market properties
3) housing not for open market sales to remain confined to local people in housing need ie. no right-to-buy outright and controls on occupancy.

More details about Rep ID: 12475

Representation ID: 12242

OBJECT R G Williams Ltd represented by Gardner Planning (Mr Geoff Gardner)

Summary:

Housing White Paper was published well before this consultation and should be referred to. Substantially increasing housing supply is a key planning objective for all Authorities. The subsequent DCLG publication "Planning for the right homes in the right places: consultation proposals" obviously came too late for the consultation, and the proposal to revise the NPPF early in 2018, will have massive implications for the Local Plan. This Response returns to this in the Housing section below, but the 'vision and objectives' for the Local Plan do not yet capture the importance, priority and urgency of national policy.

More details about Rep ID: 12242

Representation ID: 12099

COMMENT Gladman (Mr Richard Crosthwaite)

Summary:

In formulating housing trajectory, 'lead in' and 'delivery' rates should be thoroughly considered. For example, this would include consideration of: determination periods for outline and reserved matters planning applications; any likely pre-commencement conditions; any upfront infrastructure costs and associated viability assessments; the requirement for site remediation on previously developed land; the complexity of s106 agreements; and, whether there are any complex land ownership arrangements.

More details about Rep ID: 12099

Representation ID: 12034

COMMENT Bloor Homes Eastern (Mr Gary Duncan) represented by JB Planning Associates (Mr Nicholas Ward)

Summary:

We consider it to be vitally important that the Councils takes steps now to ensure that
they addresses their housing backlogs, and achieve the step-change in housing
delivery rates advocated by the Government. We consider that new settlements,
which bring with them huge uncertainties, would be likely to hinder, rather than assist
the Councils deliver housing at the higher rates envisaged. Instead, we believe that a
balanced supply of small, medium and large housing developments spread across
sustainable sites throughout the two districts is going to be much more likely to
deliver the significant increases in housing supply numbers that will need to be
achieved. However, there will need to be a particular focus on sites located in the
most sustainable locations, which will result in a particular focus upon Stowmarket
and Sudbury, as well as the Ipswich fringe area.

More details about Rep ID: 12034

Representation ID: 11630

COMMENT Bloor Homes Eastern represented by JB Planning Associates (Mr Nicholas Ward)

Summary:

It will be vital that the Councils work with site promoters and landowners to ensure that suitable sustainable sites that can be quickly brought forward for development are allocated. Small and medium sized sites being particularly important in terms of ensuring housing delivery is boosted at the beginning of the Plan period, when larger and strategic sized sites are still waiting to come on stream.

More details about Rep ID: 11630

Representation ID: 11622

COMMENT Bloor Homes Eastern represented by JB Planning Associates (Mr Nicholas Ward)

Summary:

The new Local Plan must be prepared with the aim of substantially boosting the supply of housing across the Authority area. It will need to set out how, and where, new development will be focused, clearly identifying opportunities and aspirations throughout the two Local Authority areas. It should reflect the settlement hierarchy and seek to ensure that development is focussed upon the most sustainable locations in terms of facilities and services, and transport links. The larger urban areas such as Stowmarket will have an important role to play in ensuring that sufficient homes and jobs are provided for to address the scales of need of need identified.

More details about Rep ID: 11622

Representation ID: 11614

COMMENT South Suffolk Constituency Labour Party (Ms Emma Bishton)

Summary:

In recent years, Babergh has approved large volumes of housing yet the number of completions is staggeringly low. If this trend continues the plan will be rendered void, leaving the district vulnerable to national planning policy. This will do nothing to address the stated housing need. Plan should address how Babergh seek to mitigate impacts of planning system bias towards developers, at the same time ensure that its Vision can be realised. For example proposing caps on developers such as the requirement to complete builds within 2/3 years of granting permission.

A further gap is the workforce required to build 355 houses per year, particularly post-Brexit. What steps do the council propose to ensure there are sufficient number of skilled workers to deliver this?

