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Representations on BMSDC Joint Local Plan Consultation Document (Interactive) - Landscape, Heritage & Design

Representation ID: 13126

COMMENT Suffolk Coastal District Council (Mr Mark Edgerley)

Summary:

It is noted that BMSDC have commissioned evidence in respect of Landscape Guidance (2015) and that a sensitivity assessment is underway. Need to ensure that the landscape work undertake by BMSDC is well related to that being undertaken by Ipswich and Suffolk Coastal. Having similar (or the same) evidence will be of great benefit when considering issues relating to growth on the edge of Ipswich.

More details about Rep ID: 13126

Representation ID: 13040

COMMENT Sproughton Parish Council (Mrs Susan Frankis)

Summary:

Q. 55-59

District Councils could agree to consult specifically on landscape impacts of developments more closely with local parishes at an early stage.
Local designations, in particular 'Special Landscape Area', should be strengthened.
Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature walks etc.
The Gipping Valley and the landscape leading into it, especially Chantry Vale, might well benefit from being designated as a Landscape Project Area.
We don't know how important a heritage asset will be to future generations.
If there is a clear defined heritage asset that may be compromised by enforcing some climate change policies then the planning department should have some scope to ensure the asset is not spoiled.

More details about Rep ID: 13040

Representation ID: 12678

SUPPORT Environment Agency (Miss Charlie Christensen)

Summary:

we support the use of sustainable drainage (SuDS) which protects and improves water quality

More details about Rep ID: 12678

Representation ID: 12613

COMMENT Mr Alastair Powell

Summary:

* In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.

More details about Rep ID: 12613

Representation ID: 12266

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

Summary:

This response therefore supports the preference of the CD to remove local landscape designations and effectively being more pragmatic when weighing the balance of need for growth against the inevitable loss of open land. Only truly special landscapes deserve special protection.

More details about Rep ID: 12266

Representation ID: 11560

OBJECT Annette Powell

Summary:

* The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. Comment on any aspect of development in landscape areas is pointless when we don't know what is being proposed.

More details about Rep ID: 11560

Representation ID: 11367

COMMENT Sproughton Playing Field (Damian Lavington)

Summary:

* In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. It is the only other place in Suffolk with the same combination of landscape type designations, totally justifying its local SLA designation. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature which would naturally link up with Chantry Park, potential footbridges linking to the Gipping Valley footpath and divert footfall away from the SSSI sites that need protection.

More details about Rep ID: 11367

Representation ID: 11358

OBJECT Sproughton Playing Field (Damian Lavington)

Summary:

* You are suggesting that practices have changed and to look at the landscape as a whole rather than pockets of "deemed significance". Do you have a legal right to do this? It is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of national and local government experience in favour of council need. Should this on its' own be subject to legal challenge?

More details about Rep ID: 11358

Representation ID: 11298

COMMENT The Lavenham Society (Jane Gosling)

Summary:

The Lavenham Society believes that each town, village and hamlet has its own unique character and that each deserves to be supported on its own merit. Babergh and Mid Suffolk are areas with a higher than average number of listed buildings, and these form an important part of their character.
We were disappointed to find almost no mention of the vital role that tourism plays to both districts, with no mention of support for the industry. We also believe that the current level of Conservation Officers in both regions is insufficient and should be addressed in the plan.

More details about Rep ID: 11298

Representation ID: 11134

COMMENT Rattlesden Parish Council (Mr Doug Reed)

Summary:

The Parish Council believes that measures to protect open spaces, such as playing fields and village greens, in country villages such as Rattlesden are essential.

More details about Rep ID: 11134

Representation ID: 11120

COMMENT Peter Warren

Summary:

The preserve of special landscape areas, cherished viewpoints, wildlife, flora and fauna etc. should be a priority for BMSDC as well as the local community. From Chantry Vale through to the Gipping Valley must be protected for future generations.

SLAs and all other local landscape/environmental designations relating to Sproughton should be robustly protected and the design and layout of any nearby development should by sympathetic.

