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Representations on BMSDC Joint Local Plan Consultation Document (Interactive) - Q7

Representation ID: 13217

COMMENT Building Partnerships Ltd represented by La Ronde Wright Limited (Mrs Nicole Wright)

Summary:

As stated in the Consultation Document, Babergh's objectively assessed need is for 7,820 to 203, equivalent to 355 annually; based on DCLG figures published in September 2017 and derived from the application of the Government's proposed assessment formula, there is likely to be an annual need for 439 dwellings pa to 2026. By contrast, the 2017 AMR records 226 new dwellings built in Babergh District last year, which represents 70% of the annual target (325 dwellings) set by the BDC Core Strategy.
In Ipswich, where the objectively assessed need is for 39,300, equivalent to 1,786 annually, under delivery is even more acute. The 2015 AMR for Ipswich states that the estimated housing delivery shortfall for Ipswich between 2001 and 2016 will be 2,117 dwellings. At that time, IBC could only demonstrate enough land for a 2.8 year supply of housing land.

More details about Rep ID: 13217

Representation ID: 13210

SUPPORT A R Hall & Sons represented by Savills (Mr William Lusty)

Summary:

It is essential that the Councils plan to meet growth requirements in a sustainable way, in accordance with Government planning policy contained within the National Planning Policy Framework (NPPF). Within this context, the NPPF also requires a 'step change' in housing growth by planning positively in meeting objectively assessed needs. As such, the Councils must take a positive approach in ensuring that growth requirements are met.

Furthermore, housing growth provides key support to economic growth and given the importance of economic considerations within the context of sustainable development, the Councils should prioritise housing delivery to serve this purpose. As such, we support the Councils' proposed option to plan to meet its objectively assessed need of 9,951 dwellings within Mid Suffolk and 7,820 dwellings within Babergh.

More details about Rep ID: 13210

Representation ID: 13153

OBJECT Taylor Wimpey represented by Boyer Planning (Mr. James Bailey)

Summary:

Concerned that the Council's proposed OAN figure and its difference between the DCLG's proposed figure included within their consultation document.

More details about Rep ID: 13153

Representation ID: 13140

OBJECT Mrs L J Cattermole

Summary:

Forecasts were done before Brexit and the numbers seem overstated.

More details about Rep ID: 13140

Representation ID: 12989

COMMENT Ipswich Borough Council (

Summary:

Reference should be made to the Ipswich and Suffolk Coastal OAN to show IHMA overall requirements. Whilst it mentions outputs from the SPIF will be considered, there is no infrastructure-led strategic growth option put forward. The Government's proposed formula for assessing housing need increases the housing requirement for Babergh and Mid Suffolk and Suffolk Coastal, whilst reducing the requirement for Ipswich. The SHMA figure for Ipswich Borough recognised uplift for economic growth and the correct OAN for Ipswich Borough remains 519 dwellings per annum. The total for IHMA is therefore 2,026 dwellings, 240 per annum more than in the SHMA.

More details about Rep ID: 12989

Representation ID: 12910

COMMENT Suffolk County Council (Mr. Robert Feakes)

Summary:

Question 7 refers to the approach to each district meeting its own needs because there is no evidence that a housing requirement beyond the Objectively Assessed Need is necessary. Therefore, Policy HR1 does not include any potential unmet need from other areas including Ipswich. However, as the district councils will be aware, evidence could come forward from Ipswich's review process, after other options (e.g. greater density and reusing land) have been considered.

More details about Rep ID: 12910

Representation ID: 12848

OBJECT Tidal Hill Limited represented by Armstrong Rigg Planning (Mr Geoff Armstrong)

Summary:

A more ambitious housing target is essential to ensure that Babergh, as part of the Ipswich HMA and wider East Anglia region assume the levels of prosperity sought within the SEP and the Economic Strategy. Significant infrastructure growth is required to not only reverse recent trends of under-delivery and underĀ­investment but allow Babergh to progress. These failings of the past serve to emphasise the need to be more proactive and ambitious moving forward.
We therefore recommend that the Plan's housing target includes an uplift akin to Scenario C of the Suffolk Coastal consultation document. This would see a 40% increase of the current OAN figure. Planning for this level of growth would ensure that the Plan's strategy would be future proofed against the need for substantial revision following the introduction of the Government's standard methodology.
The result would be a target of 10,948 homes for Babergh, with an annualised requirement of 498 homes

More details about Rep ID: 12848

Representation ID: 12827

OBJECT Persimmon Homes (Anglia) (Ms Laura Townes)

Summary:

The housing requirement is based on the OAN derived from the SHMA 2017. A "Report on the Objectively Assessed Housing Need" (Pegasus, P17-2499, November 2017) is appended to this letter explain how the SHMA is seriously flawed with regard to several assumptions that have been made resulting in an under-estimation of the OAN for Babergh and Mid Suffolk. The SHMA should be revisited to address the concerns that have been raised and to ensure that is provides a sound basis for determining the correct OAN.

More details about Rep ID: 12827

Representation ID: 12800

OBJECT East Bergholt Parish Council (Valerie Ayton)

Summary:

Housing OAN estimates 2014-36 need to factor in Brexit explicitely (Q7-10). Likely demand will shrink if economy does and jobs fall away.
Housing growth should be based upon local environment and employment. EBNP sets out policies AND proejcts to achieve the local need target and to ensure the deliverability of low market cost an homes for older people that are needed.

More details about Rep ID: 12800

Representation ID: 12796

OBJECT East Bergholt Parish Council (Valerie Ayton)

Summary:

Until we answer question of what/why houses then can't answer the question of where BHD1, 2 or 3?

More details about Rep ID: 12796

Representation ID: 12742

COMMENT Building Partnerships Ltd. represented by La Ronde Wright Limited (Mrs Nicole Wright)

Summary:

Historic under delivery across the district provides support for Option HD1 - Option HD1 - Apply a contingency - to address the risk of a growing gap between supply and demand. Based on recent figures, a minimum contingency of 30% should be applied to the total site allocation.

More details about Rep ID: 12742

Representation ID: 12733

OBJECT Mr Gary Clark

Summary:

o DON'T AGREE WITH THIS - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
o Relocation of major industries, effects of 'Northern Powerhouse and HS2.
o 10% uplift to increase supply/reduce sale price/increase affordability.
o Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated

More details about Rep ID: 12733

Representation ID: 12707

OBJECT Pegasus Group (Mr Stuart Wells)

Summary:

Object to the findings of the SHMA and the housing requirement as set out in Option HR1-OAN

More details about Rep ID: 12707

Representation ID: 12649

OBJECT Mr Bryan Fawcett

Summary:

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

More details about Rep ID: 12649

Representation ID: 12579

OBJECT Mr Alastair Powell

Summary:

Effects of Brexit on migration have been completely ignored and yet as the main element of any population growth shown in the historic data any migration changes due to Brexit will have he biggest effect. HS2 will effect the direction of migration potentially reversing growth, and relocation of major industries (Northern Powerhouse). 10% uplift is unsound because house and wage medians do not account for increasing cash rich migration from city against City commuters not showing a local wage. Housing need appears to be based almost entirely on single occupancy which is absurd and needs reconsideration to about half of that for average occupancy rates.

More details about Rep ID: 12579

Representation ID: 12536

OBJECT Llanover Estates represented by LRM Planning Ltd (michael rees)

Summary:

We are concerned that no other options have been considered (other than OAN) and have numerous queries over how this relates to overarching strategies / objectives. It is not clear how settling at this level relates to the economic development objectives (which themselves seek to encourage employment and business growth as well as increasing productivity). Accordingly, we believe that other options should have been explored rather than just settling at the stated OAN.
There does not appear to be justification for this plainly evidence needs to be prepared to indicate how housing provision matches employment growth over the plan period.

Para 49 of the NPPF requires explicitly that local planning authorities should boost significantly the supply of housing. Surely the Councils must demonstrate that the plan meets these requirements.

More details about Rep ID: 12536

Representation ID: 12457

OBJECT Taylor Wimpey represented by Boyer Planning (Ms Libby Hindle)

Summary:

We are concerned with the OAN figure and its difference between the DCLG's proposed figure included within their consultation. Whilst we note this document is in its infancy, and therefore can only be given limited weight, the table below identifies the disparities between these figures which cause some concern.

More details about Rep ID: 12457

Representation ID: 12449

COMMENT Ms C Ciechomski represented by Strutt & Parker (Mr. James Firth)

Summary:

The starting point for housing delivery should be the Objectively Assessed Housing Need (OAN). The OAN should be seen as a minimum, rather than a ceiling or a minimum target. This principle is confirmed through Government Policy, as set out in the NPPF, which makes clear that Local Planning Authorities should seek to significantly boost the supply of housing.
The proposed approach to housing delivery in the Draft Joint Local Plan should therefore recognise the OAN as the minimum.
In addition, the NPPF emphasises (Paragraph 14) that Local Plans should meet objectively assessed needs, with sufficient flexibility to meet rapid change. As such, by aiming for a higher figure the Local Plan is more likely to be "future proof" and able to adapt to increasing demand for housing. (See full representation attached.)

More details about Rep ID: 12449

Representation ID: 12383

OBJECT Mr David Sylvester represented by Strutt & Parker LLP (Mr Kenny Durrant)

Summary:

Considered the proposed approach is unsuitable and should be revised. Advised that the OAN figure is revised to changes such at the Government's standardised approach in establishing OAN. This may incur delays in the development of the Plan, but would be better than pursuing submission of the Plan then finding it not to be in accordance with national policy.

Asides from the above, it is also suggested that the OAN figure should be revised so that it serves as the minimum number of homes that need to be delivered across the Districts, rather than being viewed as a target to hit.

