Mid- Planning Endeavour House 8 Russell Road Ipswich Suffolk IP1 2BX

Dear Planning Team, 30th September 2019

Subject: Babergh & Joint Local Plan Preferred Options Consultation – Representation on behalf of Earlswood Homes

I write on behalf of Earlswood Homes regarding the current Babergh & Mid Suffolk Joint Local Plan Preferred Options consultation.

Earlswood Homes are a medium sized housebuilder with land interests in the Babergh and Mid Suffolk administrative areas. This representation relates specifically to land east of Hockey Hill, Wetheringsett (SHELAA 2019 Site Reference: SS1133).

It is acknowledged that, through the 2019 SHELAA, the Council concluded that the site was no suitable, with it specifically discounted based on poor connectivity and inconsistency with the settlement pattern. The purpose of this statement is to respond to these conclusions in order to support an allocation of the site in the emerging Joint Local Plan.

Housing provision and distribution

Overall, Earlswood Homes strongly supports the positive approach taken by Babergh & Mid Suffolk in the Joint Local Plan with respect to its proposal to meet, in full, the housing needs identified by the Government’s standard method (Policy SP01).

Furthermore, Earlswood Homes support the identification of Wetheringsett-Cum-Brockford (Church) as a Hinterland Village within the Settlement Hierarchy Topic Paper and subsequently within Preferred Policy SP03. This conclusion is considered to appropriately reflect the availability of key services including a local Primary School and village hall within the village, together with its accessibility and proximity to other Core Villages.

We also support the acknowledgement within the introductory text that “each category of settlements will be required to contribute towards the future growth of the districts”; this is considered – in principle – to be an appropriate strategy in order to provide flexibility to meet the housing needs of the districts (by providing a diversification of sites and locations), whilst ensuring those smaller villages benefit the growth they require in order to support on-going viability and sustainability of services. This is particularly relevant to Wetheringsett where appropriate growth would support the long-term viability of the local school.

However, Earlswood Homes considers that the approach to distribution of development, and the absence of site allocations within the village of Wetheringsett-cum-Brockford (specifically the “Church” area) is flawed. It is considered that greater housing provision should and – in respect of land east of Hockey Hill – could be sustainably delivered within hinterland villages such as Wetheringsett.

Land east of Hockey Hill, Wetheringsett

In this respect, Earlswood Homes considers that – contrary to the conclusions of the SHELAA – land east of Hockey Hill (SS1133) represents a suitable, available and achievable site capable of delivering a development of sympathetic design and scale for Wetheringsett.

Suitability

The land east of Hockey Hill comprises an area of undeveloped paddock/semi-natural grassland to the rear of existing development along the frontage of Hockey Hill. The site directly adjoins the settlement boundary and is wholly in Flood Zone 1. The site is not subject to any other protective planning, landscape or environmental designations.

The site is extremely well-contained in respect of the wider landscape with all external boundaries being defined by dense tree belts and woodland areas, limiting any views of the site from the wider countryside. Similarly, whilst the site adjoins the Conservation Area and there are nearby listed buildings, the strong boundary planting limits inter-visibility between the two. With sensitive design, development could be discretely introduced without visual impact to heritage assets or the wider countryside landscape.

It is acknowledged that the previous SHELAA concluded that development of the site “is not consistent with the settlement pattern”. In this respect, Earlswood Homes believe that the site should be allocated on the basis of a reduced site area compared to that put forward as part of the original SHELAA submission (c.0.8ha rather than 1.3ha in the original submission). This reduced area is demonstrated on the plan below, with the previous boundary indicated by a dotted blue line and the revised suggested allocation shown by a red hatched area. Crucially, Earlswood Homes believe that this would: - Contain development such that built form and gardens would extend no further west than the existing settlement boundary marked by the properties on Hockey Hill to the north and the cul-de-sac to the south which is separated from the site by only a block of woodland. In this respect, an allocation of this size would not “over-extend” the village, nor unduly disrupt its largely linear form - Allow for a modest linear cul-de-sac scheme of approximately 8 homes, consistent with – and directly drawing from – the cul-de-sac off Hockey Hill to the south where the pattern of development is already characterised development of a similar depth in behind the frontage properties.

