Working Together

Babergh Mid Suffolk Joint Local Plan 2018-2037

Pre-Submission Regulation 19

Paper Representations Form

Pre-Submission Regulation 19 stage of Babergh Mid Suffolk Joint Local Plan public representations period runs from 12th November 2020 to 24th December 2020 (6 weeks).

Regulation 19 - Town and Country Planning (Local Planning) (England) Regulations 2012

Representations must be received no later than 12 noon on 24th December 2020.

Online facilities are available to draft and submit comments electronically.

Alternatively, please completed this form and return via email: [email protected] or post to Babergh & Mid Suffolk Councils, Planning Policy Team, Endeavour House, 8 Russell Road, Ipswich IP1 2BX.

If assistance is required, please contact the Council’s Strategic Planning Policy Team via email address stated above or by telephone on 0300 1234 000 option 5, then 4.

This form has two parts: Part A for personal details and Part B for your representation.

Please make clear what part of the Joint Local Plan you are responding to and complete a separate form for each representation you wish to make.

Please note each representation must be signed and dated.

All comments received will be made publicly available and may be identifiable by name / organisation. All other personal information provided will be protected in accordance with the Data Protection Act 2018.

Babergh and Mid Suffolk Joint Local Plan

Part A

Section 1: Personal Details

Title: Mr

First Name: Simon

Last Name: Pearce

Job Title (where relevant): Chairman

Organisation (where relevant): Woolverstone Parish Council

Address:

Postcode: Telephone:

Email:

Section 2: Agent Details (if applicable)

Please supply the details below of any agent you have working on your behalf.

Agent name:

Address:

Postcode: Telephone number:

Email:

Pre-Submission (Nov 2020) Paper Representations Form 2

Babergh and Mid Suffolk Joint Local Plan

Part B

Please fill in a separate form for each representation

The Joint Local Plan will be examined by an independent inspector in order to assess whether the plan has been prepared in accordance with the legal and procedural requirements, and whether it is sound.

Section 3: Section of Joint Local Plan

Name or Organisation: Woolverstone Parish Council

Client: (if relevant)

To which part of the Joint Local Plan does this representation relate? BMS Pre-submission JLP Part 3 - Place and Allocation Section and Paragraph: Policies P. 161

LS01 Hinterland and Hamlet sites Policy:

Babergh Settlement maps and allocations Q-Z Policies Map:

Section 4: Legal Compliance & Duty to Cooperate

Do you consider the Joint Local Plan is: (tick as appropriate)

Yes (Support) No (Object)

1. Legally and procedurally compliant:

(a) Positively prepared

(b) Justified No

2. Sound: (c) Effective

(d) Consistent with national policy No

Yes 3. In Compliance with the Duty to Cooperate

Pre-Submission (Nov 2020) Paper Representations Form 3

Babergh and Mid Suffolk Joint Local Plan

Section 5: Details of Representation

If you wish to support or object to the legal compliance or soundness of the Joint Local Plan or with the Duty to Cooperate, please use this box to set out and explain your comments. Please be as precise as possible, and provide a 100 word summary of each point.

Woolverstone is a rare example of a 19th Century estate village with value in both its architecture and the spaces in between buildings centred on the 18th century Woolverstone Park estate. There are 18 listed buildings or structures in Woolverstone. There are Tree Preservation Orders on all trees throughout the village. Much of the building that is listed took place in the eighteenth and nineteenth century. As you travel through the village, the estate buildings are still in clear evidence and the estate village retains its shape; a rare example of a carefully planned and “closed” estate with value in both its architecture and the spaces in between buildings centred on Woolverstone Hall.

To the north of the B1456 the village is situated within the Suffolk Coasts and Heaths Area of Outstanding Natural Beauty; to the south of the B1456 is within the AONB project area. The majority of the village of Woolverstone is located within its own Conservation Area which was designated in 1989. A further appraisal was adopted by Babergh District Council Strategy Committee on 18th September 2008. See “Woolverstone Conservation Area Appraisal” 2008. Babergh District Council has a duty in law to “preserve and enhance” conservation areas within its district as well as the sensitive landscape areas. That Woolverstone is worth protecting is acknowledged by this designation. Within the settlement there are a number of plots that have the status of Areas of Visual or Recreational Amenity which protects these areas from development. There is a duty to see this designated Conservation Area protected and enhanced by planning policies and not degraded by development.

The “open character” of the village is the essence of the Conservation Area. In a recent Appeal decision from the Planning Directorate it was noted that this open character and space “contributes positively to the character of the conservation area and are important to its significance” (APP/D3505/W/18/3214989). Any loss of this “open character” would have an adverse impact and cause harm to the character and appearance of Woolverstone Conservation Area. Babergh Local Plan 2006 CN08 states: “Proposals for … the erection of new buildings in a conservation area or which have an impact on views into or out of a conservation area should…retain all elements and components, including spaces, which contribute to the special character of the area”. The intention of this policy is clearly to protect sensitive and special areas from harmful development.