More details about Rep ID: 12383

Representation ID: 12303

OBJECT Taylor Wimpey represented by Boyer Planning (Mr. James Bailey)

Summary:

Concerned that the Councils' proposed OAN figure and its difference between the DCLG's proposed figure included within their consultation document.

More details about Rep ID: 12303

Representation ID: 12287

OBJECT Anthony Villar represented by Strutt & Parker (Mr William Nichols)

Summary:

Considered approach is unsuitable and should be revised. Government have argued that a standardised approach to assessing local housing need would be simpler, quicker, and more transparent. Advised that the OAN figure is revised in response to such changes. This may incur delays in the development of the Plan, but it is better to wait, rather than pursue the submission of the Plan and then finding it to not be in accordance with national policy.

OAN figure should b revised so that it serves as the minimum number of homes that need to be delivered across the Districts, rather htan being viewed as a target to hit.

More details about Rep ID: 12287

Representation ID: 12249

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

Summary:

No. The Local Plan will have to be based on recalculated OAN based on the new national methodology set out in DCLG 'Planning for the right homes in the right places: consultation proposals' (September 2017). This will be incorporated in a revised NPPF to de published for consultation early in 2018, to be finalised in Spring 2018. By the next stages of the LP the new methodology will fully be in place. Government has clearly signalled that OAN calculations should be simple and transparent, a significant change to the sort of exercise carried out in the 400-page SHLAA. Additional 1,838 homes must be allocated in the LP in Babergh.

More details about Rep ID: 12249

Representation ID: 12220

COMMENT Marden Homes represented by Strutt & Parker (Ms Laura Dudley-Smith)

Summary:

The starting point for housing delivery should be the Objectively Assessed Housing Need (OAN). The OAN should be seen as a minimum, rather than a ceiling or minimum target. This principle of is confirmed through Government policy set out in the National Planning Policy Framework (NPPF), which makes clear that Local Planning Authorities should seek to boost significantly the supply of housing. The proposed approach to housing delivery in the draft joint Local plan should therefore recognise the OAN as a minimum. See full representation attached.

More details about Rep ID: 12220

Representation ID: 12151

OBJECT LRM Planning Ltd (michael rees)

Summary:

see attachment:
We are concerned that no other options have been considered (other than the OAN) and have numerous queries over how this relates to overarching strategies / objectives.
Note in this regard, that para 49 of the NPPF requires explicitly that local planning authorities should boost significantly the supply of housing.
For the Local Authority to demonstrate that the plan meets these requirements, however we note that as no other options have been assessed it is unclear how various matters relate.

More details about Rep ID: 12151

Representation ID: 12132

OBJECT APT Philpot Ltd represented by Strutt & Parker LLP (Mr Richard Clews)

Summary:

OAN should be seen as a minimum, rather than a ceiling to be NPPF compliant. Paragraph 14 makes it clear that Local Plans should meet OAN with sufficient flexibility to adapt to rapid change. It the JLP aims to simply meet OAN it would not be sufficiently flexible to respond to changes in circumstances, such as sites failing to come forward as expected. Risks a situation where the JLP fails to ensure an adequate five-year land supply during the entirety of the plan period, which would render it out of date.

Need for flexibility is highlighted by Government's consultation on standardised methodology for calculating OAN, which represents an increase of 84 additional dwellings per annum. JLP should ensure that potential increases in housing needs are accounted for.

More details about Rep ID: 12132

Representation ID: 12123

OBJECT Mr Herbert Godbold, Ms Olive Godbold, Mr Stephen Baker and Diana Johnson represented by Strutt & Parker LLP (Mr Kenny Durrant)

Summary:

In order to be in accordance with future national policy, it is considered that the proposed approach set out under Option HR1 is unsuitable and therefore should be revised. Government has recently published a standardised approach to assessing local housing need which would be simpler, quicker and more transparent. It is advised that the OAN figure is revised in response to changes in national policy. This may incur delays in the development of the plan, but will be better than submitting the Plan to find it not to be in accordance with national policy.

OAN figure should be revised so it serves as the minimum number of homes that need to be delivered across the Districts, rather than being viewed as a target to hit.

More details about Rep ID: 12123

Representation ID: 12097

OBJECT Gladman (Mr Richard Crosthwaite)

Summary:

Essential that the HMA authorities continue to engage through the plan making process to ensure that the development needs of the area can be met in full over the plan period. Authorities need to be mindful of the changing national context, in particular any decisions made from the Governments Planning for the Right Homes in the Right Places consultation. NPPF sets out the Government's goal to 'significantly boost the supply of housing' and how this should be reflected through the preparation of Local Plans. Gladman raise concerns with no alternatives options being put forward with regards to total housing requirement rather than OAN, considered essential to test various options. Ipswich & Suffolk Coastal have identified a range of growth scenarios. Important for OAN to be identified as a minimum.

More details about Rep ID: 12097

Representation ID: 12081

OBJECT Ms Rosemary Anne Welburn & Mr Robert Gordon Stiff represented by Strutt & Parker LLP (Mr Kenny Durrant)

Summary:

In order to be in accordance with future national policy, it is considered that the proposed approach set out under Option HR1 is unsuitable and therefore should be revised. Government consultation on a standardised approach to establishing OAN figure. It is advised that OAN is revised in response to changes. This may incur delays in the development of the Plan, but would better than pursuing the submission of the Local Plan and then finding it not to be in accordance with national policy.

OAN should be revised so that it serves as the minimum number of homes that need to be delivered across the Districts, rather than being viewed as a target to hit.

More details about Rep ID: 12081

Representation ID: 12072

OBJECT The Thornhill Settlement (John Davie-Thornhill) represented by Strutt & Parker LLP (Melissa Reynolds)

Summary:

Option HR1 is unsuitable and the OAN figure needs to be reconsidered so it serves as the minimum number of houses to be delivered, encouraging greater delivery of housing and increasing supply.

We would suggest that the OAN figure is re-considered in response to changes such as the Governments consultation on a standardised approach in establishing OAN. If OAN serves as the minimum number of homes that need to be delivered, rather than being viewed as a target to be met. Such an approach would encourage a greater delivery of housing and thus ensure an increase in supply, which would assist in tackling the Districts' persistent under-delivery.

More details about Rep ID: 12072

Representation ID: 12050

OBJECT Montague Asset Management represented by Strutt & Parker (Mr William Nichols)

Summary:

Should be alternative options. Government standardised approach in establishing an OAN figure, it is advised that the OAN figure is revised in response to such changes. This may incur delays in the development of the Plan, but in terms of opportunity cost it is better to wait for the proposed changes, rather than pursue the submission of the Local Plan and then finding it not to be in accordance with national policy.

Suggested that the OAN figure should be revised so that it serves as the minimum number of homes that need to be delivered, rather than a target to hit. This would encourage a greater delivery of housing and thus ensure an increase in supply, thus assisting in tackling the Districts' persistent under-delivery.

More details about Rep ID: 12050

Representation ID: 12026

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

Summary:

JLP will need to take full account of the implications of the Government's proposed formula for assessing housing needs. This representing a 25% increase in the overall housing requirement figure specified in the JLP. Councils will indeed need to
significantly increase the currently stated OAN figure.

More details about Rep ID: 12026

Representation ID: 12011

OBJECT Endurance Estates represented by Pegasus Group (Jamie Roberts)

Summary:

There must be clarity over how the housing requirement will be set and how performance against requirements will be monitored, as this is currently unclear.

There are issues associated with the 2017 SHMA which cast significant doubt on whether it can be relied upon as a robust assessment of housing need. Moreover, the Councils must be prepared for the proposed standardised methodology and it is appropriate to plan on the basis of 573 dwellings per annum for Mid Suffolk and 439 dwellings per annum for Babergh.

More details about Rep ID: 12011

Representation ID: 11994

OBJECT Endurance Estates represented by Pegasus Group (Jamie Roberts)

Summary:

There must be clarity over how the housing requirement will be set and how performance against requirements will be monitored, as this is currently unclear.

There are issues associated with the 2017 SHMA which cast significant doubt on whether it can be relied upon as a robust assessment of housing need. Moreover, the Councils must be prepared for the proposed standardised methodology and it is appropriate to plan on the basis of 573 dwellings per annum for Mid Suffolk and 439 dwellings per annum for Babergh.

More details about Rep ID: 11994

Representation ID: 11988

OBJECT Pigeon Investmenrt Management (Mr. Andrew Fillmore) represented by Beacon Planning Ltd (Ms Sophie Pain)

Summary:

Pigeon have commissioned Pegasus Group (Pegasus) to independently consider the level of Objectively Assessed Need (OAN) in the Ipswich HMA. This commission includes a
review of the Strategic Housing Market Assessment (SHMA) dated May 2017, which forms part of the evidence base for the joint Local Plan for Babergh and Mid Suffolk District Councils. The OAN Report prepared by Pegasus is attached at Appendix 1.
The key conclusions of the Pegasus OAN Report are that the Issues and Options consultation is evidenced by a SHMA which is considered to be seriously flawed, given the
assumptions which are made within it. In this regard, the SHMA identifies a total OAN for Babergh of 355 dwellings per annum and for Mid Suffolk an OAN of 452 dwellings per annum in the period 2014 - 2036, based on short term (five year) population projections, updated by one year from the 2014-based ONS/DCLG projections. However, this produces significantly different results across the HMA as a whole, but particularly in relation to Babergh and Mid
Suffolk, when compared to longer-term trend based projections.

More details about Rep ID: 11988

Representation ID: 11959

OBJECT The Trustees of the Tollemache 1965 Settlement represented by Strutt & Parker (Sam Hollingworth)

Summary:

The proposed approach to housing delivery in the draft JLP should treat the OAN very much as a minimum, and should ensure strategies are in place to exceed this figure.