Figure 1: Plan illustrating proposed allocation boundary (reduced from SHELAA submission SS1133)

At a capacity of approximately 8 new homes (reduced from the previously suggested 9 to 15 units), it is considered that the land east of Hockey Hill would represent a modest, proportionate and wholly appropriate addition to the village, supporting its long term sustainability. Earlswood Homes consider that the site could lend itself to a collection of detached and semi-detached chalet style (1.5 storey) units, reflect the forms and type of dwellings which existing along Hockey Hill. The remainder of the land would be retained by the existing landowner in its current use as amenity space and/or grazing land, consistent with surrounding land.

It is also noted that the 2019 SHELAA also considered that the site had poor connectivity to the settlement. Respectfully, Earlswood Homes disagree with this conclusion for the following reasons: - The site has direct access to Hockey Hill which could be upgraded to comply with Suffolk County Council highway standards (in terms of width and junction visibility) in order to provide a safe vehicular and pedestrian access to the site. - The access point connects directly to the existing footpath along the eastern side of Hockey Hill which provides direct and continuous pedestrian access into the wider village to the north; including to the Primary School and village hall. - The site is in walking distance to bus stops to the north and south on Hockey Hill, which are served by the 115 bus route which provides access to the Core Villages of Mendlesham and Debenham, as well as Ipswich, albeit on an infrequent service.

In our view, the nature of Wetheringsett is such that there are limited alternative opportunities within the settlement boundary (i.e. through windfalls) to bring forward new development to support the long-term sustainability and vitality of this hinterland village. Opportunities within the settlement boundary are scarce due to the tightly drawn settlement boundary and prevailing constraints (such as the Conservation Area and listed buildings).

Consequently, Earlswood Homes strongly believe that the land east of Hockey Hill is suitable for residential development of approximately 8 homes and that the site should be allocated on this basis to support the sustainable growth of the village of Wetheringsett.

Availability and achievability

The site remains available for development. As per the previous SHELAA submission, the site is owned by a single family who wish to bring the site forward for development.

Earlswood Homes are in active dialogue with the current landowners with a view to progressing development options for the site, further demonstrating the intentions of the landowner.

Subject to achieving an allocation or obtaining a satisfactory planning consent, the site would there be available for development within the short-term (0-5 years). Unlikely larger allocations within the emerging Joint Local Plan, the site could therefore deliver in early stages of the plan period, helping to sustain a five-year land supply.

The site could be developed viably based on the capacity and development parameters above.

Conclusions

Earlswood Homes welcome the opportunity to make representations to the emerging Babergh & Mid Suffolk Joint Local Plan Preferred Options (Regulation 18) consultation.

Whilst Earlswood Homes supports the proposed housing requirements in the emerging Joint Local Plan which seek to meet the minimum Local Housing Need identified by the Government’s standard methodology, it is considered that opportunities have been missed to deliver housing whilst supporting the long-term sustainability of hinterland villages such as Wetheringsett-cum-Brockford.

Specifically, Earlswood Homes consider that land east of Hockey Hill, Wetheringsett (SHELAA reference SS1133) should be included within the settlement boundary of Wetheringsett-cum-Brockford (Church) and allocated for residential development (approximately 8 homes) within the emerging Joint Local Plan, based on the reduced area identified above.

Whilst acknowledging the conclusions of the previous SHELAA, for the reasons above, Earlswood Homes strongly believe that this site (based on the reduced area proposed) represents a suitable, available and achievable small- scale development opportunity which would be well-connected with, and sympathetic to, the village.

Earlswood Homes looks forward to engaging with Babergh & Mid Suffolk as the Joint Local Plan progresses and would welcome the opportunity to provide any further information or clarification as may be considered necessary to support the allocation of this site. Should you have any queries or wish to discuss these representations, please do contact me on the details below.

Yours sincerely

David Smith Regional Director - East Anglia

www.earlswoodhomes.com

Earlswood Homes www.earlswoodhomes.com Earlswood Homes Holdings. Company number 8130321. Registered in and Wales