Waveney Local Development Framework Draft Open Space Supplementary Planning Document Consultation August 2011

Consultation Statement August 2011

A draft Supplementary Planning Document (SPD) has been prepared to assist with the implementation of policy DM25 of the Development Management Policies.

Prior to the preparation of this draft document a preliminary consultation was undertaken to identify potential content matter. The consultation was targeted towards organisations that have planning and development interests in the District including the provision of open space. Groups included Town and Parish Councils within the District, adjoining local authorities, local and national organisations with a potential interest in open space and members of the Developers Forum, The consultation was open for six weeks between 14 th April 2011 and 27 th May 2011. There were 13 responses to the consultation. Consultees were contact by email, or where appropriate, by post. A list of consultees is provided below.

As part the Council’s ongoing engagement with local developers the proposed content and layout of the Draft Open Space Supplementary Document was put forward for comment at the Developers Forum event held on February 1st 2011. The Developers Forum consists of local developers, housing providers and Council officers with events taking place quarterly to share information.

The document has been prepared and approved in conjunction with the Local Development Framework Working Group. This working group consists of thirteen Elected Members and Council Officers. .

An article was placed in the ‘In Touch’ magazine published by the Council in July 2011 and distributed to households in the District to inform the public that the Draft Open Space Supplementary Planning Document was being prepared and would soon be available for public comment.

List of Consultees

Town and Parish Councils

Barnby Parish Council Parish Council Barsham & Parish Lound Parish Council Council Town Council Parish Council Benacre Parish Council Parish Council & Flixton Parish Council Parish Council & Parish Council Oulton Parish Council Brampton with Parish Council Redisham Parish Council Town Council Parish Council Parish Council & Weston Parish Council

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Corton Parish Council Parish Council Parish Council Rushmere Parish Council Flixton, SE St Cross & St Margaret , , Willingham & Parish Council Parish Council , & South Cove , Ashby & Parish Council Parish Council Parish Council Town Council Town Council Parish Council with Hulver Street Parish Parish Council Council Holton Parish Council Three Saints Parish Council Parish Council with Henham Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Wrentham Parish Council

Adjoining Local Authorities

Broads Authority South Norfolk District Council Great Yarmouth Borough Council Coastal District Council Mid-Suffolk District Council Suffolk County Council

Local Organisations

Active Waveney Halesworth Playing Field Association Beccles Society Kessingland Sports and Social Centre Broads Society -GY NHS Bungay Allotment Society NPS Bungay Society Positive Changes 4 Young People Fen Park Friends Southwold and Reydon Society Friends of Gunton Community Park Suffolk Wildlife Trust Friends of North Lowestoft Parks Waveney Norse Geoff Young Waveney Play Partnership Gunton Woodland Community Project WeCount2

Government Organisations

Environment Agency Sport Natural England

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Developers Forum Members

AAK Design Associates Ltd M. Dixon (Agent) Arnolds Chartered Surveyors M S Oakes Ltd Ashgate Construction Limited Oakwood Construction ASD Architecture Oldman Homes Ltd Badger Building East Anglia Ltd OWL Partnership B. Cutts (Agent) P. England (Agent) Barsham Securities Ltd Paul Robinson Partnership Brian Haward Chartered Architect P. Tungate (Agent) Brian Sabberton Ltd Persimmon Homes (Anglia) Ltd Chaplin Farrant Ltd PDA Architectural Homes Ltd P J Spillings Circle Anglia Pure Architecture Ltd Cripps Developments Ltd Purple Property Ltd Duncan and Son Ltd Riddle Construction Ltd Flagship Housing RRS Garret Design Sprake and Tyrrell Ltd Gilbert Builders Taylor Properties Graham Ling Architectural Consultant Technicus Consulting Heritage Construction Tredwell Developments Hopkins Homes Ltd Utting Construction Howard Group New Homes Land Vaughan Keal Associates Division J. Bennet (Architect) WAS Ltd. J. Kelly (Agent) Warnes and Son Ltd J. Putman (Agent) Wellington Construction Ltd K Holdings Ltd (Anglia)

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Responses to the Preliminary Open Space Supplementary Planning Document Consultation 2011

Question 1 Below is a preliminary list of information we are considering to include in the SPD. Do you think there is anything else that needs to be covered to ensure the document is as helpful as possible? Or is there anything listed that you consider does not need to be included?