The JLP must be mindful of the Government's consultation on standardised methodology for calculating objectively assessed housing need. The consultation methodology results in a proposed annualised OAN of 573 dwellings for Mid Suffolk District. This additional requirement, when applied over the proposed plan period of 2014 - 2036), equates to an additional 2,662 dwellings.

Failing to ensure the Local Plan's housing target exceeds the minimum OAN risks a situation in which the JLP fails to ensure an adequate five-year housing land supply during the entirety of the plan period, which would render the local plan out of date.

More details about Rep ID: 11959

Representation ID: 11950

OBJECT Fieldens Ltd represented by Boyer Planning (Mr. James Bailey)

Summary:

It is noted that the Councils' initial combined OAN figure is 17,771 dwellings over the plan period. However there is some concern that this could be higher, given the DCLG proposed figure as part of the Standard Methodology Consultation, which indicates a combined figure of 22,264 dwellings. The Council may be subject to a future increase in their housing requirement, and if that is the case, then additional sites will be necessary.

More details about Rep ID: 11950

Representation ID: 11937

COMMENT Home Builders Federation (HBF) (Mr Mark Behrendt)

Summary:

It is important that all the authorities in this HMA continue to work together to ensure needs are met. It is likely that Babergh and Mid Suffolk will need to take a proportion of any unmet needs arising in IBC. We are also concerned that the level of housing needs arrived at through the Strategic Housing Market Assessment (SHMA), and set out in the consultation document, is not sufficient. In particular we consider that the SHMA should have taken more account of market signals.

More details about Rep ID: 11937

Representation ID: 11934

OBJECT The Trustees of the Tollemache 1965 Settlement represented by Strutt & Parker (Sam Hollingworth)

Summary:

the NPPF makes clear (paragraph 14) that Local Plans should meet objectively assessed needs with sufficient flexibility to adapt to rapid change. If the JLP were to merely aim to meet the OAN, it would not be sufficiently flexible to respond to changes circumstances, such as allocated sites failing to come forward as expected / changes in OAN. Failing to ensure the Local Plan's housing target exceeds the minimum OAN risks a situation in which the JLP fails to ensure an adequate five-year housing land supply during the entirety of the plan period, which would render the local plan out of date.

More details about Rep ID: 11934

Representation ID: 11932

OBJECT The Trustees of the Tollemache 1965 Settlement represented by Strutt & Parker (Sam Hollingworth)

Summary:

Imperative that the JLP meets the development needs of the Districts, including in relation to housing. The NPPF makes clear that Councils should seek to boost significantly housing supply. Proposed approach should therefore treat the OAN very much as a minimum, and should ensure strategies are in place to exceed this figure.

JLP must be mindful of the Government's consultation on standardised methodology for calculating OAN. The current drafting of the option does not make allowances to cover an increased OAN as set out by the standardised methodology. The JLP should seek to ensure that potential increases in housing need / Government requirements are accounted for.

More details about Rep ID: 11932

Representation ID: 11812

OBJECT Mrs Julie Clark

Summary:

Housing Requirement 2014 to 2036 - Option HR1 - 7,820 new houses based on population growth.
o DON'T AGREE WITH THIS - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
o Relocation of major industries, effects of 'Northern Powerhouse and HS2.
o 10% uplift to increase supply/reduce sale price/increase affordability.
o Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated

More details about Rep ID: 11812

Representation ID: 11757

OBJECT Amber REI represented by Pegasus Group (Mr David Onions)

Summary:

The Council recognise that delivery of new housing in the districts can be an issue. It is also significant that neither District can identify a 5 year housing land supply. It is also evident from the most recent AMR that in Mid-Suffolk District only in 2013/14 has the Council ever met its annualised housing requirement. With these obvious signs of non-delivery the Council should be identifying more housing than merely the minimum based on OAN as suggested in the single option HR1-OAN. There is clear need to build in a mechanism to deliver more housing as both districts appear to be struggling to do so even when conditions are relatively buoyant. As a consequence additional housing land should be identified at the outset.

More details about Rep ID: 11757

Representation ID: 11753

OBJECT Mr & Mrs Heather & Michael Earey

Summary:

Housing Requirement 2014 to 2036 - Option HR1 - 7,820 new houses based on population growth.
*DON'T AGREE WITH THIS - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
*Relocation of major industries, effects of 'Northern Powerhouse and HS2.
*10% uplift to increase supply/reduce sale price/increase affordability.
*Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated

More details about Rep ID: 11753

Representation ID: 11748

OBJECT Councillor Frank Lawrenson

Summary:

Due to the slow-down in house building across Babergh, it would appear to be a mistake to set the housing level any higher than the OAN of 355, as the effect of not completing on those would mean that Babergh's plan becomes invalid very quickly.

More details about Rep ID: 11748

Representation ID: 11658

COMMENT Haughley Park Consortium represented by Boyer Planning (Mr. James Bailey)

Summary:

We are concerned with the Councils' initial combined OAN figure of 17,771. This is considerable lower (nearly 20%) than the DCLG's proposed figure included within their consultation document. Whilst this document is in its preliminary stages, the disparity in figures suggest that the Council may be subject to a future increase in housing requirement, as highlighted in the table on page 5 of the full submission.

More details about Rep ID: 11658

Representation ID: 11626

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

Summary:

Need to take full account of the implications of the Government's proposed formula for assessing housing needs - this will represent a 25% increase in the overall housing requirement figure specified.

It is stated that analysis of delivery in recent years suggests that exceeding OAN could prove challenging. Whilst this might indeed be the case, the fact is if the Government's proposed housing methodology is implemented, the Councils will indeed need to significantly increase the currently stated OAN figure.

More details about Rep ID: 11626

Representation ID: 11600

OBJECT South Suffolk Constituency Labour Party (Ms Emma Bishton)

Summary:

Population of Babergh is predicted to grow by 8,000 in the next 20 years, with an average household size of 2.3 people. Proposed OAN is for a further 7,820 households. Even assuming a proportional increase in single persons households, it is not clear why the OAN establishes an increase in houses almost equal to the growth in the number of residents. Appreciate that the OAN may take into account additional housing pressures from surrounding districts. If this is the case, why is this additional need not reflected in the anticipated increase in population of 8000?

Need to be clear what figures are being used, how they relate to each other, and what the implications are for infrastructure as well as housing development. Without this clarity, the developments in infrastructure required to meet increased population need may be significantly under-estimated.

More details about Rep ID: 11600

Representation ID: 11538

OBJECT Annette Powell

Summary:

* Effects of BREXIT on domestic and overseas migration have been completely ignored and yet as the main element of any population growth shown in the historic data any migration changes due to Brexit will have he biggest effect.
* Brexit and HS2 will also effect the direction of any Migration potentially reversing growth.
* Relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability is unsound because house and wage Medians do not account for increasing cash ritch migration from city against City commuters not showing a local wage.
* Housing need derived from population growth appears to be based almost entirely on single occupancy which is absurd and probably needs reconsideration to about half of that for average occupancy rates.

More details about Rep ID: 11538

Representation ID: 11493

COMMENT McCarthy & Stone Retirement Lifestyles Ltd. represented by The Planning Bureau Ltd (Miss Carla Fulgoni)

Summary:

Local planning authorities should make an assessment of the percentage of their OAN for housing which should comprise housing for older people across all the relevant classifications. Overall percentage should be broken down in to the need for different categories of housing for older people according to an analysis of the market, supply and demographic context.

Delivering Retirement Housing is very different from open market housing schemes. Most likely be apartment type development having to respond to the brownfield constraints of the site and constraints that surround. Has different viability and risk characteristics. Policy should be able to fairly test the viability of sites on an individual basis.

More details about Rep ID: 11493

Representation ID: 11362

COMMENT Greater London Authority (Juliemma McLoughlin)

Summary:

We welcome the Council's commitment to meeting its housing need in full including a reserve-site approach as contingency.

More details about Rep ID: 11362

Representation ID: 11359

COMMENT Stour & Orwell Society (Ms Emma Proctor King)

Summary:

We agree with the general approach, but fail to see why you are starting from 2014. You are missing a trick here. The period for which you are planning should start from 2016 or 2017. That way, any underperformance in past years has no impact upon the 5 year housing land supply calculation. Put bluntly, you are making an unnecessary rod for your own backs - and for those who have to suffer the impacts of ad hoc planning applications submitted to meet a 5 year housing land supply deficit. Please review as a matter of urgency.

More details about Rep ID: 11359

Representation ID: 11329

SUPPORT Eleanor & Guy Barker & Mrs V Aitken represented by Savills (Mr William Lusty)

Summary:

Essential that the Councils plan to meet growth requirements in a sustainable way, in accordance with Government planning policy. NPPF requires a 'step change' in housing growth by planning positively in meeting objectively assessed needs. As such, the Councils must take a positive approach in ensuring that growth requirements are met.

Housing growth provides key support to economic growth and given the importance of economic considerations within the context of sustainable development, the Councils should prioritise housing delivery to serve this purpose. As such, we support the Councils' proposed option to plan to meet its objectively assessed need

More details about Rep ID: 11329

Representation ID: 11321

OBJECT Sproughton Playing Field (Damian Lavington)

Summary:

* I don't agree with this - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
* You do not take into account the relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability. How can you achieve this without legislation (which you do not have the power to do)?
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated

More details about Rep ID: 11321

Representation ID: 11215

OBJECT Bildeston Parish Council (Mr David Blackburn)

Summary:

We consider that insufficient allowance has been made in the housing need calculation for windfall sites, taking into account the historic contribution which these have made. We also question why the housing requirements appear to substantially outstrip the projected population growth.