More details about Rep ID: 11614

Representation ID: 11401

OBJECT Sproughton Playing Field (Damian Lavington)

Summary:

* Councils are no longer public services, they are businesses, only the elected councillors are there to represent the community. Their primary interest is profit and loss.
* The electorate are bound by law to pay their council tax, nothing done good or bad by the council effects that income other than that by increasing the electorate they increase their income.
* On the other hand, interaction with commercial interest can generate income so for housing that will include new homes bonuses, planning fees, 106 payments, CIL etc.
* If the council is failing to achieve the 5 year supply now and builders are failing to build (over 2000 approved home applications lying dormant in BDC area) why are they not setting an achievable Housing Need objective? If they can't achieve what they need now how can they expect to achieve even more? Why have they accepted data that is unreliable because it makes no consideration for Brexit when a more up to date analysis would almost certainly provide a smaller growth figure that might be achievable. Is the answer that the bigger the numbers the bigger the opportunity to generate income regardless of what the electorate wants?

More details about Rep ID: 11401

Representation ID: 11400

OBJECT Sproughton Playing Field (Damian Lavington)

Summary:

It is recognised that a primary reason for creating a new JLP is that the councils are failing to provide the 5 year supply of development sites. This failure may result in government taking over administration of planning applications. However this in itself throws up a multitude of questions not addressed in this JLP.
* This is becoming a problem nationwide, it is possible that the Government could set up a department to deal with all the planning applications from the massive number of councils that are failing?
* What is the main problem here? Would application based on NPPF be such a hardship when BDC is proposing policies to circumvent the environmental and social policies of the NPPF and rarely abides by their own policies if it disadvantages developers. The basic NPPF may be better.

More details about Rep ID: 11400

Representation ID: 11360

COMMENT Greater London Authority (Juliemma McLoughlin)

Summary:

The explicit consideration of longer term historic migration trends in the Strategic Housing Market Assessment of the Ipswich and Waveney Housing Market Areas is welcomed. The use of shorter-term tends is justified.

The Council should note that our latest population and household projections are now available on the London Datastore. Projections include consistent outputs for all local authorities in England and form the basis for the Strategic Housing Market Assessment of our new London Plan, which shows that London has a need for approximately 66,000 additional homes a year. The Strategic Housing Land Availability Assessment suggests capacity for around 65,000 additional homes a year.

More details about Rep ID: 11360

Representation ID: 11114

COMMENT Peter Warren

Summary:

The housing need projections are based on historic data and appear very over optimistic especially considering more recent/future political change. Additionally, larger developments and over concentration only create a greater burden on finances with the inevitable infrastructure requirements.

More details about Rep ID: 11114

Representation ID: 10981

OBJECT Mrs Carol Marshall

Summary:

* 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.
* Developers and Councils promote growth as the ultimate objective, but for who? Take a look at London and compare it with your present lifestyle. Businesses and Councils do well in Cities, but what is the quality of life of those that live there?
New NPPF white paper imminent
* The latest consultation paper on the NPPF is proposing a cap of 40% above any LP created prior to their new proposals.
* Therefore it is entirely possible that the unrealistic housing needs proposals being proposed in our JLP could be increased by another 40% making an unrealistic growth plan impossible.

More details about Rep ID: 10981

Representation ID: 10468

OBJECT Mr Joe Lavington

Summary:

Recognised that a primary reason for creating a new JLP is the councils failure to provide the 5 year supply of development sites. This throws up a multitude of questions not addressed in this JLP:
This is a nationwide problem, it is possible that the Government could set up a department to deal with all the planning applications from the council that are failing. Would deciding applications base don NPPF be such a hardship when BDC is proposing policies to circumvent the policies of the NPPF and rarely abides by their own policies if it disadvantages developers. The basis NPPD may be better.

More details about Rep ID: 10468

Representation ID: 10459

OBJECT Wendy Lavington

Summary:

Recognised that a primary reason for creating a new JLP is the councils failure to provide the 5 year supply of development sites. This throws up a multitude of questions not addressed in this JLP:
This is a nationwide problem, it is possible that the Government could set up a department to deal with all the planning applications from the councils that are failing
Would deciding applications based on NPPF be such a hardship when BDC is proposing policies to circumvent the policies of the NPPF and rarely abides by their own policies. The basic NPPF may be better.