• General information on the intentions of the document. • Background information: o Planning policy framework; o Types and benefits of open space. • Identifying the issues: o Evidence base (including the Open Space Needs Assessment, Playing Pitch Assessment, Open Space and Play Strategies); o Current open space provision and shortfalls in Waveney. • Provision of Open Space: o Quantity and accessibility standards. o Scope of provision (residential, industrial, holiday uses, exceptions); o Circumstances where on-site or off-site provision is appropriate; o How density affects open space provision; o Open space design (general concepts, play spaces, industrial developments). • Developer contributions: o Larger settlements and rural areas; o On-site and off-site provision; o Open space contribution calculations and payments; o Summary of contributions (located at the front or back of the document). • Monitoring of contributions. • Adoption and maintenance standards. • Diagram showing the planning application process and how this relates to open space provision. • Section 106 (s106) agreements and the Community Infrastructure Levy (CIL).

Responses

Respondent Comment Comment WDC Response WDC Action Number Beccles Town 1 The provision of allotments Agree. Allotments are Council should be addressed in the identified as a document. form of open space and are discussed in the SPD.

Beccles Town 2 Are linkages between open Yes. Linkages are Council spaces via green corridors discussed in for walking, cycling and the SPD. wildlife to be covered in the

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document? Environment 3 There is a great opportunity Noted. The benefits of Agency with this SPD to promote Examples open space and give some examples of would be such as how open space can be useful, mitigating flood designed/ managed to however, they risk and any enhance the environment. are considered potential Many of these benefits to be more environmental have been acknowledged in appropriate to impacts are the supporting text to policy be included in discussed in DM25 and no doubt will be an updated the document. re-emphasised in your Open Space SPD, but giving examples Strategy. A weblink to of what can be achieved the would be very useful. Environment Some basic information can Agency’s be found on our website: website is http://www.environment- included in the agency.gov.uk/business/se SPD. ctors/32713.aspx .

Gunton 4 Under the section Burial land will Reference to Woodland Identifying the Issues it may be identified in the Site Community be relevant to highlight the the SPD as a Specific Project impending shortage of type of open Allocations Burial Land in the Lowestoft space. The DPD has been area and the resulting need need to identify made. to address this. new burial land has been covered in the adopted Site Specific Allocations DPD and will be addressed through a review.

Gunton 5 It is important that new Agree. The importance Woodland proposals should meet the of open space Community objectives of a green to support Project network linked by wildlife biodiversity is corridors, with full discussed in consideration being given the document. to the principles set out in policies DM27 (Protection A list of policies of Landscape Character), that are related DM28 (Strategic Gaps and to open space Open Breaks) and DM29 of some form (Protection of Biodiversity are listed. and Geodiversity).

Gunton 6 Unclear what detail will be Noted. The Not appropriate Woodland provided in the diagram SPD is to assist to include in the Community showing the planning with the document. Project application process? It is implementation essential that before the of policy DM25

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Site Specific Allocation of the phase is opened for public Development consultation, the relevant Management landowner should be Policies and contacted (providing this is will not possible to do) and his or introduce new her support should be policy or land enlisted in order that the use allocations. scheme has a reasonable chance of success. Natural 7 It would be useful to refer Agree. Green England specifically to green infrastructure infrastructure in the SPD as and associated it is evident that, in order to benefits are achieve sustainable discussed in development, good quality the SPD. green infrastructure, including accessible natural greenspace, must be included as a primary consideration in developments.