More details about Rep ID: 11215

Representation ID: 11194

OBJECT Mr Nigel Roberts

Summary:

The Housing OAN estimates 2014-36 need to factor in Brexit explicitly (Q7-Q10). Likely demand will shrink if economy does and jobs fall away.

More details about Rep ID: 11194

Representation ID: 11165

COMMENT Mr S Ruffell represented by Strutt & Parker (Mr Michael Ward)

Summary:

OAN should be seen as a minimum, rather than a ceiling. This is confirmed through Government Policy. Therefore the Draft Joint Local Plan should recognise the OAN as a minimum.

NPPF paragraph 14 emphasises that Local Plans should meet OAN with sufficient flexibility to adopt rapid change. Aiming for a higher figure will make the plan more likely to be 'future proof'. Governments consultation on standardised methodology sets a higher OAN. The current drafting of the option does not make allowances to cover an increased OAN. Wording such as minimum target must be incorporated.

More details about Rep ID: 11165

Representation ID: 11163

SUPPORT Old Newton Parish Council (Mrs Karen Price)

Summary:

Agree with option HD2 as we currently have two major building projects in for planning development and we would naturally assume they are included within the village quota expected.

More details about Rep ID: 11163

Representation ID: 11086

OBJECT Catesby Estates Limited represented by Strutt & Parker LLP (Jen Carroll)

Summary:

Proposed approach to housing delivery in the draft joint Local plan should recognise the OAN as a minimum. Local Plans should meet OAN, with sufficient flexibility to adopt to rapid change, ensuring that Local Plans are 'future proof' and able to adapt for increased housing demands.

Importance of flexibility is highlighted by the publication of the Government's consultation on standardised methodology for calculating OAN, which represents an increase of 84 additional dwellings per annum. The current drafting of the option does not make allowances to cover an increased OAN, wording such as 'minimum target' or similar must be incorporated to ensure compliance with the NPPF.

More details about Rep ID: 11086

Representation ID: 11064

COMMENT John Miles & Sons represented by Strutt & Parker (Sam Hollingworth)

Summary:

OAN should not been seen as a ceiling which cannot be exceeded. Proposed approach should treat the OAN as a minimum, and should ensure strategies are in place to exceed this figure to comply with the NPPF.

NPPF Paragraph 182 requires Local Plans to consider the unmet needs of neighbouring authorities, and we would urge the Councils to consider the needs of other authorities.

JLP must be mindful of the Government's consultation on standardised methodology for calculating OAN. This exemplifies the need to avoid merely meeting current OAN. Current draft does not make allowances to cover an increased OAN, the JLP should do this. JLP needs to be sufficiently flexible to respond to changing circumstances.

More details about Rep ID: 11064

Representation ID: 10943

OBJECT Babergh Alliance of Parish & Town Councils (Helen Davies)

Summary:

Notwithstanding the fact 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 therefore ask the Councils to engage with BAPTC on the detail of housing requirement.

More details about Rep ID: 10943

Representation ID: 10942

OBJECT Babergh Alliance of Parish & Town Councils (Helen Davies)

Summary:

No alternatives are proposed. Brett Associates report contains several caveats. For example, the base data has no assessment for scenarios concerning Brexit.

The Government's preferred methodology is based on earnings to property price ratios. As this measure fails to allow for key factors, such as wider migration from high priced areas, the investment of available capital by older people who have fewer inflation proof havens for their wealth, plus the interaction of all these market forces, it is inevitable that perceived demand will continue to struggle to match actual supply.

Regrettable that the report does not provide sufficient, well targeted original research to provide an insight into these issues.

More details about Rep ID: 10942

Representation ID: 10901

COMMENT Lady Anne Windsor Charity (Deborah Langstaff)

Summary:

In the absence of further evidence Option HR1 is supported

More details about Rep ID: 10901

Representation ID: 10888

OBJECT Bloor Homes Eastern represented by Strutt & Parker (Sam Hollingworth)

Summary:

If the JLP were to merely aim to meet the OAN, it would not be sufficiently flexible to respond to changes circumstances, such as allocated sites failing to come forward as expected. Failing to ensure the Local Plan's housing target exceeds the minimum OAN risks a situation in which the JLP fails to identify an adequate five-year housing land supply during the entirety of the plan period, which would render the local plan out of date.

Does not make allowances to cover an increased OAN. The JLP should seek to ensure that potential increases in housing need / Government requirements are accounted for.

More details about Rep ID: 10888

Representation ID: 10804

OBJECT Mrs Carol Marshall

Summary:

Housing Requirement 2014 to 2036 - Option HR1 - 7820 new houses based on pop. growth.
* I do not agree with this: numbers seem overstated with no apparent account taken of effects of BREXIT on domestic and overseas migration.
* Relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability.
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3)

More details about Rep ID: 10804

Representation ID: 10759

SUPPORT Mendlesham Parish Council (Mrs Sharon Jones )

Summary:

Yes

More details about Rep ID: 10759

Representation ID: 10615

OBJECT Mrs LP Wheatley

Summary:

Do not agree.
Additional houses are not needed in Sproughton and surrounding villages.

More details about Rep ID: 10615

Representation ID: 10607

OBJECT Ms Caroline Powell

Summary:

* Effects of BREXIT on domestic and overseas migration have been completely ignored and yet as the main element of any population growth shown in the historic data any migration changes due to Brexit will have the biggest effect.
* Brexit and HS2 will also effect the direction of any Migration potentially reversing growth.
* Relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability is unsound because house and wage Medians do not account for increasing cash rich migration from city against City commuters not showing a local wage.
* Housing need derived from population growth appears to be based almost entirely on single occupancy which is absurd and probably needs reconsideration to about half of that for average occupancy rates.

More details about Rep ID: 10607

Representation ID: 10599

OBJECT Harrow Estates (Miss Cindy Wan)

Summary:

There is evidence to suggest that the housing target for the plan period should be set at a level higher than identified in the SHMA. Using the proposed methodology in the DCLG's current consultation on housing need, Babergh is to provide 439 dpa and Mid Suffolk is to provide 573 dpa. As the emerging JLP is currently expected to be submitted for examination in summer 2018, it is likely that Babergh & Mid Suffolk will be required to adopt the new standardised method and as a result will be required to plan to meet these increase levels. Unclear whether any discussions have taken place with neighbouring authorities to confirm whether any unmet needs will need to be considered.

More details about Rep ID: 10599

Representation ID: 10562

OBJECT Hopkins Homes Ltd represented by Armstrong Rigg Planning (Mr Geoff Armstrong)

Summary:

The current Objectively Assessed Need (OAN) figures are insufficient to enable the Plan to meet the needs of Babergh and Mid Suffolk and contribute towards the strategic requirements for East Anglia. A more aspirational approach towards housing delivery is required to ensure that each authority can reverse recent trends of under-delivery and under-investment and can assume any uplift that will be introduced upon the implementation of the Government's standard methodology.
The total requirement for Babergh should be 10,948 homes with an annualised requirement of 498 homes. The total requirement for Mid Suffolk should be 13,931 homes with an annualised requirement of 633 homes.

More details about Rep ID: 10562

Representation ID: 10551

COMMENT Countryside Properties (Mrs Emma Woods)

Summary:

The recent publication of the Governments consultation for the standardised approach to assessing housing needs suggests that for Babergh the assessment of need is 84 units per annum lower than the Governments methodology for the period to 2026. As it is a consultation document, only minimal weight can be given to its content at present. However, it does provide an indication as to what the Government considers to be an appropriate assessment of housing needs and how market signals should be taken into account. It also confirms that the Government attach significant weight to the robustness of the Household Projections as outlined in Planning Practice Guidance. It is important that the Council continues to ensure that its own assessment of needs are appropriate and in line with current national policy and guidance.

More details about Rep ID: 10551

Representation ID: 10544

OBJECT Alison Barratt

Summary:

There is also a fundamental oversight in the mix, in that the effects of Brexit has not been considered, either in trade, employment or migration calculations.
JLP 20 year projections based on historic data, all pre Brexit Vote, and the bulk of growth came from migration, so are likely to be very over optimistic.

More details about Rep ID: 10544

Representation ID: 10531

OBJECT Mr john barratt

Summary:

There is also a fundamental oversight in the mix, in that the effects of Brexit has not been considered, either in trade, employment or migration calculations.
JLP 20 year projections based on historic data, all pre Brexit Vote, and the bulk of growth came from migration, so are likely to be very over optimistic.

More details about Rep ID: 10531

Representation ID: 10518

OBJECT Mr Joe Lavington

Summary:

* I don't agree with this - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
* You do not take into account the relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability. How can you achieve this without legislation (which you do not have the power to do)?
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated

More details about Rep ID: 10518

Representation ID: 10466

OBJECT Mr Joe Lavington

Summary:

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: 10466

Representation ID: 10461

OBJECT Wendy Lavington

Summary:

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: 10461

Representation ID: 10410

OBJECT Wendy Lavington

Summary:

* I don't agree with this - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
* You do not take into account the relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability. How can you achieve this without legislation (which you do not have the power to do)?
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated

More details about Rep ID: 10410

Representation ID: 10399

COMMENT Delphi Diesel Systems represented by Colliers International (Mr Leigh Thomas)

Summary:

We welcome that the Councils have indicated in the emerging Local Plan that the housing requirement will be set at the level of the OAN. In order to ensure that the housing requirement can be met over the Plan period, it will be necessary to ensure that sufficient sites are identified and allocated for residential use.

Given the importance of providing an adequate supply of housing for the District, particularly in the context of the historic undersupply outlined in the emerging Local Plan at page 22, Delphi are exploring whether a future redevelopment scheme could incorporate residential use.