More details about Rep ID: 10459

Representation ID: 10292

OBJECT Keith Barwick

Summary:

Development which meets local need only and improve infrastructure to cope .
Housing Requirement 2014 to 2036

I do not agree with the numbers stated ,in view of the changes which are occurring for example BREXIT

More details about Rep ID: 10292

Representation ID: 10047

OBJECT Charlotte Lavington

Summary:

Councils are no longer public services, they are businesses.
If the council is failing to achieve the 5 year supply now and builders are failing to build (over 2000 approved home applications lying dormant in BDC area) why are they not setting an achievable Housing Need objective? If they can't achieve what they need now how can they expect to achieve even more?
Why have they accepted data that is unreliable because it makes no consideration for Brexit when a more up to date analysis would almost certainly provide a smaller growth figure that might be achievable. Is the answer that the bigger the numbers the bigger the opportunity to generate income regardless of what the electorate wants?

More details about Rep ID: 10047

Representation ID: 10045

OBJECT Charlotte Lavington

Summary:

It is recognised that a primary reason for creating a new JLP is that the councils are failing to provide the 5 year supply of development sites. This failure may result in government taking over administration of planning applications. However this in itself throws up a multitude of questions not addressed in this JLP.
What is the main problem here? Would application based on NPPF be such a hardship when BDC is proposing policies to circumvent the environmental and social policies of the NPPF and rarely abides by their own policies if it disadvantages developers. The basic NPPF may be better.

More details about Rep ID: 10045

Representation ID: 9905

OBJECT Professor Robert Turner & Mrs J.M. Turner

Summary:

Persons/organisations do not want to immediately start the complete development for which they have obtained permission as this would have the effect of lowering the prices of houses on such developments, but instead they wish toensure that they can release properties slowly onto the market to ensure that prices are retained at the current impossible levels

There are at the moment permission for building 2,480 houses within the Mid Suffolk District yet 2,040 houses remain unbuilt. This not unique to Mid Suffolk as in Babergh, 2,160 houses out of 2,320 for which planning permission has been granted, also remain unbuilt.

More details about Rep ID: 9905

Representation ID: 9839

COMMENT Stowupland Parish Council (Claire Pizzey)

Summary:

With the publication of a government consultation with 'targets' for housing numbers, are the numbers suggested higher than the numbers upon which the JLP has been based and, if so, should the numbers in the JLP be revised?

More details about Rep ID: 9839

Representation ID: 9683

OBJECT Mr Chris Marshall

Summary:

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.
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.

* The latest consultation paper on the NPPF is proposing a cap of 40% above any LP created prior to their new proposals.
* Therefore it is entirely possible that the unrealistic housing needs proposals being proposed in our JLP could be increased by another 40% making an unrealistic growth plan impossible.

More details about Rep ID: 9683

Representation ID: 9502

OBJECT Cllr John Hinton

Summary:

The SHMA was a paper exercise with limited use of up to date information and resources and had no real contact with the actual need / requirement of the market - even when 60% migration is taken into account? (ONS figures 2017)

More details about Rep ID: 9502

Representation ID: 9497

OBJECT Cllr John Hinton

Summary:

Peter Brett Associates(PBA), failed to produce a robust or viable Infrastructure Strategy document for the last Local Plan - it was effectively a partial cut/paste from the Core Strategy document, and the current Housing Needs Survey - was a desk top exercise, utilising flawed and ancient information extrapolated to give a preconceived "NEED". Current ONS figures are less than 40% of those in the PBA report and yet they are not included even though more current. The arbiter increase, because of the house price issue is a classic "lies, lies and dammed statistics" approach which further colours the credibility.

More details about Rep ID: 9497

Representation ID: 9184

OBJECT Mr Ken Seager

Summary:

The JLP should also have an in-built flexibility so that the housing need can be regularly reviewed against forecasts during the life of the plan to 2036 and adjusted to take account of significant changes in demand which affect the amount, type and location of housing during that time.

More details about Rep ID: 9184

Representation ID: 9044

COMMENT Mr Guy McGregor

Summary:

Mid Suffolk should plan for modest growth in housing stock in line with natural growt.

More details about Rep ID: 9044

Representation ID: 7823

COMMENT Dr Ian Russell

Summary:

Infrastructure, employment and housing must go hand in hand. The danger is more and more people commute farther and farther due to imbalances between jobs and housing where they live. For instance, around one third of the estimated benefit in the Business Case for the Sudbury Relief Road derives from commuters who live to the north of Sudbury and work to the south, or vice versa. Common sense dictates investment in roads to the east and south of Sudbury to service past, present and future development instead of forcing traffic into the Belle Vue junction.