Besides access and biodiversity provision, accessible natural greenspaces will provide a variety of other functions such as: • Alleviating and reducing the effects of climate change; • Mitigating flooding; • Providing space for informal recreation; • Positively affecting the health of site users; • Providing opportunities for environmental learning and aiding social development; • Offering social benefits such as crime reduction and community cohesion; • Demonstrating a variety of ecosystem services; • Improving the economy of an area by raising property values and attracting investment.

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Natural 8 The important role of open Agree. A statement England space, particularly has been accessible natural included in the greenspace, in relieving SPD. recreational pressure on designated landscape and nature conservation areas should be discussed in the SPD.

Natural 9 The SPD should include Agree. Complementing England provision for the extension, the section on inter-linking and green enhancement of open infrastructure, space and green the importance infrastructure to increase of green the strategic value, quality corridors for or quantity of important biodiversity and natural greenspace and movement is access facilities. discussed as well as the potential to improve existing open spaces if that will meet identified local needs.

Natural 10 It would be helpful to The use of Not included. England include designated nature open space to conservation sites under mitigate this heading including Sites potential of Special Scientific impacts on Interest, Special Protection protected sites Areas, Special Areas of is discussed, Conservation, National however, it is Nature Reserves, County not considered Wildlife Sites and Local appropriate to Nature Reserves. identify protected sites in this document.

Natural 11 Natural England suggests Agree. The Accessible England that the Council considers Council has Natural adopting the Accessible made previous Greenspace Natural Greenspace reference to Standards are Standards (ANGSt) as these included in the briefly set out below. No standards. document. person should live more than 300 m from their nearest area of natural green space of at least 2 ha in size There should be at least one accessible 20 ha site within 2 km of home There should be one accessible 100 ha site within 5 km of home. There

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should be one accessible 500 ha site within 10 km of home.

Natural 12 We consider that all new The submission Not included. England developments, not only version of the residential, could contribute Development towards accessible natural Management greenspace provision. As Policies sought all residents and people open space working in the district will contributions benefit from improved and from residential enhanced accessible and non- natural greenspace and residential facilities to enjoy outdoor development recreation, then all types of but this was not development could supported by contribute. the Planning Inspector.

NHS Great 13 The document does not Yes. The benefits of Yarmouth and address the opportunities open space Lowestoft that open spaces provide including those for physical activity. Is this related to to be considered? physical activities and accessibility are discussed in the SPD.

NPS 14 Uncertain in what context Noted. A statement is the reference to ‘industrial included in the developments’ is being SPD stating the made? need to consider the inclusion of open space as part of the design process to provide benefits for workers and the immediate environment.

NPS 15 Aspects of quality of open Agree. The importance space as well as quantity of quality and should be addressed in the value of open SPD. spaces to the community is discussed in the SPD as well quantity of provision.

Identified shortfalls of both quantity and quality of open space are

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set out in the document.

Sport England 16 Our focus is around three Noted. Provision for outcomes - growing and open space for sustaining the numbers of outdoor sport is people taking part in sport discussed in and improving talent the SPD. development to help more people excel. From Sport England’s perspective therefore, our main concern and remit with a document such as this is with regard to the provision of open space for outdoor sport – primarily playing fields, recreation grounds, artificial turf pitches, tennis courts, bowling greens etc. To this end Natural England is supportive of the reference in the supporting document to the evidence base including the WDC Playing Pitch Assessment, as this implies that provision for outdoor sport will be a key component of the document.