More details about Rep ID: 10399

Representation ID: 10235

COMMENT Taylor Wimpey represented by Boyer Planning (Kate Kerrigan)

Summary:

We are concerned with the Councils' proposed OAN figure and its difference between the DCLG's proposed figure included within their consultation document We welcome the Councils' recognition that it is prudent to allocate contingency sites in order to provide a degree of certainty that the requirement will be met should the original allocations be substantively delayed or not progressed.We also consider that, in determining the allocation of sites, the Council should view sites which are owned entirely by developers favourably, as this will ensure the deliverability of such sites

More details about Rep ID: 10235

Representation ID: 10058

COMMENT Historic England (Katie Parsons)

Summary:

We do not have a view on the exact figure, but the impact on the
historic environment will be important.

The capacity for the area to accommodate new housing development whilst
maintaining its historic environment should be a key consideration, so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be a priority. Allocations should be considered in the most sustainable locations and should get the right densities and character appropriate to the area. This will require a careful and detailed analysis - the historic environment is a critical factor.

More details about Rep ID: 10058

Representation ID: 9982

OBJECT Charlotte Lavington

Summary:

* I don't agree with this - Numbers seem overstated - no apparent account taken of effects of BREXIT on domestic and overseas migration.
* You do not take into account the relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability. How can you achieve this without legislation (which you do not have the power to do)?
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3) therefore 7,820 is over-stated

More details about Rep ID: 9982

Representation ID: 9915

OBJECT Professor Robert Turner & Mrs J.M. Turner

Summary:

As mentioned above, the Council should insist on the "affordable" houses being built first. Of course the developers will claim that this is not practicable and that only by building expensive houses for profit can they afford later to build the less profitable houses for the families who in reality have a greater and more urgent need.

More details about Rep ID: 9915

Representation ID: 9843

COMMENT Stowupland Parish Council (Claire Pizzey)

Summary:

Will this option be affected by the spreadsheet accompanying the Planning for the right homes in the right places: consultation issued by DCLG in September?

More details about Rep ID: 9843

Representation ID: 9808

OBJECT Merton College, Oxford represented by Savills (Mr James Yeoman)

Summary:

We note the proposed new standard methodology for housing need was published for consultation in September 2017 by the Department for Communities and Local Government. Using the proposed methodology, Babergh and Mid Suffolk Councils' OAN will increase to 439 and 573 homes respectively.

The proposed transitional arrangements reports the new standardised method should be used unless the plan will be submitted for examination on or before 31 March 2018. This time deadline will not be achieved in respect of the new Plan and as such it is strongly recommended that any option for housing requirements take full account of the Government's consultation on calculating housing need.

More details about Rep ID: 9808

Representation ID: 9693

OBJECT Miss R P Baillon

Summary:

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/.

More details about Rep ID: 9693

Representation ID: 9635

COMMENT Mr Chris Marshall

Summary:

* I do not agree with this: numbers seem overstated with no apparent account taken of effects of BREXIT on domestic and overseas migration.
* Relocation of major industries, effects of 'Northern Powerhouse and HS2.
* 10% uplift to increase supply/reduce sale price/increase affordability.
* Housing need based on projected 1.03 persons per dwelling (past average has been 2.3)

More details about Rep ID: 9635

Representation ID: 9515

OBJECT Cllr John Hinton

Summary:

NO! I assume you mean HD1 and not HR1. Please get the designation correct:-
HD2 is more acceptable as Babergh has consistently granted permissions, currently 2,320 (page 21) which have not been started ;- land banking will always be a problem and should not be encouraged by oversupply of land which will keep house process high and defeat the objectives of numbers built.

More details about Rep ID: 9515

Representation ID: 9423

SUPPORT Bacton Parish Council (mrs tina newell)

Summary:

Agree

More details about Rep ID: 9423

Representation ID: 9373

SUPPORT Beyton Parish Council (Ms Adele Pope)

Summary:

Whilst agreeing with HR1 we think the council needs to consider adopting a lower ratio of affordable to unaffordable housing in villages such as Beyton to ensure developers build such houses when only small developments are being considered.

More details about Rep ID: 9373

Representation ID: 9322

OBJECT J W Baldwin Farms represented by Pegasus Group (Mr Robert Barber)

Summary:

As currently proposed 'Option HR1 - OAN' will not deliver the housing need Babergh and Mid Suffolk require. Accordingly, my client objects to this element of the Consultation Paper and would expect to see further housing need options presented in future drafts of the Plan following a review of SHMA methodology.

More details about Rep ID: 9322

Representation ID: 9319

OBJECT Mrs Mel Seager

Summary:

- Housing needs overstated. No regard for likely effects of Brexit.
- Potential relocation of major industries to continental Europe. Projected employment growth in Professional and Business services sectors vulnerable. Uncertainty on Brexit and levels of overseas migration, with emphasis on "Northern Powerhouse" and HS2.
- JLP must take account of the most likely possibilities and be based on revised data.
- "market signals uplift", judgement applied for Babergh is 15%, seems excessive when all other Districts are at 10%.
- Projected population increase not well explained.
- JLP needs in-built flexibility to regularly deal with changes in housing need.

More details about Rep ID: 9319

Representation ID: 9269

OBJECT Elmsett Parish Council (Andrea Newman)

Summary:

We find it difficult to understand the so called objectively assessed need for 7820 new homes from 2014 to 2036 and do not believe it is a proven need.

More details about Rep ID: 9269

Representation ID: 9250

OBJECT W H Jardine represented by Phase 2 Planning & Development Ltd (Mr Kevin Coleman)

Summary:

Alternative Options to HR1 relating to a consideration of meeting Ipswich's unmet need and relating to affordable housing delivery should be considered.
In addition to these options, the draft standard methodology for calculating OAN now suggests higher rates of OAN for both Babergh and Mid Suffolk than the SHMA indicates.

More details about Rep ID: 9250

Representation ID: 9232

OBJECT The Gooderham Family and ESCO Developments Ltd represented by Cheffins Planning & Development (Mr Jon Jennings)

Summary:

The plan does not consider the current consultation 'right homes in the right places'

More details about Rep ID: 9232

Representation ID: 9183

OBJECT Mr Ken Seager

Summary:

Do NOT agree. The housing need may well be overstated. The report uses historic patterns of migration, extrapolated forwards to arrive at a projected population growth, but no regard seems to have been given for the effects on migration due to the UK leaving the EU. Effects are likely to reduce the forecast need for new housing.

Projected employment growth in the Districts may be particularly vulnerable. Emphasis on the "Northern Powerhouse" and HS2 could significantly increase outwards migration. Market signals uplift is higher in Babergh (15%) than other districts in the report (10%). The consultation document does not explain in simple enough detail how a projected population increase over the period of the JLP in Babergh of 8086 persons translates into an OAN of 7820 dwellings.

More details about Rep ID: 9183

Representation ID: 9165

OBJECT J D Pickett

Summary:

The number of houses required seems to be overstated and takes little or no account of the effects of amongst other things, BREXIT and the relocation of major industries, etc.

More details about Rep ID: 9165

Representation ID: 9154

OBJECT Wendy Shorrock

Summary:

The Housing requirement 2014 to 2036 appears overstated @7820, particularly as this is based on 1.03 persons per house, as opposed to past average of 2.3. This begs the question of whether this forecast is current and has taken full account of our leaving the EU, and related domestic and overseas migration estimates.

More details about Rep ID: 9154

Representation ID: 9142

OBJECT Mr Bay Knowles represented by Keymer Cavendish Limited (Mr Edward Keymer)

Summary:

New national district figures show Mid Suffolk needing 570 dwellings a year:
570 x 22 years = 12,540

More details about Rep ID: 9142

Representation ID: 8942

COMMENT Andrew Searle

Summary:

Objectively Assumed Need probably bares no relationship to housebuilders perception of houses sold, and therefore new starts.

More details about Rep ID: 8942

Representation ID: 8737

COMMENT Mr Philip Schofield

Summary:

HR1/OAN ignores the commitments & completions since it was determined. As such it overstates the required housing significantly - is there a calculation/justification for the size of this gap?

More details about Rep ID: 8737

Representation ID: 8703

SUPPORT Cllr John Field

Summary:

For a number of reasons allocated sites may not be delivered and if there is no contingency the existence of a valid five year land supply may again be questioned

More details about Rep ID: 8703

Representation ID: 8506

OBJECT Mr David Pettitt represented by Keymer Cavendish Limited (Philippa Hull)

Summary:

New national district figures show Mid Suffolk needing 570 dwellings a year: 570 x 22 years = 12,540

More details about Rep ID: 8506

Representation ID: 8254

SUPPORT Acton Parish Council (Mr Paul MacLachlan)

Summary:

The Council agrees with the principle of an annualised requirement set out under HR1.

More details about Rep ID: 8254

Representation ID: 7923

COMMENT Suffolk Preservation Society (Bethany Philbedge)

Summary:

Yes we agree with the application of the OAN formula as set our under Option HR1. However for housing delivery prefer HD2 which meets the identified need. We do not agree with HD1 which applies a contingency as the case to oversupply via additional reserve development sites has not been made. The failure to deliver housing requires measures from central government to ensure developers implement extant consents rather than local councils allocating more greenfield sites for development.

More details about Rep ID: 7923

Representation ID: 7899

SUPPORT Hadleigh Town Council (Mrs Carol Bailey)

Summary:

HTC accepts the requirement

More details about Rep ID: 7899

Representation ID: 7893

OBJECT Tattingstone Parish Council (mrs Jane Connell-Smith)

Summary:

Tattingstone Parish council would back HD2. We feel there is no need for reserve sites as this would lead to constant speculation that additional sites will come forward and would be a developers' charter.

