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Babergh & Mid Suffolk Joint Local Plan Preferred Options (Regulation 18) Consultation Land north of The Street, Elmsett – SS0230 Prepared by Strutt & Parker on behalf of Luna Land Investments Ltd. September 2019 Site Name: Land north of The Street, Elmsett Client Name: Luna Land Investments Ltd. Type of Report: Regulation 18 Local Plan Representation Prepared by: Laura Dudley-Smith MRTPI Approved by: Sam Hollingworth MRTPI Date: September 2019 COPYRIGHT © STRUTT & PARKER. This publication is the sole property of Strutt & Parker and must not be copied, reproduced or transmitted in any form or by any means, either in whole or in part, without the prior written consent of Strutt & Parker. The information contained in this publication has been obtained from sources generally regarded to be reliable. However, no representation is made, or warranty given, in respect of the accuracy of this information. We would like to be informed of any inaccuracies so that we may correct them. Strutt & Parker does not accept any liability in negligence or otherwise for any loss or damage suffered by any party resulting from reliance on this publication. Strutt & Parker, Coval Hall, Rainsford Road, Chelmsford, Essex CM1 2QF [email protected] Tel No: 01245 258201 Babergh and Mid Suffolk Joint Local Plan - The Street, Elmsett Contents 1. Background and Overview ............................................................................................. 2 2. Babergh & Mid Suffolk Joint Local Plan Regulation 18 Consultation .............................. 3 3. Site Deliverability ......................................................................................................... 11 4. Summary ..................................................................................................................... 14 Appendices Appendix A: Land north of The Street, Elmsett - Location Plan 1 Babergh and Mid Suffolk Joint Local Plan - The Street, Elmsett 1. Background and Overview 1.1 This representation has been prepared by Strutt & Parker on behalf of Luna Land Investments Ltd. in relation to Babergh & Mid Suffolk District Council’s Joint Local Plan Preferred Options (LPPO) (Regulation 18) Consultation. 1.2 Strutt & Parker are actively promoting the site on behalf of Luna Land Investments Ltd. in relation to an option agreement they have with the landowner on land north of The Street, Elmsett. 1.3 The site has previously been represented by Strutt & Parker on behalf of the landowner as part of the consultations run on the Call for Sites 2014, Issues & Options 2015 and the additional Issues and Options presented in 2017. 1.4 As part of the Local Plan process, the site has been assigned a Local Plan reference of SS0230 and has also been assessed within the Mid-Suffolk & Babergh District Council Strategic Housing and Economic Land Availability Assessment (SHELAA) (2017). 1.5 As a result of the SHELAA (2017), the site was considered “potentially suitable” to accommodate residential development. Despite this however, the site has not been proposed for allocation within the LPPO. 1.6 This representation seeks to clarify the site’s sustainability credentials, and ability to meet the strategic intentions of the emerging Joint Local Plan. 2 Babergh and Mid Suffolk Joint Local Plan - The Street, Elmsett 2. Babergh & Mid Suffolk Joint Local Plan Regulation 18 Consultation SP03 – Settlement Hierarchy 2.1 As addressed in detail in our response to Policy SP04 below, it is critical that the Local Plan does not simply allocate growth to settlements based on its position within the settlement hierarchy alone. This is particularly the case when we have concerns over the methodology used to designate settlements within the hierarchy. 2.2 We welcome the fact that the LPPO does not propose a strategy which follows the settlement hierarchy in an overly prescriptive manner, and we consider this is necessary to ensure a strategy which is appropriate. We also recognise that it is a useful tool to guide a higher level strategy for guiding growth in Babergh and Mid Suffolk, provided the hierarchy is appropriately developed, and that there is an additional level of consideration beyond the position of a settlement in this hierarchy. However, we do not consider that Elmsett has been appropriately categorised within the proposed settlement hierarchy. As such, to ensure it is robust and justified, and that the Joint Local Plan’s approach to distribution of development informed by this is sound, we consider that modifications are required to the settlement hierarchy. 2.3 The LPPO details the settlement hierarchy at SP03 and Table 2, and includes five categories of settlements. Beyond the Ipswich Fringe Areas, and settlements previously identified as Urban Areas and Market Towns within previous adopted development plans, a weighted scoring system has been used to indicate the relative sustainability of remaining villages. As a result of this process, Elmsett is categorised as a Hinterland Village. 