Sport England 17 Natural England is not Noted. It is As the most up aware of a more up to date recognised that to date playing pitch assessment the Pitch and assessment of than the one carried out in Non-Pitch playing pitches 2002, and from Sport Assessment in the District England’s perspective we could be the Pitch and are of the view that a updated and Non-Pitch playing pitch assessment some updating Assessment is needs to have been was quoted as an completed or substantially undertaken important part reviewed within a three during the of the evidence year period to be classed preparation of base. as an up to date the Open assessment and therefore a Space Strategy sound evidence base on (2007). which to be base local However, policy. We would therefore Waveney has recommend that a new not playing pitch assessment experienced a should be carried out, using significant the recommended amount of methodology in Sport growth since England’s guidance 2002 and the document ‘Towards a Level needs identified Playing Field: A Guide to in the the Production of Playing assessment Pitch Strategies’ as the are still valid. methodology framework. This study would then

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constitute an accurate and up to date assessment of provision in the Waveney area (including identified shortfalls by geographical area – e.g. ward level).

Sport England 18 With regard to the provision Noted. Ancillary The importance of outdoor space for sport, facilities will be of ancillary it is critical to include a taken into facilities is qualitative and quantitative account when discussed in assessment of essential considering the the document. ancillary facilities, provision of particularly changing new open facilities and car parking. space and Previous studies show that improving it is often these elements existing open which are the key priorities space. for provision or enhancement, rather than the open space itself, and Sport England does not advocate the provision of new facilities for outdoor sport without adequate ancillary facilities to serve them.

Suffolk County 19 There is potential that open Agree. Section is Council space be used to included in the (Archaeology) preserving important document heritage assets of discussing the archaeological interest in potential for situ within new open space to developments (i.e. below protect local ground archaeological heritage. remains can be preserved within the open space areas).

If archaeological evaluation is undertaken at an early stage in a project, and important sites are identified, the information can be used to inform the design of the masterplan scheme, and the open space (where feasible) can be to designed to coincide with the archaeological remains. This results in a win-win situation - the heritage assets are preserved/ protected in perpetuity and the costs to the developer can be significantly reduced (if the amount of archaeological excavation is reduced).

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Suffolk County 20 The Open Space strategy Agree that Green Council ideally ought to be individual open infrastructure (Spatial grounded within a wider spaces should and the Planning) green infrastructure also be importance of strategy as there are likely considered in a open space important green spaces strategic sense networks are which lie outside the to meet the discussed in PPG17 definition and which needs of both the document. could help complement the immediate provision and/or provide residents and As part of the important spatial links. In the wider evidence base, this context it is worth community. Waveney’s looking at work done by St Open Space Eds. Currently the Strategy (2007) Council is not will support the proposing to SPD. prepare a green infrastructure strategy but may do in the future.

Suffolk 21 Open space / green space Noted. The potential Coastal can be used to mitigate for open space District impacts on protected sites. to be used to Council mitigate the (Planning impacts of Policy) development has been addressed in the document.

Southwold 22 The current Section 106 Government The statutory Town Council rules are over restrictive. It policy restricts tests in Circular is very difficult for money to the use of 05/2005 are set be spent within the Section 106 out in the SPD. stipulated distance from a funds. development. Can more Contributions flexibility be introduced so must meet the that Section 106 funding statutory tests can be spent anywhere set out in within the parish at the Circular Town/Parish Council’s 05/2005, in discretion? particular ‘making acceptable development which would otherwise be unacceptable in planning terms.’ The Community Infrastructure Levy recently introduced by the government will provide

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greater flexibility.

Question 2 Shortfalls of open space and related facilities have been identified across the District. However, different areas require different types of improvement. When new open space and/or facilities are to be provided or improved what do you consider is the most appropriate way to identify and prioritise the needs of an area? • Would it be more useful to set out the requirements for each area (location) in the SPD so it is clear from the outset how contributions will be allocated and invested in the community? or • Do you think that a more flexible approach is needed? Would it be more beneficial to set out the general process for deciding what investment is most appropriate and were based on the needs of the community at the time of the planning application?