More details about Rep ID: 7893

Representation ID: 7592

OBJECT Mrs Annette Brennand

Summary:

The approach is based on historical data; this seems inappropriate in light of Brexit and the resultant uncertainty re. its long term impact on inward / outward migration, location of industries and economic growth more broadly. Also lacks analysis of impact of HS2 and focus on the Northern Powerhouse. The JLP should have built in flexibility to be able to respond to changing need.
Unclear how projected population growth translates to the objectively assessed need

More details about Rep ID: 7592

Representation ID: 7301

OBJECT Dr DAVID Brennand

Summary:

The approach is based on historical data; this seems inappropriate in light of Brexit and the resultant uncertainty re. its long term impact on inward / outward migration, location of industries and economic growth more broadly. Also lacks analysis of impact of HS2 and focus on the Northern Powerhouse. The JLP should have built in flexibility to be able to respond to changing need.
Unclear how projected population growth translates to the objectively assessed need.

More details about Rep ID: 7301

Representation ID: 7299

OBJECT Mr Mark Blackwell

Summary:

I don't understand the Option. The consultation document is not a simple document to follow and contains significant technical language. If it means that sites should be allocated over and above the needs then no. The sites are overwhelmingly owned by developers who have banked land for years. This plan only serves to encorage this behaviour and restrict opportunity for Suffolk residents and stops a more organic growth. The plan as i understand it is no more than a surrender to developers.

More details about Rep ID: 7299

Representation ID: 7263

OBJECT Mr Andrew Sterling

Summary:

The stated alternatives are false dichotomies. The concept of 'affordable housing' and its popularly associated terminology, 'housing need' are entirely misleading, as affordable housing is based on 80% of full market value, which, in these districts, remains unaffordable, so not meeting 'housing need'.
Actual housing need largely requires social housing - and that is that.
If development land was to be assessed on this criterion, then the picture would be entirely different re the demand for land.
But unfortunately the pressures to capitalise from the actual housing need comes from many interested quarters, including councils' housing bonus.

More details about Rep ID: 7263

Representation ID: 7035

OBJECT Ms Sharon Maxwell

Summary:

In the current climate with regard to Brexit and the possible migration both domestic and international that would have an effect on the JLP. There is an enormous emphasis on developing the "Northern Powerhouse" and HS2 which would lower the need for the amount of housing proposed. The consultation document needs to reflect the needs of the community, highlighting any problem such as local housing needs, dealing with the infrastructure etc. and preserving the local heritage and "village".

More details about Rep ID: 7035

Representation ID: 7011

COMMENT Great Waldingfield PC (Mr Cecil Allard)

Summary:

Dictated by Sout requirements. No choice

More details about Rep ID: 7011

Representation ID: 6903

OBJECT Mx Miles Row

Summary:

No because this can mean that contingency sites are given planning permission to start building before building has started on allocated sites

More details about Rep ID: 6903

Representation ID: 6892

COMMENT Thurston Parish Council (Mrs Victoria Waples)

Summary:

It appears to be logical to follow the proposed approach set out under Option HR1. However, the Parish Council feels that there is a need to have a consistent approach to assessing local housing need and also the ability for local plans to be reviewed on a consistent basis. It is important that all assessments take into account local circumstances and properly consider the deliverability of underlying infrastructure needs.

More details about Rep ID: 6892

Representation ID: 6867

COMMENT Mrs Linda Rushton

Summary:

Rather than having a number for all new dwellings I believe the types of dwelling should be identified and quantified, for instance number of detached houses/flats/bungalows, etc.

More details about Rep ID: 6867

Representation ID: 6834

OBJECT Mr Peter Powell

Summary:

The projections do not make any sense compared to the developing situation.

More details about Rep ID: 6834

Representation ID: 6813

COMMENT Botesdale & Rickinghall CAP Group (Mr. William Sargeant)

Summary:

7 Option HR1 is the logical outcome of the current data. Experience informs us that it will need adjustment before the end the plan period, and I would suggest a review and revision at a maximum of 10-yearly intervals.

More details about Rep ID: 6813

Representation ID: 6784

OBJECT Dr John Webb

Summary:

The claimed overall housing need seems to be overestimated and confused.
A figure of 1.03 persons per household appears to have been used, which implies a high proportion of single occupier houses - in which case why is the council considering a mix including only 35% or so affordable houses. A figure of 1.03 persons per dwelling implies a MUCH HIGHER affordable homes.

More details about Rep ID: 6784

Representation ID: 6704

SUPPORT Yaxley Parish Council (Mr Philip Freeman)

Summary:

Yes

More details about Rep ID: 6704

Representation ID: 6397

COMMENT Mr Robin Coates

Summary:

Consideration of the impact Brexit must be included in this analysis. It is already apparent that significant numbers of people who previously have opted to live and work in the UK from Europe are no longer doing so, e.g. the significant reduction in the number of European Nurses choosing to work in the UK.

More details about Rep ID: 6397

Representation ID: 6335

OBJECT MSDC Green Group (Cllr John Matthissen)

Summary:

Challenge numbers as according to 2011 census 4019 people have a second home in mid Suffolk. So do we need 9,951 more houses? (cited in Guardian Data Blog https://www.theguardian.com/news/datablog/2012/oct/22/second-homes-england-wales-detailed )

More details about Rep ID: 6335

Representation ID: 6303

OBJECT Barham Parish Council (Mrs Joanne Culley)

Summary:

To ensure a fair distribution this should be a strategic approach across all areas of Suffolk.

More details about Rep ID: 6303

Representation ID: 6275

COMMENT Freston Parish Council (Ms Elizabeth Aldous)

Summary:

No. We feel that this approach takes the "easy option" The inability of the District Council to deliver on the sites it has already given planning permission to should not define the approach to the new Joint Local Plan. There should be a clear examination of the problems that have led to this failure to deliver and a definition of possible solutions

More details about Rep ID: 6275

Representation ID: 6248

SUPPORT Webb & Son (Combs) Ltd represented by Carter Jonas (Ben Ward)

Summary:

The approach set out under HR1 is consistent with national planning policy.

More details about Rep ID: 6248

Representation ID: 6129

OBJECT Sproughton Parish Council (Mrs Susan Frankis)

Summary:

Figures don't support option HR1.
Figures over inflated.
No account taken of affects of Brixit, HS2 and the "Northern Powerhouse", housing numbers appear to be based on an occupation level of just over 1 person per dwelling whereas the current average is ~2.3, a 10% uplift has been applied to increase supply/reduce sale price/increase affordability. This appears to be an arbitrary figure with no supporting evidence. Developers will limit supply to maximise house price and profit.

More details about Rep ID: 6129

Representation ID: 6016

OBJECT Endurance Estates represented by Savills (Mr Paul Rowland)

Summary:

There is no robust assessment of reasons for historic under-delivery or explanation how this will be addressed. Higher target should not be ruled out simply because 'challenging'. Market evidence is smaller rural sites deliver faster.
No evidence that contingency sites will urgently speed up delivery. More deliverable rural sites should be introduced now. Likelihood of higher OAN figures from Government support this approach.

More details about Rep ID: 6016

Representation ID: 5829

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: 5829

Representation ID: 5816

SUPPORT Little Waldingfield Parish Council (Mr Andy Sheppard)

Summary:

LWPC supports

More details about Rep ID: 5816

Representation ID: 5758

OBJECT KBB (Keep Bildeston Beautiful) (John Beales)

Summary:

The devil is in the detail; once you dig down into the actual process, the historically proven year-on-year contribution to Babergh's housing from windfall sites is nowhere near equally reflected in the allowance made within the forward 5 Year Housing Land Supply Assessment.

Raising the expected contribution from windfall sites to a more realistic level would help restore and maintain the benchmark 5 years of housing land supply requirement without which, the Council currently remains exposed to almost any planning application put before it that can be presented as "sustainable" in planning terms.

More details about Rep ID: 5758

Representation ID: 5536

OBJECT Mr Graham Moxon

Summary:

The risk with this approach is that less suitable land will be included in the plan and subsequently developed.

More details about Rep ID: 5536

Representation ID: 5532

COMMENT ms sally sparrow

Summary:

No.
The housing needs apear to be overstated and don't appear to take account of the Brexit outcomes. A hard Brexit will affect both migration, immigration as well as the locations of various industries. The government emphasis on the Northern Powerhouse will likely create jobs and therefore people moving north rather than to East Anglia.It is unclear how the projected population increase translates into a need for so many dwellings. There needs to be a built in flexibility over the life span of the JLP.

More details about Rep ID: 5532

Representation ID: 5442

COMMENT Denham Parish Council (Sarah Foote)

Summary:

Denham Parish Council agrees as the requirement seems to be evidence based.

More details about Rep ID: 5442

Representation ID: 5196

COMMENT Mr Terence Gray

Summary:

What alternatives can we base any other proposals?

More details about Rep ID: 5196

Representation ID: 5097

COMMENT Stradbroke Parish Council (Odile Wladon)

Summary:

Yes but we know that the figure is always changing.

More details about Rep ID: 5097

Representation ID: 4947

COMMENT Brantham Parish Council (Mrs Sarah Keys)

Summary:

Without understanding the methodology this is hard to do. It does appear that the OAN figure rises due to previous shortfalls.

More details about Rep ID: 4947

Representation ID: 4582

OBJECT Woolverstone Parish Council (Mr Simon Pearce)

Summary:

No. We feel that this approach takes the "easy option". The inability of the District Council to deliver on the sites it has already given planning permission to should not define the approach to the new Joint Local Plan. There should be a clear examination of the problems that have led to this failure to deliver and a definition of possible solutions. Furthermore, neither should this inability to deliver hitherto give reason to target soft areas like rural "greenfield" sites. Please adopt Option HD2.

