PETTAUGH PARISH COUNCIL Pettaugh

Babergh and Joint Local Plan Preferred Options Consultation Response Endeavour House 8 Russell Road IP1 2BX

Dear Sirs

Babergh and Mid Suffolk Joint Local Plan Preferred Options (July 2019) Consultation response – PETTAUGH PARISH COUNCIL

Thank you for inviting the Parish Council to comment on the emerging new joint local development plan by 30 September 2019. The Parish Council wish to OBJECT to the policies identified below as currently proposed in the joint local plan which have particular significance for the hamlet of Pettaugh and, in addition, to the settlement plan for Pettaugh as included in this consultation draft.

The Parish Council supports good growth and sustainable development. Equally, the Parish Council considers that it is essential that there is an evidence based, plan led approach to development which has been robustly tested. The Babergh and Mid Suffolk Joint Local Plan Preferred Option 2019 currently appears to fail short of this well-established legal test in relation to the issues identified below.

In summary, the proposal to arbitrarily extend the settlement boundary of the hamlet of Pettaugh is not based on any evidence and not supported by any of the existing and/or emerging policies. Similarly, the proposed strategic and local policies identified below are unsound and would have materially adverse effects not only on the physical environment, including the natural environment, but also on the community and future generations. The grounds of the Parish Council’s objection as follows:

Pettaugh Settlement Plan

The Parish Council can only assume that the proposed plan is the result of a mapping and/or printing error, but please confirm.

If the proposal map is not erroneous, the Parish Council objects in the strongest possible terms to the unreasonable, improper and totally arbitrary change proposed to the settlement boundary of this hamlet village. The proposed changes to the boundary of this hamlet village are affecting land to the East of Way. What is proposed is the exclusion of four residential dwellings 21, 23, 25 and 27 of Debenham Way from the settlement boundary of Pettaugh and the inclusion of a significant area of greenfield, good quality agricultural land along Debenham Way located between the boundary of 21 Debenham Way and the junction with the A1120.

By contrast, the proposals maps in the current local plan, the Mid Suffolk Local Plan (1998) at Insert Map 63, show the true settlement boundary of our village, and includes 21-27 Debenham Way, four houses which have formed part of Pettaugh for several decades. The Parish Council respectfully asks the District Council to provide rational reasons (if any) for the exclusion of this part of the established settlement, if not minded to rectify the map.

Secondly, the arbitrary inclusion of current greenfield land that has been and is being cultivated and is in active agricultural use, not only goes against the fundamental principle of planning, namely sustainable development, but also appears unreasonable and irrational. The Parish Council is unaware of any proper and settlement related reason providing for such a change. The Parish Council respectfully ask the District Council to confirm that this considerable sized parcel of land is not owned by the District Council (as the village’s collective memory recalls) and therefore it is not included for financial or other improper reason. Whilst the Parish Council understands that land ownership is not a planning consideration, identifying and, in effect, allocating land for completely unsustainable development is. Proposed policies SP03 and LP01 confirm that development within settlement boundaries will be permitted. As such it is of utmost importance that the settlement boundary setting exercise does not allow unsustainable locations (and locations never before included in the village) artificially fitted into the village. The plan-led approach should ensure that unsustainable development does not happen and not, as here, being legitimised and supported. As before, the proposals map in the 1998 Local Plan shows the true boundary of the hamlet village of Pettaugh without including this area of agricultural land.

The Parish Council considers that unless the proposed settlement plan in the Joint Babergh and Mid Suffolk Joint Local Plan Preferred Options (July 2019) is corrected (as set out above) the plan is unacceptable in planning terms.

Strategic and Local Policies

The Parish Council would strongly urge the local planning authority to reconsider the following policies:

Strategic Policy SP03 and Local Policy LP01

Sub-policy D of SP03 confirms that development within Hamlet Villages (Pettaugh) will be permitted within settlement boundaries. Consequently, the settling of the settlement boundary is of paramount importance. As set out above, the Parish Council strongly objects to the inclusion of greenfield, agricultural land, that has always been outside the established village boundary, within the settlement boundary of Pettaugh. Such inclusion, in effect, would enable and encourage unsustainable development ‘via the back door’.

Further, the Parish Council considers that in sub-heading D the proposed policy must refer to ‘Sustainable Development’ as any other development is clearly remains unacceptable and should not be permitted. In addition, the list of requirements (I-IV) whilst supported should be extended to include, for example, density, highways and other infrastructure etc., and the cumulative impact heading must make it clear that it encompasses the cumulative impact not only in the district, but also in the relevant neighbourhood area/surrounding villages around the development site and in the village itself.

Local Policy LP01 reiterates that within the settlement boundary of identified hamlets the principle of development is acceptable. The Parish Council refers to its comments above about the importance of settling the settlement boundaries and the grave concerns that the proposed arbitrary changes to Pettaugh’s settlement boundary raise. Such change would lead to establishing the principle of unsustainable development being acceptable. Clearly such an outcome is completely undesirable and indefensible. As set out in relation to SP03 above the word ‘development’ in Policy LP01 must also be qualified by the requirement of ‘sustainable’

Strategic Policy SP07 and Local Policies LP14 and LP15

The Parish Council appreciates and supports the District Councils’ ambitions relating to Tourism and Leisure and genuine Countryside Tourist Accommodation uses. However, being closely located and heavily impacted by the unlawful Stonham Barns developments the Parish Council is very concerned about the on-going abuse of this policy area. The Parish Council would like to see strengthened policies that give real protection to communities and balance fairly the competing interests. In particular, the occupancy restriction condition proposed in local policy LP15 has proven to be woefully inadequate at Stonham Barns. In addition, part 2 of policy LP15 as currently worded is a potential ‘Charter’ for unscrupulous developers to secure planning permission for residential development in unsustainable locations and without the necessary scrutiny after a 12 month ‘wait’, as the holiday occupancy restriction can be lifted after 12 months’ marketing. The Parish Council strongly urges the local planning authority to strengthen significantly this element of the policy. The very least the marketing requirement should be lengthened to two years and further restrictions must be imposed via section 106 agreements for example a requirement to have the nature of the accommodation noted at the Land Registry and in every transfer such as is standard practice with parking permit restrictions in other parts of the country.

Consultation process

The Parish Council is gravely concerned about the timing of this consultation. 6 weeks of the consultation out of the total of 10 fell in the summer school holiday period greatly impacting on many to consider and to express a view on the Preferred Options document. Whilst the Parish Council prepared this initial response, it reserves the right to add further consultation comments as they may emerge because, in effect, there was only four weeks in which to consider the proposals.

Conclusion

The Parish Council objects to the above policies and the proposed settlement plan for Pettaugh and respectfully requests the local planning authority to reconsider its position going forward in the plan making and adoption process for the reasons set out in this representation.

Yours faithfully

Pettaugh Parish Council Planning