With just current plans, our village will have an additional 14 dwellings; 6 on redundant farm building site at Whitehouse Farm and 4 in redundant farm buildings at Home Farm; 1 in a redundant farm building at Dairy House. When these dwellings are built they will represent an increase of about 13% in the housing stock in Woolverstone. We think this is as much as the village can absorb and retain its character, both physical and social. Furthermore, there are an additional 4 new houses on the Nursery Garden “enabling” development which are nearly built out. We have taken our fair share yet in a way that preserves the historic shape of the village and reflects best practice.

Woolverstone is correctly classified as a hamlet in the JLP. It is remote from services and facilities Woolverstone Parish Council does not believe the BMSDC JLP LS01 is “sound “with respect to either the allocations or sites selected in our village. Both sites allocated to Woolverstone SS0203 and SS0255 listed in the Joint Local Plan are outside the current settlement boundary. Indeed the settlement boundary has been expanded to include these sites.

The Shotley Peninsula is the only location of Ancient Estates Farmlands in Babergh. The mixture of fields and woods are unique. The agricultural land surrounding Woolverstone is high quality land Grade 1 and 2, i.e. considered to be the best and most versatile land. “The ALC system classifies land…the best and most versatile land is defined as Grades 1, 2 and 3a by policy guidance (see Annex 2 of NPPF). This is the land which is most flexible, productive and efficient in response to inputs and which can best deliver future crops for food and non-food uses such as biomass, fibres

Pre-Submission (Nov 2020) Paper Representations Form 4

Babergh and Mid Suffolk Joint Local Plan and pharmaceuticals. Current estimates are that Grades 1 and 2 together form about 21% of all farmland in England” TIN049 edition 2 - Agricultural Land Classification: protecting the best and most versatile agricultural land.

Only 5m separates the AONB from the allocated sites. The sites offered on the North side of the road were rejected because of the sensitive nature of the landscape. Clearly the Conservation Area rather than the arbitrary route of the road should preserve this historic settlement pattern.

Site reference SS0255 • This is a Greenfield site and was a Glebe field: always used solely for agriculture. It currently has a covenant in place to restrict any development or intensive agricultural use • Any development would require the lifting of a covenant and consent of St Edmundsbury Diocese as neighbours and covenanters • The land is Grade 1 or 2 listed, some of our finest, most productive arable land • The greater part of the field identified for development >75% is within Woolverstone Conservation Area and adjacent to the ANOB – separated by 5m road • The site is outside the current BUAB • The density proposed of 5 dwellings in the Joint Local Plan is not consistent with the layout of the village. • The density has been increased from two dwellings to five on a .2 hectare plot in the most recent iteration of the JLP. BDC have not explained the planning judgement that led to this increase. • The site is within 15 m of the Grade 2 listed “Holbrook Lodge, original gate house to Woolverstone Hall • This site was rejected for development in 2016 SHELAA as “inadequately related to services, facilities”. The site has not changed only the methodology. • Building on allocated site SS0255 would be detrimental to the character and appearance of Woolverstone Conservation Area, its landscape (including the AONB) and heritage • Use of this site would consolidate the sporadic development and result in loss of gaps between settlements resulting in coalescence. • The scale of development is simply too dense for the location allocated.

Site reference SS0203 • This is a Greenfield site and has always been used solely for agriculture. • Land is Grade 2 listed, some of our finest, most productive arable land. • The part of the field identified for development is entirely within Woolverstone Conservation Area and adjacent to ANOB –separated by just 5m road • The site is outside the current BUAB • The density proposed in the Joint Local Plan is not consistent with the remainder of the village. • The density has been reduced from eight dwellings to five on a .6 hectare plot. (Even so, this is in stark contrast to SS0255 with 5 dwellings on .2 hectare plot. There is no consistency with the street scene.) • The site is adjacent to the Grade 2 listed “Widows Homes” and between that and the Grade 2 listed “Berners Hall” and the Grade 2 listed War Memorial. • The space between the Widows Homes and Berners Hall has existed for one hundred and thirty years. It is at the heart of the open spaces that are the essence of the village of Woolverstone. • Any building between the Widows Homes and Berners Hall will diminish both heritage assets and, in the case of the Widows Homes compromise the setting to a great degree. • This site was rejected for development in 2016 SHELAA as “inadequately related to services, facilities”. The site has not changed only the methodology. • Building on allocated site SS0203 would be detrimental to the character and appearance of Woolverstone Conservation Area, its landscape (including the AONB) and heritage • Use of this site would consolidate the sporadic development and result in loss of gaps between settlements resulting in coalescence. • The scale of development is simply too dense for the location allocated.

Pre-Submission (Nov 2020) Paper Representations Form 5

Babergh and Mid Suffolk Joint Local Plan

• This site was rejected for development in 2016 SHELAA as “inadequately related to services, facilities” The site has not changed only the methodology.

References BMSJLP Sustainability Appraisal Oct 2020 Main Report Para 7,462 Woolverstone 10 dwellings. Significant negative effect Allocated sites SS0203 and SS0255 25% of land falls within SSI impact Risk Zone for proposed capacity.