More details about Rep ID: 7823

Representation ID: 7540

COMMENT Dr John Caesar

Summary:

Disappointing that a continued lack of a 5 year housing supply plan in Mid-Suffolk has led to a lot of speculative large-scale development applications which are set to blight a number of communities in the district and stretch services and infrastructure.
It is not clear but, based upon numbers provided in the SMHA table on page 21, are around 265 houses now required per year in Mid-Suffolk based upon residual requirements?

More details about Rep ID: 7540

Representation ID: 7285

COMMENT Mr Mark Blackwell

Summary:

Has the methodology in coming to the housing need included any consideration of major strategic shocks - Brexit? Is there any scope for a review of this requirement, and what happens if it rises of lowers?

There is a lot of talk about strategy but it appears that the need and proposed site favour those who have banked land waiting to develop it. If it is a truely strategic plan, sites should be compulsory purchased at farm land prices, with a tender put out to privae industry to develop with a profit share between council, residents and company

More details about Rep ID: 7285

Representation ID: 6817

COMMENT Freston Parish Council (Ms Elizabeth Aldous)

Summary:

Freston is unsuitable for development as it is classified as unsustainable.

More details about Rep ID: 6817

Representation ID: 6780

OBJECT Mr Peter Powell

Summary:

Brexit, HS2, will we really need this level of housing?

More details about Rep ID: 6780

Representation ID: 6266

OBJECT Neil Fuller

Summary:

Data used to forecast growth is too historic as it makes no consideration for Brexit, it is therefore unreliable and potentially over ambitious. JLP proposes significant home building to accommodate significant migration into the area to fulfil the employment needs of significant growth in business/employment.

Developers and Councils promote growth as the ultimate objective, but for who? Take a look at London and compare it with your present lifestyle. Businesses and Councils do well in Cities, but what is the quality of life of those that live there?

More details about Rep ID: 6266

Representation ID: 6264

OBJECT Neil Fuller

Summary:

It is recognised that a primary reason for creating a new JLP is that the councils are failing to provide the 5 year supply of development sites. This failure may result in government taking over administration of planning applications. However this in itself throws up a multitude of questions not addressed in this JLP.

Would application based on NPPF be such a hardship when BDC is proposing policies to circumvent the environmental and social policies of the NPPF and rarely abides by their own policies if it disadvantages developers. The basic NPPF may be better.

if the council is failing to achieve the 5 year supply now and builders are failing to build (over 2000 approved home applications laying dormant in BDC area) why are they not setting an achievable Housing Need objective?

More details about Rep ID: 6264

Representation ID: 5824

OBJECT Little Cornard Parish Council (Mr Dave Crimmin)

Summary:

No. There is insufficient consideration given to undeveloped sites which have planning permission, long term unoccupied dwellings and potential population shifts caused by for example expansion/closure/relocation of large employers.

More details about Rep ID: 5824

Representation ID: 3823

OBJECT Mr John Bellwood

Summary:

I do not agree with the housing figures, what are they based on, does this consider the effects of BREXIT plus overseas migration -- the figures are overstated.

Sproughton village has an extremely high amount of houses outlined which is not proportional to the surrounding villages under Babergh, its taking the duty to Co-operate to the extreme.

More details about Rep ID: 3823

Representation ID: 3787

COMMENT Mr Alan Squirrell

Summary:

To consider that more housing is required in the BDC area is completely ignoring the effects of Brexit.

To create more concrete jungle is against nature, and the rights of 'country people' to live in open countryside.

BDC, Suffolk CC, and the Government are all cutting back services; so how is providing housing, without social infrastructure responsible, or even legal?

Farmland developed, is food, employment and nature lost forever; houses built when public services cannot cope, is a major long term cost, and hindrance to real positive progress in so many ways

More details about Rep ID: 3787

Representation ID: 3744

OBJECT Mrs Louise Baldry

Summary:

Population growth is not a known fact. Will Brexit affect numbers? Allocation is unrealistic

More details about Rep ID: 3744

Representation ID: 3736

OBJECT Mr Jeremy Doncaster

Summary:

I do not agree with the housing figures, what are they based on, does this consider the effects of BREXIT plus overseas migration -- the figures are overstated.
Sproughton village has an extremely high amount of houses outlined which is not proportional to the surrounding villages under Babergh, its taking the duty to Co-operate to the extreme.