More details about Rep ID: 4582

Representation ID: 4554

COMMENT Lavenham Parish Council (Carroll Reeve)

Summary:

No. HRI does not fully recognise the table above it on page 21. The number of new dwellings for Babergh District is thus reduced to 4,210 and then further reduced by Strategic Sites. Moreover, the number of proposed Social/Affordable housing units does not reconcile with the number of households registered with the authority seeking such accommodation.

More details about Rep ID: 4554

Representation ID: 4464

COMMENT Kersey Parish Council (Mrs Sarah Partridge)

Summary:

The Parish Council considers that there is not enough detail to be able to comment on option HR1. There needs to be more transparent calculations and forecasts.

More details about Rep ID: 4464

Representation ID: 4456

OBJECT Mr Carroll Reeve

Summary:

HRI does not fully recognise the table above it on page 21. The number of new dwellings for Babergh District is thus reduced to 4,210 and then further reduced by Strategic Sites. Moreover, the number of proposed Social/Affordable housing units does not reconcile with the number of households registered with the authority seeking such accommodation.

More details about Rep ID: 4456

Representation ID: 4352

OBJECT Mrs Stella Blackwell

Summary:

The HD1 proposal leaves communities based around 'reserve' sites with too much uncertainty for too long. The concern that houses may be built on a site at some point over the next 20 years has a massive effect on an individual's ability to sell a property for a particularly extended and unfair period of time (especially when neighbouring a proposed development). Community moral/spirit and even personal wellbeing are likely to suffer as a result of the uncertainty. Much better to set out where will/won't be built on from the out-set, then everyone knows where they stand and can plan accordingly.

More details about Rep ID: 4352

Representation ID: 4322

OBJECT Mrs Stacey Achour

Summary:

The use of contingency sites which were agreed when the preferred sites were put forward should be subject to further scrutiny if needed as other economic/local factors may mean they are no longer suitable. for this reason better to create plans that are current and for the need required only so we don't create housing that is undesirable/unaffordable or where develoment doesn't follow because a lack of potential.

More details about Rep ID: 4322

Representation ID: 4220

OBJECT Mr Tony Jackson

Summary:

Opportunistic development by developers could be encouraged by having strategic reserves.. they will quickly become a green light to get the reserves released.

More details about Rep ID: 4220

Representation ID: 4177

COMMENT Mrs Jackie Ward

Summary:

Will this option be affected by the spreadsheet accompanying the Planning for the right homes in the right places: consultation issued by DCLG in September?

More details about Rep ID: 4177

Representation ID: 4118

COMMENT Holton St Mary Parish Council (Ms Dorothy Steeds )

Summary:

Yes but if there is an objectively assessed need that should be the basis of decision-making as shown by HR1.

More details about Rep ID: 4118

Representation ID: 4007

OBJECT Mr Vic Durrant

Summary:

* This is a major concern - The requirements seem overstated and there appears to be no account taken of the effects of BREXIT on domestic and overseas migration.
* Little, if any, effects of Government Policy to relocate major industries to the North and the effects of the emphasis on the 'Northern Powerhouse' and the impacts of HS2, seem to have been considered.
* The provision of more affordable homes/ Council Housing that will increase supply/reduce sale prices/increase affordability.
* Housing need appears to be based on a projected 1.03 persons per dwelling (whereas the past average has been 2.3) Why?

More details about Rep ID: 4007

Representation ID: 3911

SUPPORT Mr Richard Fletcher

Summary:

Option HR1 is supported preferable as housing building required to exceed OAN Level does not seem realistically achievable. Also with higher growth levels Hadleigh could not readily accept such development without further irreversible damage to the town's character and its community.

More details about Rep ID: 3911

Representation ID: 3892

OBJECT Caverswall Holdings Ltd/Highbridge Properties plc and West Suffolk NHS Foundation Trust represented by CODE Development Planners Ltd (Ms Karen Beech)

Summary:

We object to the OAN need in the draft local plan and consider that the level should be increased to take account of market signals.

In addition the figure will need to be increased to take account of the recent DCLG consultation on objectively assessed housing need which indicates that using the proposed standard methodology will increase the level of housing need in Babergh from 355 to 439 dwellings per year.

More details about Rep ID: 3892

Representation ID: 3875

COMMENT Mr Alan Squirrell

Summary:

I would broadly agree with HD1, with the express condition that ONLY individual dwellings are built one by one by LOCAL builders. Once an area is attractive to a developer, local needs, infrastructure, sustainability, and quality of build go completely out the door, and the quickest profit is the ONLY consideration. This is NOT what our beautiful countryside, and wildlife can withstand.
Remember SUSTAINABILITY is an integral requirement of the Localism Act 2011

More details about Rep ID: 3875

Representation ID: 3832

OBJECT Mr John Bellwood

Summary:

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. No analysis of the effect of Brexit.

The application of a "market signals uplift" is unsupported by any evidence - 15% seems excessive when compared to others.

The consultation document does not explain in simple enough detail how a projected population increase over the period of the JLP in Babergh of 8086 persons translates into an OAN of 7820 dwellings. Past average occupancy is 2.3 persons per dwelling, giving a much lower need.

More details about Rep ID: 3832

Representation ID: 3766

OBJECT Mrs June Durrant

Summary:

* This is a major concern - The requirements seem overstated and there appears to be no account taken of the effects of BREXIT on domestic and overseas migration.
* Little, if any, effects of Government Policy to relocate major industries to the North and the effects of the emphasis on the 'Northern Powerhouse' and the impacts of HS2, seem to have been considered.
* The provision of more affordable homes/ Council Housing that will increase supply/reduce sale prices/increase affordability.
* Housing need appears to be based on a projected 1.03 persons per dwelling (whereas the past average has been 2.3) Why?

More details about Rep ID: 3766

Representation ID: 3747

OBJECT Mrs Louise Baldry

Summary:

Housing need is well be overstated. The SHMA does not take into account the likely effects of BREXIT such as: migration changes, immigration controls, and the relocation of businesses which are likely to reduce the forecast need for new housing.
HS2 and the "Northern Powerhouse" could locate employment opportunities along the HS2 corridor rather than East Anglia.

These potential impacts are real and significant.

More details about Rep ID: 3747

Representation ID: 3661

COMMENT Mr Alan Lewis

Summary:

The requirement is for 452 new houses/annum over the period. Assuming an affordable housing need of 97 houses/annum and that residual houses include affordable houses in the same ratio would give an average of 1:4.4 (affordable:new). Since developers are not required to provide affordable housing on sites of less than 10 houses, villages with only small sites available may not gain any affordable housing. The council should consider whether a lower limit for developers is appropriate in some circumstances.

More details about Rep ID: 3661

Representation ID: 3646

OBJECT Mr Neil Lister

Summary:

Don't accept that IBC has insufficient building land. Why is undeveloped land in Borough unavailable? Are mechanisms to release this.
How many vacant dwellings in HMA?
HMA should cover whole of Babergh; Suffolk Coastal; Mid Suffolk.

'Housing requirement' cannot be revised under 'other factors':
* Need to accommodate unmet need from elsewhere - incompetence's/inconveniences of other Councils shouldn't find a home in Babergh.
* Decision to increase the requirement for more affordable housing. What's the point of stating requirement when figure can be 'upped'?
* Aspirations for higher levels of growth. Published plan equals Babergh's requirement. Future aspirations don't count.

More details about Rep ID: 3646

Representation ID: 3551

OBJECT Bentley Parish Council (Dr Michael Bamford)

Summary:

The Parish appreciates the need for a new, refreshed, evidence based local plan. It accepts the need for an objectively assessed housing growth requirement, based on projected population growth, and the need for economic growth in Babergh, but notes there are very considerable variables in play which may materially change prospects for growth (e.g. Brexit). Whilst it is desirable to have an overview of desirable and achievable growth within a District, this will always be subject to the significant external pressures of political change, and external economic pressures e.g. the London housing and job market and consequent commuter demand. Local housing growth has been subject to piecemeal planning applications and external imperatives such as the NPPF

More details about Rep ID: 3551

Representation ID: 3502

OBJECT Mr Richard Howard

Summary:

numbers proposed disproportionate to actual requirement or even proposed requirement especially in this area.

More details about Rep ID: 3502

Representation ID: 3405

OBJECT Mr John Kitson

Summary:

Housing need may well be overstated. The SHMA does not take into account the likely effects of BREXIT such as: migration changes, immigration controls, and the relocation of businesses which are likely to reduce the forecast need for new housing during the life of the JLP. Projected employment growth may be vulnerable to relocation.

HS2 and the "Northern Powerhouse" could locate employment opportunities along the HS2 corridor rather than East Anglia.

These potential impacts are real and significant. The JLP must take the most likely possibilities into account and be based on revised data.

More details about Rep ID: 3405

Representation ID: 3285

COMMENT Braiseworth Hall Farms Limited represented by Evolution Town Planning (Mr David Barker)

Summary:

It is important to apply a contingency when allocating sites in the new Local Plan to
ensure sufficient sites are delivered over the Plan Period and to provide flexibility for
sites that don't come forward. The Framework seeks to ensure choice and
competition in the market for housing (paragraph 47) and the emerging Local Plan
should adopt the same principles. This is particularly important to ensure that
housing requirements are met going forward, given that Mid Suffolk are currently
unable to demonstrate a five year supply of deliverable housing sites.