More details about Rep ID: 11120

Representation ID: 10944

COMMENT Mrs Carol Marshall

Summary:

* Relevant to Sproughton are SLAs which cover Chantry Vale and most of area surrounding village. Other local designations that relate to views/recreational/open spaces also relate to Sproughton.
*Support retention of local landscape designations and application of present policies applicable.
* Chantry Vale has same landscape designations as Dedham Vale AONB. Only other place in Suffolk with same landscape designations, justifying local SLA designation. Being on edge of Ipswich it is an ideal landscape for Recreational/Nature which would link up with Chantry Park, potential footbridges linking to Gipping Valley footpath and divert footfall away from SSSI sites that need protection.

More details about Rep ID: 10944

Representation ID: 10941

OBJECT Mrs Carol Marshall

Summary:

* It then suggests that practices have changed to look at the landscape as a whole rather than pockets of "deemed significance" which is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of experience in favour of Public / Economic Need.

More details about Rep ID: 10941

Representation ID: 10493

OBJECT Mr Joe Lavington

Summary:

* You are suggesting that practices have changed and to look at the landscape as a whole rather than pockets of "deemed significance". Do you have a legal right to do this? It is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of national and local government experience in favour of council need. Should this on its' own be subject to legal challenge?

More details about Rep ID: 10493

Representation ID: 10438

OBJECT Wendy Lavington

Summary:

* You are suggesting that practices have changed and to look at the landscape as a whole rather than pockets of "deemed significance". Do you have a legal right to do this? It is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of national and local government experience in favour of council need. Should this on its' own be subject to legal challenge?

More details about Rep ID: 10438

Representation ID: 10395

COMMENT Historic England (Katie Parsons)

Summary:

We strongly recommend that further evidence is gathered in support of the emerging Plan. This could be in form of a Historic Environment Chapter within the Borough profile or as a standalone document. Any evidence base should be proportionate. In particular, we would highlight that the historic environment includes both above and below ground heritage assets, as well as historic landscapes.

Good Practice Advice Note and Sources available in full representation.

We recommend indicators to measure how successful historic environment policies are.

More details about Rep ID: 10395

Representation ID: 10387

COMMENT Historic England (Katie Parsons)

Summary:

It may be appropriate to specifically identify Registered Parks and Gardens as protected by any such policy. The policy should anticipate and protect any future designations.

We welcome a policy basis for the creation and management of a local Heritage at Risk register for Grade II listed buildings. Similarly, we welcome positive local solutions for addressing all heritage at risk, whether nationally or locally identified.

More details about Rep ID: 10387

Representation ID: 10373

COMMENT Historic England (Katie Parsons)

Summary:

A number of the existing settlements where expansions are being considered contain Conservation Areas. We encourage that the local plan process provides a basis for the continued update and management of Conservation Management Plans. There should identify features that typify and contribute to this special distinctiveness as well as allow for less tangible judgments of character, quality of place and special distinctiveness. Plan will be more robust where it directs future development to take account of the special and distinctive character of Conservation Areas.

We would welcome provision for any future designation of conservation areas as well as specific provision for the landscape setting of different parts of the area.

More details about Rep ID: 10373

Representation ID: 10372

COMMENT Historic England (Katie Parsons)

Summary:

Listed buildings include a variety of structures reflecting the areas architectural,
industrial and cultural heritage. We will look for policies that carefully consider the
preservation and preferably enhancement of these assets and crucially, of their
setting.
In some instances, a full consideration of setting may require close co-operation with
adjoining districts where landscape setting may fall within the boundary of these
neighbouring authorities. Where relevant, we will seek evidence of this crossboundary
co-operation in the evidence base.
We also encourage a policy that addresses the potential listing over the plan period
of as yet unidentified heritage assets that further demonstrate the development and
activity of the town and its inhabitants.

More details about Rep ID: 10372

Representation ID: 10371

COMMENT Historic England (Katie Parsons)

Summary:

We welcome specific provision for the protection and enhancement of archaeology
as well as emphasis that sites of archaeological importance can occur everywhere.
We encourage clear guidance on expectations for archaeological recording and the
submission of records with an appropriate public record (e.g.: Historic Environment
Records) for archaeological remains that are not to be retained in situ.
Where suggested sites are located in areas of known archaeological potential, weight
should be given to this as a consideration in site selection and the comparison with
alternate locations. We encourage close liaison with the County Archaeologist at site
allocation stage.