Responses

Respondent Comment Comment WDC WDC Action Number Response Broads 23 There is merit in providing a Agree. The SPD Authority structure for explains the provision/investment, in the importance of interests of clarity about where the evidence and what type of public open base to space is to be provided in a delivering particular area. However, there open space should also be some flexibility that will meet to allow for changes in local needs. circumstances (in an area or The SPD across the District), or to states the address the requirements of a need to particular development. This consult type of approach (structure relevant combined with flexibility) would Town and also appear to reflect the Parish content of your Policy DM25. Councils when appropriate without limiting the flexibility of providing open space by agreeing the type of open space provision with the developer at an inappropriate time.

Gunton 24 Of the two options presented, Agree. The The SPD

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Woodland we much prefer that the second provision of explains the Community (more flexible) approach is open space importance of Project followed, for several reasons, and the evidence not least of which is the fact improvement base to that the needs of the of existing delivering community can change quite open spaces open space rapidly over a relatively short will be based that will meet period of time. on identified local needs. needs of the In this context, we hope that the community. The SPD last bullet point of policy DM29 states the is interpreted in the following Consideration need to way: s for any consult Development of open development relevant areas…will only be permitted of open space Town and where…an assessment are set out in Parish demonstrates that the site is policy DM25 Councils surplus to requirements and is and where when likely to remain so for the necessary will appropriate foreseeable future. be used in without We will look forward to conjunction limiting the receiving and commenting on with other flexibility of the draft Open Space SPD in a policies in the providing few months time. Core Strategy open space and the by agreeing Development the type of Management open space Policies . provision with the developer at an inappropriate time.

Norfolk & 25 Setting out the requirements Noted. The The Suffolk clearly for each area is called text in the document Aviation for, along with an explanation SPD seeks to identifies Museum of the decision process behind aid the open space them. decision needs across making the District process and and is provide supported justification with a for the comment that approach more locally taken. specific information may be required in some circumstance s. Norfolk & 26 Your reference to "at the time of The type of The SPD Suffolk the planning application" open space explains the Aviation suggested that "the clear to be importance of Museum requirements" might be subject provided will the evidence to change/dilution at the time of be decided base to application. by the Local delivering Planning open space Authority that will meet based on local needs.

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identified The SPD need and states the appropriate need to discussions consult with Town relevant and Parish Town and Councils. Parish Councils when appropriate to ensure the most correct facilities are provided.

Open space needs may change between planning permission being granted and using the contributions. Therefore flexibility is required.

Suffolk 27 The critical issue in terms of Agree. As all The statutory County Section 106 are that the CIL residential tests in Council Regulations 2010, which came development Circular (Section 106) into force on 06 April 2010, is required to 05/2005 will mean that planning obligations contribute be set out in are subject to three statutory open space it the SPD. tests set out in Regulation 122. will be the On this basis potentially each developer’s Areas with public open space contribution responsibility identified will need to be justified on its to clearly shortfalls of own merits, rather than on an demonstrate quantity and area wide or pooled standard circumstance quality of charge approach. s where no open space contribution are set out in is justified. the SPD. A statement The CIL is clarifies that discussed in further site the SPD and specific briefly assessments outlines how may be it will relate to required in the provision some of circumstance infrastructure s. associated with new The development. implications of CIL with Parts of the regard to SPD that open space relate to off- provision and

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site open contributions space are discussed provision and in the contributions document. will be superseded The use of with the planning adoption of obligations the CIL. and how these are likely to change with the introduction of CIL are covered in the SPD.

Suffolk 28 Whilst existing shortfalls of Agree. This issue County open space and related has been Council facilities have been identified included in (Section 106) across the District, the costs of the SPD. remediating these existing deficiencies should not fall on new development. However, it would seem perfectly reasonable for new development to mitigate local impacts to avoid making existing deficiencies worse or placing existing provision under pressure.

Suffolk 29 There is a difference between Agree. Quantitative County on-site and off-site provision; a and Council judgement needs to be made qualitative (Section 106) on both quantitative and open space qualitative open space shortfalls are provision. identified in the SPD. Guidance is provided in the SPD to support the use of open space contributions (in kind or financial) that best reflects the needs of the area.

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