BMSDC Joint SHELAA Report Oct 2020 P332 and 333 JLP allocated site reference LS01 Babergh District Council Place Maps and Policies - Settlement Maps Q-Z P39 BUAB Appendix E Detailed Appraisal of Site Options Babergh Mid Suffolk Joint Local Plan October 2020 The basis for “major positive effects” is simply wrong although there is good access to open space. E387 – Woolverstone is not within walking distance of a GP Surgery except along footpaths and across fields. In reality, all the household access to primary healthcare facilities will be car dependent. Woolverstone may have bus stops but is not well served by buses. There is a limited bus service in Woolverstone. There are now only eight buses a day that travel through Woolverstone to Ipswich on a school day and only 7 buses on non-school day. There are 2 options in the morning, only one if a non-school day. Only two morning peak hour buses to Ipswich Mon to Sat: 07.41 and 8.08 NSD or 8.23 SDO. The last bus from Ipswich is at 17.45 in the evening. The last bus into Ipswich is at 18.38. There is no return bus service in the evening from Ipswich. There is no Sunday bus service at all. In reality, all the proposed households will be car dependent.

It is extremely unlikely that households will be encouraged to use more sustainable modes of transport.

E391 - The reference “they are both partially within the Woolverstone Conservation Area” is wrong and misleading. Site SS0203 is entirely within Woolverstone CA and >75% of site SS0255 is within Woolverstone CA.

(Continue on a separate sheet if necessary. Please remember to include on any separate sheets the name/organisation and details of which section, paragraph, policy or element of the policies map your representation relates)

Pre-Submission (Nov 2020) Paper Representations Form 6

Babergh and Mid Suffolk Joint Local Plan

Section 6: Proposed Modifications to the Joint Local Plan

Please set out what modification(s) you consider necessary to make the Joint Local Plan legally compliant or sound, having regard to the test(s) you have identified above where this relates to soundness. (NB Please note that any non-compliance with the Duty to Cooperate is incapable of modification at examination) You will need to say why this modification will make the Joint Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

The settlement boundary for Woolverstone should not be extended as is proposed. The two sites SS0203 and SS0255 should not be used for housing because of the harm caused to Woolverstone Conservation Area, the impact on Listed Buildings therein and the degrading of the Suffolk Coasts and Heaths AONB. Even if the sites were deemed appropriate, which we challenge, the density of housing proposed is totally out of character with the Conservation Area and the heritage design of our “model” village.

(Continue on a separate sheet if necessary. Please remember to include on any separate sheets the name/organisation and details of which section, paragraph, policy or element of the policies map your representation relates)

Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested modification, as there will not be a subsequent opportunity to make further representations based on the original representation at publication stage.

After the representations period of the Pre submission Babergh and Mid Suffolk Joint Local Plan has closed, further submissions will only be at the request/invitation of the Inspector, based on the matters and issues debated at the examination.

Pre-Submission (Nov 2020) Paper Representations Form 7

Babergh and Mid Suffolk Joint Local Plan

Section 7: Participation at the Examination

If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? (please select one answer with a tick) √ Yes, I wish to participate at the oral examination

No, I do not wish to participate at the oral examination

If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary:

To make sure that our voice and view is heard.

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination.

Section 8: Being Kept Informed

Would you like to be kept informed of the progress of the Babergh and Mid Suffolk Joint Local Plan through to adoption? (please select one answer with a tick) YES Yes, I want to be kept informed

No, I do not want to be kept informed

Please note that if you do not wish to be kept informed of the progress of the Babergh and Mid Suffolk Joint Local Plan through to adoption, you will not receive any subsequent updates relating to the Local Plan examination etc.

Section 9: Signature & Date of Representation

Please sign and date below: Signature:

Date: 23rd December 2020

Pre-Submission (Nov 2020) Paper Representations Form 8

Babergh and Mid Suffolk Joint Local Plan

After the end of the representation period the Councils will submit all individual representations received to the Secretary of State, together with a summary of the main issues raised during the representations period.

Information that you provide in your representation, including personal information, may be published or disclosed in accordance with the Environmental Information Regulations 2004 (EIR), or the Freedom of Information Act (FOI). If you want the information that you provide to be treated as confidential, please tell us, but be aware that under the EIR and FOI, we cannot guarantee confidentiality.

However, if you are submitting representations as an individual, the Council will process your personal data in accordance with the Data Protection Act 2018 and this means that if you request confidentiality, your personal information will not be disclosed to third parties.

For more information on how we do this and your rights with regards to your personal information, and how to access it, please visit our website or call Customer Services on 0300 123 4000 and ask to speak to the Information Governance Officer.

If you wish to request that the personal details submitted with this representation are treated in confidence and not published. (please tick the box) Please explain below, why you have made this request:

Babergh and Mid Suffolk District Councils

Strategic Planning Policy Team, Endeavour House, 8 Russell Road, Ipswich IP1 2BX

Planning Policy Team | 0300 1234 000 option 5 then 4 | [email protected]

Pre-Submission (Nov 2020) Paper Representations Form 9