More details about Rep ID: 10371

Representation ID: 10370

COMMENT Historic England (Katie Parsons)

Summary:

We expect to see appropriate references to setting in policies. It is important to understand the significance of any heritage assets and their settings, that would be affected by allocations in order for the policy to reflect these considerations. This involves more than identifying known heritage assets within a given distance, but a more holistic process which seeks to understand their significance and value. Distance or visibility alone is not appropriate. Allocations including heritage assets may offer opportunities for enhancement and tackling heritage at risk. Conversely allocations a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

More details about Rep ID: 10370

Representation ID: 10367

COMMENT Historic England (Katie Parsons)

Summary:

NPPF Paragraph 126 requires Local Plans to set a positive and clear strategy for the conservation, enjoyment and enhancement of the historic environment. Ideally the strategy should offer a strategic overview including overarching heritage policies to deliver the conservation and enhancement of the environment.

A good strategy will offer a positive holistic approach, whereby the historic environment is not considered as a stand-alone topic but as an integral part of every aspect of the plan. Housing, retail etc policies may need to be tailored to NPPF paragraph 8. Allocations may need to refer to the historic environment. The plan may need to include areas as being inappropriate for certain types of development due to their impact on historic environment. Good strategy will be spatially specific, unique to the area. Would expect references to the historic environment in the vision, inclusion of policies for historic environment and character of the landscape/built environment, and other references.

More details about Rep ID: 10367

Representation ID: 10366

COMMENT Historic England (Katie Parsons)

Summary:

NPPF Paragraph 126 requires local authorities to have a positive strategy for the historic environment in their Local Plans. In developing your plan we suggest full consideration is given to this matter.

A number of detailed Good Practice Advice and Advice Note Documents are available.

More details about Rep ID: 10366

Representation ID: 10079

OBJECT Historic England (Katie Parsons)

Summary:

The Heritage Assets section is of concern. Paragraph 132 of the NPPF states that when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset's conservation.The more important the asset, the greater the weight should be. The text then goes on to reiterate the provision of paragraph 133 of the NPPF but in this context it is not appropriate to do so. This paragraph relates only to instances where a development proposal would lead to substantial harm which should be exceptional or wholly exceptional and not, as suggested, a consideration in the attachment of weight of protection.

More details about Rep ID: 10079

Representation ID: 10078

SUPPORT Historic England (Katie Parsons)

Summary:

We welcome the inclusion of a focused chapter on the landscape, heritage and design within the consultation document. Recommends that any forthcoming Plan states the number of each asset type across the two districts and those on the Heritage at Risk Register. It is true that the character of landscape is influenced by
the heritage assets and their settings, as well as traditional villages and townscapes. Landscape can be an important aspect of a heritage asset's setting. Hedge rows and field markings indicate the historical way people would access and travel through landscape.

More details about Rep ID: 10078

Representation ID: 10062

COMMENT Historic England (Katie Parsons)

Summary:

The Joint Babergh and Mid Suffolk District Council Landscape Guidance 2015 is a
helpful document and any forthcoming Plan should draw on it when considering site allocations and redefined settlement boundaries. Site allocations and settlement
boundary parameters should be carried out with a full consideration of the unique
and distinctive Suffolk landscape and its relationship with individual settlements. It
would be advantageous to give clear guidance to any future developers and decision
makers about the characteristics and significance of landscape and settlement
edges. This kind of understanding informs and produces distinctive placemaking.

More details about Rep ID: 10062

Representation ID: 10013

OBJECT Charlotte Lavington

Summary:

* You are suggesting that practices have changed and to look at the landscape as a whole rather than pockets of "deemed significance". Do you have a legal right to do this? It is a concern as it appears to be an excuse to ignore recognised and cherished views/areas etc. that have been designated after many years of national and local government experience in favour of council need. Should this on its' own be subject to legal challenge?