More details about Rep ID: 3736

Representation ID: 3638

COMMENT Mr Alan Lewis

Summary:

The document states a need for 97 affordable house/annum in Mid-Suffolk out of a OAN of 452 which gives a need for c 21% affordable housing. However, the current target is 35%. Why has the figure been reduced? Given the decrease in affordability caused by increasing house price and negative pay growth it seem unlikely this should be the case.

More details about Rep ID: 3638

Representation ID: 3114

OBJECT Iain Pocock

Summary:

Absolute priority should be given to the utilisation of brown field sites and organic growth. If this is insufficient then consideration should be given to a new "garden village" with adequate infrastructure rather than overloading existing ones without

More details about Rep ID: 3114

Representation ID: 3085

OBJECT Mrs June Webb

Summary:

Population growth is not a known fact. Depends where industry in the future is located. Will Brexit affect numbers?

More details about Rep ID: 3085

Representation ID: 2085

COMMENT Great Finborough Parish Council (Mrs Paula Gladwell)

Summary:

The generalised jargon is opaque to understand and we question how the figures are derived. Though we understand there are housing needs we find it difficult to understand the priorities when we have a village of 350 houses with no public transport links, an overflowing school and without any retail outlets. The roads are narrow and already busy with through traffic. Housing needs to be near employment opportunities and properly sustainable.

More details about Rep ID: 2085

Representation ID: 776

OBJECT Supporters Against Fressingfield Expansion (SAFE) (Dr John Castro)

Summary:

We believe that the delivery of houses should be organic based on local need and not a plan centrally dictated which goes against the Localism Act of 2011.Current rates of house building are low because as the last local plan stated population here is dropping and local employment opportunities are few. The current evidence base for population is misleading, the population since 2001 has hardly changed but there is a 10% growth assumption based on total UK migration levels that it has therefore providing false information that 430 houses are needed in the District. Encouraging migration will make it harder for local people to buy into affordable housing.

More details about Rep ID: 776

Representation ID: 741

OBJECT Mr. Nick Miller for Sudbury Green Belt Group

Summary:

This section relies on a consultants' report and gives selective findings and value judgements rather than answering important questions which we list; nor does it recognise that environmental and social requirements could influence either the figures or the land supply; nor that the role of the County Council as major landowner around Sudbury should be examined closely and publicly.

More details about Rep ID: 741

Representation ID: 610

OBJECT mr david martin

Summary:

Peninsular is different geographically/demographically.
Same as other Suffolk AONB's
Rivers, land mass shape, Maritime, ancient woodlands
Picturesque inland and river vistas
B1436 status to be maintained for compatibility with present and future AONB safety review, time taken for emergency services to get in and return.
Agriculture, visitor amenity and attractions of local and national importance. Poor communication, transport, no industry or commerce centres.
Accumulative development disproportionate effects

For these reasons the "Babergh Local Plan Evidence base" is out of date and needs correction

More details about Rep ID: 610

Representation ID: 369

OBJECT Mr W King

Summary:

Contrary to your propaganda there is no need, whatsoever, for more housing.

There is a need, however, for English heroes. Here's your chance
Stand up against a treasonous government.
Refuse to concrete over what remains of our green and pleasant land.
Say no to turning England into a teeming termites nest of alien humanity.
Put England and the English first.

More details about Rep ID: 369

Representation ID: 277

OBJECT Ms Jackie Knight

Summary:

Mid-Suffolk is suffering from an all too rapidly expanding and invasive development of housing, roads and industrial areas. I object to any non-brown site developments for the following reasons: maintaining villages/rural areas distinct from built-up areas, light/noise pollution, overcrowding and overstressing residents, land and local services, such as roads, businesses, community areas, wildlife habitat, trees, etc. Over population is a huge worldwide problem and more housing stimulates population increase. I support all objections to development submitted by Stowupland or Stowmarket town councils. NHS services and local infrastructures can no longer cope (NHS should be given priority for all brown-site developments).

More details about Rep ID: 277

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