2.4 Further information on this assessment is provided within the Settlement Hierarchy Review Topic Paper (SHR) (July 2019). We are not aware of any consultation on the methodology used within this and therefore this appears to be the first opportunity to do so. Accordingly, we make these comments to assist the Council in ensuring the assessment is robust, and the Joint Local Plan will be sound. 2.5 The methodology for cataloguing settlements attributes points for a number of criteria, and finds that Elmsett has a settlement score of ‘16’. The threshold for Core Villages (the next highest category) is 18 points or over. It is clear that in respect of the scoring process, Elmsett is one of the most sustainable villages in the District given that it’s score is only just below that required for it to be considered a Core Village. 3 Babergh and Mid Suffolk Joint Local Plan - The Street, Elmsett 2.6 The preparation of a settlement hierarchy based on a scoring system is commonplace for local plan preparation. However, we are concerned that the settlement scoring does not reflect the importance of some services over others, and that the nature of some settlements have been mis-categorised, including Elmsett, in relation to their suitability to support residential or employment development accurately. 2.7 The SHR states at paragraph 2.2 that: The scoring is based on the relative importance of each facility available within a settlement, in that some services are more essential and used more frequently than others, such as a primary school or a convenience store. As these are important facilities that reduce the need to travel by car and support the vitality of the local community, they are given a score of 2 points. (para.2.2) 2.8 While the general point that certain services are more important, and more likely to be needed on a daily basis than others, is accepted and agreed, the scoring should be scrutinised further to ensure it achieves the aim of recognising and reflecting that very point. For example, a settlement could receive an identical score for containing a pre- school, secondary school, post office, village hall, place of worship, library, allotment, and for each food and drink outlet (to a maximum of 5) within the settlement, when in reality some of these services are far more important to a successful village than others. 2.9 On a similar vein, this also means that a settlement could have a pre-school, a secondary school and a post office and score 3 points, but also have none of these facilities and three public houses instead, and achieve the same number of points. 2.10 There is no refinement of the scoring to account for any weighting of relative importance of these facilities/services, except to give some facilities 2 points and others 1 point. In reality, there is likely to be more community engagement and activity around some services than others, and on a much more varied scale, which is not reflected here. 2.11 For employment opportunities, the Review refers only to proximity to either strategic and small scale employment within 5km. The score is a maximum, in that regardless of the number of employment sites nearby, a settlement can only score 1 or 2 points. This scoring system effectively concludes that it is more beneficial for a settlement to be 4.9km from a strategic employment site, than for it to be able to offer small scale employment within the settlement itself and within walking distance. 4 Babergh and Mid Suffolk Joint Local Plan - The Street, Elmsett 2.12 The rationale for scoring these is to ‘reduce the need to travel’ and therefore the relative distance should be accounted for, with those containing employment options being given a greater score. This again emphasises a need for greater flexibility and variety within the scoring methodology. 2.13 For settlements such as Elmsett, that scores close to a hierarchy threshold, it is imperative that its sustainability credentials are appropriately scored to reflect its suitability to provide sustainable development. 2.14 As an alternative, we recommend a more sophisticated system be applied. It is clear that Babergh is a largely rural district with many smaller settlements that depend upon each other to meet the needs of residents. The scoring system adopted for the SHR is incapable of fully reflecting the availability of services within such a district. Of primary importance are four aspects that would result in a more sophisticated understanding of the living standards and desirability of different Settlements within the hierarchy: a. The scoring should reflect the relative scores of neighbouring settlements and not simply apply a single number to a standard proximity. A reduction or scaling of the score could be applied, but this would likely be an arbitrary reduction unless there were a judgement on the value of the reduction (based on distance, or relative accessibility, for example). Our preference would be for a supplementary value to further inform the overall score for the settlement, or to inform the suitability of the village/town to accommodate additional residents and employment.

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