More details about Rep ID: 10013

Representation ID: 9660

COMMENT Mr Chris Marshall

Summary:

The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. It is a ticking rural development time bomb.

Landscape Project Area designation might be appropriate for Sproughton and the River Valley

More details about Rep ID: 9660

Representation ID: 9627

OBJECT R Williams, A Williams and Ensors Trustee Co. Ltd represented by Boyer Planning (Mr. James Bailey)

Summary:

Boyer and Haughley Park Trust welcome the Councils' recognition of the importance of conserving the historical environment. Whilst Boyer appreciate the Councils' recognition of non-designated assets and the need for these to be protected, we would equally suggest that the Councils should include a policy which emphasises the need to protect existing designated assets.
This would ensure that the Councils' emerging Joint Local Plan is in accordance with Paragraph 126 of the National Planning Policy Framework (NPPF), which states that:
"Local Planning Authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment... in doing so they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance" [own emphasis].

More details about Rep ID: 9627

Representation ID: 9283

OBJECT Kersey Parish Council (Mrs Sarah Partridge)

Summary:

The Parish Council is very concerned that the heritage aspect is not given enough priority in this Joint Local Plan. Given the prevalence of heritage assets across both Districts and their importance to the local economy, greater weight should be given to protecting and enhancing heritage assets whilst at the same time setting out a strategy for growth. The Parish Council has made a number of comments relating to the protection and enhancement of heritage assets throughout their online submission in response to the consultation questions.

More details about Rep ID: 9283

Representation ID: 9209

OBJECT Mr Ken Seager

Summary:

The JLP refers to the 'Heritage Settlement and Landscape Sensitivity Assessment'. This will apparently identify areas where 'development can enhance the landscape'. But it is incomplete and nothing, not even the defining criteria, has been disclosed. It is a ticking rural development time bomb.

In relation to landscape types Chantry Vale has the same mix of landscape designation as Dedham Vale AONB. Being on the edge of Ipswich it is an ideal landscape for Recreational / Nature. A Landscape Project Area is mentioned, this designation might be appropriate for Sproughton and the River Valley.

More details about Rep ID: 9209

Representation ID: 9060

COMMENT Mr Daniel lord-vince

Summary:

* The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character.
* That lends itself to small developments not estates which change the character of the county.
* All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.

More details about Rep ID: 9060

Representation ID: 8959

COMMENT Mrs Hannah Lord-Vince

Summary:

* The spirit of the market town and hamlet type community is the character of Suffolk and design would fit in better if more effort was made to blend in with this traditional character.
* That lends itself to small developments not estates which change the character of the county.
* All development should be designed to blend into the countryside and community, protected or not, & the dominant visual features should always be the landscape that existed before the development & not the development itself.

More details about Rep ID: 8959

Representation ID: 8437

COMMENT Mr Peter Powell

Summary:

The suggestion that development can improve a landscape is preposterous to anyone other than an urbanist, and they would be better moving to London.

More details about Rep ID: 8437

Representation ID: 8327

COMMENT Ms Helen Davies

Summary:

It is important to protect our landscape. IT is a shame that the SLA designation in SProughton is being ignored in order to build around 2000 on the Ipswich side of the A14, eliminating the Vale completely.

More details about Rep ID: 8327

Representation ID: 6596

COMMENT MSDC Green Group (Cllr John Matthissen)

Summary:

The 2015 Landscape Guidance seems to be a good document but is not being used at Development Management level and must be upheld in most circumstances, not just "wherever possible." There is a need for consistency with the Open Space section. Opportunities should be taken to enhance Landscape, not merely protect.
Q60 Design must refer to embodied energy and resource efficiency, using orientation to achieve low demand and low annual carbon footprint .
The lessons of pilot exemplar projects such as Clayfields, Elmswell are not being applied. We should also look to other councils for examples of best practice.

More details about Rep ID: 6596

Representation ID: 6125

COMMENT Neil Fuller

Summary:

If Suffolk wants to preserve their green environment then we should lead by example. The higher optional build standards are therefore the best option.

Issues to consider:

* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.