More details about Rep ID: 3285

Representation ID: 3115

OBJECT Iain Pocock

Summary:

Historically much of the development has been of small sites not previously earmarked within plans, this together with likely lower population growth post Brexit should mean that the overall requirement is overstated and will inherently have a contingency embedded in it

More details about Rep ID: 3115

Representation ID: 2883

OBJECT Mr Graham Shorrock

Summary:

This appears to be looking at the housing requirements too parochially. If you look at the requirements listed just for Ipswich, Babergh and Mid Suffolk the forecast is for an extra 57000 houses with an implied population of approximately 125,400
Surely the only realistic way of accommodating such growth is for a brand new town with the appropriate infrastructure.

More details about Rep ID: 2883

Representation ID: 2847

COMMENT Diss & District Neighbourhood Plan Steering Group (Ms Deborah Sarson)

Summary:

The implications of the proposals in the White Paper: Planning for the right homes in the right places in terms of a standardised methodology and greater figure for growth are noted with great concern.

The DDNP Area will need to take cognisance of the specific housing requirement, arrived at jointly with South Norfolk and Mid Suffolk Districts. It is noted that the HMA used to derive the OAN does not include South Norfolk as that changed the outputs, therefore a local HMA may be required.

More details about Rep ID: 2847

Representation ID: 2830

SUPPORT Mr Andrew Coxhead

Summary:

Support

More details about Rep ID: 2830

Representation ID: 2802

COMMENT Mr Simon Wood

Summary:

It would appear that numerous sites have been made available with no regard for their location.
When granting permission consideration should be give to number of existing dwellings and a percentage increase for each village should be applied. Increasing a housing count from 550 to 2300 will lose any identity a village retains.

More details about Rep ID: 2802

Representation ID: 2581

SUPPORT Hadleigh Society (Margaret Woods)

Summary:

THE SOCIETY considers Option HR1 is preferable as attainment of the OAN requirement will be difficult as the annualised housing building required exceeds levels the district has ever achieved in recent times. Additionally it is considered that Hadleigh could not accommodate a higher level of growth without further irreversible damage to the town's character and its community.

More details about Rep ID: 2581

Representation ID: 2556

SUPPORT Cockfield Parish Council (Mr Doug Reed)

Summary:

Cockfield Parish Council supports option HD1.

More details about Rep ID: 2556

Representation ID: 2526

SUPPORT Mr Terry Corner

Summary:

Yes

More details about Rep ID: 2526

Representation ID: 2482

OBJECT Mr Brian HUNT

Summary:

No,s appear over stated , no account appears to be taken on Brexit migration or local available industry.

More details about Rep ID: 2482

Representation ID: 2415

COMMENT Preston St Mary Parish Council (Nicola Smith)

Summary:

The total requirement figure for Babergh is 7820, a clear breakdown of how that figure is achieved is not set out. It is unclear as to how up to date the figure is and further there are decisions being made imminently about possible strategic sites such as Chilton Woods that could significantly reduce that figure which could impact on the response given by Parish Councils, and therefore the number of housing that a Parish Council may consider as appropriate within their locality (see response to q5). This may be different if significant local housing development will reduce the overall housing need but most of it is being situated within easy distance and impacting on infrastructure such as hospital beds/medical needs etc.

More details about Rep ID: 2415

Representation ID: 2359

COMMENT Chelmondiston PC (Mrs Rosie Kirkup)

Summary:

We agree with Option HD1 that there should be a small contingency, but not so many that developers are tempted to choose only the easier sites.

More details about Rep ID: 2359

Representation ID: 2358

SUPPORT Fressingfield Parish Council (Mr Alexander Day)

Summary:

In principal the Parish Council agrees with HR1 however there needs to be greater detail to feel confident in the Consultation documents assertions.

HMA - if an adjacent Council fails to meet its target then MSDC could provide additional houses to assist that under delivering Council. Given that MSDC seems to be well ahead of its projections there should be very real concerns that the minimum planned may rise sharply to allow for slippage of adjacent councils.

Also likely to be additional houses built through 'windfall' development not been accounted for in the plans

More details about Rep ID: 2358

Representation ID: 2210

OBJECT Mrs Fiona Loader

Summary:

A balance needs to be struck between housing need and impact on existing settlements, infrastructure requirements and access routes as Babergh consists of many rural settlements and small roads to access them.
Therefore allocation should be to meet housing requirements and not a 'reserve' approach which removes he opportunity for democratic scrutiny by local residents

More details about Rep ID: 2210

Representation ID: 2037

SUPPORT Mrs Kathie Guthrie

Summary:

Support. This is about the future developments which will always be required.

More details about Rep ID: 2037

Representation ID: 1948

SUPPORT Mrs Tania Farrow

Summary:

This is an evidence based approach

More details about Rep ID: 1948

Representation ID: 1902

COMMENT Palgrave Parish Council (Sarah Foote)

Summary:

Yes. However, it is hoped that bringing empty housing stock back into use is also taken into account when calculating the figures. Please confirm.
The implications of the proposals in the White Paper: Planning for the right homes in the right places in terms of a standardised methodology and greater figure for growth are noted with concern.

More details about Rep ID: 1902

Representation ID: 1798

SUPPORT Debenham Parish Council (Mr Richard Blackwell)

Summary:

Agree with the proposed approach. The Objectively Assessed Need (OAN) seems a logical way to look at the situation.

More details about Rep ID: 1798

Representation ID: 1732

SUPPORT Mr Richard Blackwell

Summary:

Agree with the proposed approach. The Objectively Assessed Need (OAN) seems a logical way to look at the situation.

More details about Rep ID: 1732

Representation ID: 1691

SUPPORT Battisford Parish Council (Mr Chris Knock)

Summary:

Yes

More details about Rep ID: 1691

Representation ID: 1642

SUPPORT Hoxne Parish Council (Mrs Sara Foote)

Summary:

Hoxne Parish Council agrees with this approach.

More details about Rep ID: 1642

Representation ID: 1535

SUPPORT Mrs Elizabeth Schmitt

Summary:

There should be some contingency but this should be reviewed regularly against the level of windfall and infill sites that become available.

More details about Rep ID: 1535

Representation ID: 1515

OBJECT Mr. A. Breen

Summary:

Build houses where there is evidence of economic growth.

More details about Rep ID: 1515

Representation ID: 1438

OBJECT Barton Willmore Planning P'ship (Mr. Paul Foster)

Summary:

In line with the Department for Communities and Local Government document "Planning for the Right Homes in the Right Places", the standardised methodology would increase the OAHN in Mid-Suffolk from 452 dwellings per annum to 573 dwellings per annum, an increase of 27%. The policy should be redrafted to take into account the standardised methodology, which provides a starting point, and could potentially increase further. As a result, the Council will need to provide additional housing sites to meet this identified need.

More details about Rep ID: 1438

Representation ID: 1386

SUPPORT Mr Alf Hannan

Summary:

Yes

More details about Rep ID: 1386

Representation ID: 1224

SUPPORT Raydon Parish Council (Mrs Jane Cryer)

Summary:

In allocating sites, apply a contingency through a reserve sites approach.
It is inevitable that some sites identified will never actually be developed therefore it is prudent to assess and plan for reserve sites to allow positive consultation and appreciation of the issues and allow local stakeholders the opportunity to influence thinking on the acceptability or otherwise of reserve locations. This should allow sites to be removed from long term uncertainty re viability and avoid planning blight on adjacent properties which could be adversely affected by the prospect of housing development.

More details about Rep ID: 1224

Representation ID: 1205

SUPPORT Mrs Diana Chapman

Summary:

Using the OAN and Option HR1 is supported.

More details about Rep ID: 1205

Representation ID: 1074

OBJECT Simon Bell

Summary:

When you say, "HR1", do you mean "HD1"?

HD1 permits a contingency which allows for the allocation of housing sites above the objectively assessed Housing Need (OAN).

No method is set out for how the level of contingency will be set, objectively or otherwise.

"Windfall development" is not taken into account.

The Council should take an "infrastructure led" approach to Housing Need, by first establishing objectively where employment growth will take place and planning for communication improvements in road, rail and broadband and then allocating sites based around the developed infrastructure.

More details about Rep ID: 1074

Representation ID: 790

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

Summary:

We do not agree with the overall targets. We are unclear HR1 as to the base line used. Table 19 of the Sustainability Assessment does not include 9 years of "windfall houses" The 2 years that are recorded show 240 and 246 pa being built. The inclusion of 9 years of unrecorded windfall builds result in an additional 2160 having been built. We are unclear as to whether these 2160 houses have been factored into the calculations.

It is difficult to comment on the OAN as there is no discussion on the Peter Brett Paper. The paper has a lot of caveats and these are not exposed.

More details about Rep ID: 790

Representation ID: 524

OBJECT Redgrave Parish Council (Mr John Giddings)

Summary:

RPC objects because it will make delivery of affordable housing more difficult to control and will skew new housing away from the needs of the neighbourhood.

More details about Rep ID: 524

Representation ID: 166

COMMENT Mr D C Warren

Summary:

Once a development site is identified the number and type of houses to be built should be part of the planning process with no deviation allowed. So often developments have very few affordable houses and always seem to target the higher end of the market.

More details about Rep ID: 166

Representation ID: 106

OBJECT Mrs Sara Knight

Summary:

Given that there are plans for over half the projected requirement and that this is only a projection it would seem unnecessary to adopt HD1 when HD2 will still give sufficient flexibility to meet the housing requirements.

More details about Rep ID: 106

Representation ID: 70

SUPPORT J. E. Knock & Partners (Mr. Chris Knock)

Summary:

Farming, accommodation and leisure services

More details about Rep ID: 70

Representation ID: 68

SUPPORT Mrs Rosemary Shurmer

Summary:

I would broadly agree that some contingency for alternative sites be identified

More details about Rep ID: 68

Representation ID: 60

OBJECT mr stephen edevane

Summary:

there should be new roads to get to the property and not through existing estates

More details about Rep ID: 60

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