More details about Rep ID: 6125

Representation ID: 5422

COMMENT Mrs Louise Baldry

Summary:

A point overlooked is the sequence of Landscape Character designations that run down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB).

More details about Rep ID: 5422

Representation ID: 4092

COMMENT Mr Vic Durrant

Summary:

* A point overlooked is the sequence of Landscape Character designations that run down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB).

More details about Rep ID: 4092

Representation ID: 3831

COMMENT Mrs June Durrant

Summary:

* A point overlooked is the sequence of Landscape Character designations that run down from The Holliday Inn, through Chantry Vale and Sproughton and into the Gipping Valley. There is only one other place in Suffolk with the same combination and that is Dedham Vale which is designated as an Area of Outstanding National Beauty (AONB).

More details about Rep ID: 3831

Representation ID: 2373

COMMENT Polstead Parish Council (Mr Dave Crimmin)

Summary:

The Council welcomes the fact that the consultation recognises the importance and value of Landscape and Heritage and seeks to build on existing planning policies in this area vital to Polstead.

More details about Rep ID: 2373

Representation ID: 1416

COMMENT Mrs P. Brightwell

Summary:

My piece of land in Eye has been nominated as a Visually Important Open Space. My piece of land has had this V.I.O.S. order on it for a number of years and I would like to know when this order is to be taken off.

More details about Rep ID: 1416

Representation ID: 1378

COMMENT Suffolk Coast & Heaths AONB (Ms. Paula Booth)

Summary:

Key evidence should be updated to reflect new publications. Full representation gives details.

More details about Rep ID: 1378

Representation ID: 1200

OBJECT Mr. Nick Miller for Sudbury Green Belt Group

Summary:

We seek to ensure the standards in the documents are translated into a clear understanding of Sudbury's landscape needs, including aspects for wildlife, and that the most populated areas facing the most development need to give proper priority alongside economic priorities (overlapping with the 'Healthy Communities' section) - this has become too urgent to wait for yet more guidelines and we challenge Babergh to put this into effect prior to the Inspector's report, we believe it will not prevent development nor cost money.

More details about Rep ID: 1200

Representation ID: 780

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

Summary:

Babergh is mentioned above Mid Suffolk District in terms of being part of an area of outstanding beauty. Mid Suffolk's landscape is of no less value. Objectives of the plan must include to safeguard quality of life. Many people choose to come or remain in this area despite lack of income/job opportunities for the rural quality of life here which should be protected.

More should be mentioned in this section on saving the rural character of the district.

More details about Rep ID: 780

Representation ID: 773

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

Summary:

Our overarching concern is that there is little discussion and emphasis on protecting our rural character and cherishing our historical heritage. The Council has completely underplayed these contrary to the Guidance in the NPPF and National Planning Law.

We understand the pressures on the Council to deliver housing targets, but this should not be at the expense of quality of life for residents and a diminution of our distinct rural heritage which should be safe guarded for future generations.

It is disappointing that there is little discussion about protecting our rural character and cherishing our historical heritage.

More details about Rep ID: 773

Representation ID: 716

SUPPORT Martyn Levett

Summary:

The Consultation plan for Sproughton on page 174 edged green and mauve (existing and proposed new draft settlement boundary), excludes SS0121(Bramford), SS0711 (Sproughton, Lorraine Way) and SS0223 (allotments) by definition, "Countryside". This area is "rolling valley farmland" in the Landscape Guidance document 2015 The key objective maintains the sense of separation between Sproughton and Bramford, and any change/development would be visually significant. Valley sides makes a significant contribution to the specific local character of the village with elevated locations and substantial views .

More details about Rep ID: 716

Representation ID: 574

OBJECT Mrs Abigaile Maydon

Summary:

The onus on protecting heritage and environment in the local plan here as dictated by the NPPG is entirely lacking, I have never read a local plan so driven by economic need and not actual realities of local need as they stand. The plan is not realistic again against government guidelines and the tiny mention of landscape, environment and heritage it contains is shameful. You are custodians of this very unique District and this plan will ruin its many assets by over development.

More details about Rep ID: 574

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