Hundon Residents Group
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Representations in response to West Suffolk Council’s Local Plan – Regulation 18 of the Town and Country Planning (Local Development) (England) Regulations 2012 On Behalf of Hundon Residents Group December 2020 Our Ref: C20114 270 Avenue West | Skyline 120 | Great Notley | Braintree | Essex | CM77 7AA | 01376 329059 | www.phase2planning.co.uk Quality Assurance Site Name: Hundon Client Name: Hundon Residents Group Regulation 18 - Representations in response to West Suffolk Council’s Type of Report: Local Plan Author Initials Date Lisa Skinner BSc (Hons) MA DipMgt MRTPI LS 16/12/2020 Director Reviewed Initials Date Emma Walker BSc (Hons) MA MRTPI EW 16/12/2020 Associate © Phase 2 Planning and Development Ltd 2020 Contents Executive Summary ................................................................................................................................. 1 1. Introduction .................................................................................................................................... 3 2. Planning Policy ................................................................................................................................ 4 3. The Village of Hundon ..................................................................................................................... 6 4. Existing Planning Policy ................................................................................................................. 10 5. Evidence Base for the Emerging Local Plan .................................................................................. 16 6. Response to the Plan Policies ....................................................................................................... 22 7. Conclusions ................................................................................................................................... 39 Appendices Appendix 1 – Village Photographs © Phase 2 Planning and Development Ltd 2020 Executive Summary These representations have been prepared on behalf of the Hundon Residents Group in respect of the West Suffolk Local Plan, Regulation 18 Consultation - Issues and Options, (“the Plan”) published for consultation from 13 October 2020 to 22 December 2020. We have reviewed the Plan and the associated evidence base and do not believe it meets the requirements of paragraph 31 of the NPPF that requires the Plan to be based on up-to-date evidence that is relevant, adequate and proportionate to the policies concerned for the following reasons: • We support the principle of a settlement hierarchy. However, there are fundamental errors in how the evidence base has been produced that has led to flawed assessments of the settlements within the suggested hierarchy. • The evidence base for assessing the Village of Hundon is considered to be fundamentally flawed on the basis of the location of the Village and the facilities available within the Village. • According to the Plan, the population mid year estimate in 2018 is 1,915. However, in the Core Strategy in 2009, the population was stated as 1,061. This suggests nearly doubling of the population in 10 years which does not appear to be correct and should be investigated further. • Hundon should not be considered a local service centre in relation to the actual facilities within the Village. • The Village is not situated in a sustainable location. There is no regular public transport and the Village is accessed by rural, unclassified roads. • There are no cycleways in the Village and there are restricted width pavements in some areas and no pavements in other parts of the Village. • The Village is served by a 25sqm community shop that has limited opening hours and is run by volunteers apart from one part time employee. • The Village Post Office is only open for limited hours. • The Village Community Shop and Post Office would not survive without subsidies from the community and are therefore not commercially viable. • The Village School would not be able to extend to accommodate additional pupils. • The heritage assets, landscape character, topographical nature of the area and overall attractiveness of the Village has not been assessed. We object to the methodology and the assessments within the Plan and associated evidence base for the reasons identified in these representations. In summary, the key issues that are being considered by the Plan relate to the options for growth that have been informed by this background evidence. As we object to the evidence base, we therefore also object to how this has then been used to inform subsequent proposals in the Plan, in particular with regard to the settlement hierarchy and the sustainability assessment for sites referred to as “included” as part of the SHELAA. The current approach within the Plan will not lead to growth taking place in the most sustainable areas and will increase the reliance and use of the private car and will not therefore lead to sustainable development and is contrary to the Strategic objectives of the Plan itself. We do not therefore believe that the Plan has been positively prepared, justified, effective or consistent with 1 national policy that seeks to enable the delivery of sustainable development. The Plan is not therefore considered to be sound in accordance with the requirements of paragraph 35 of the NPPF. We therefore request the Council considers our objections in relation to the accessibility of the Village, the services and facilities available, the suggested position within the settlement hierarchy and the current sites registered as “included” within the SHELAA to address these deficiencies. 2 1. Introduction 1.1 These representations have been prepared by Phase 2 Planning and Development Ltd on behalf of the Hundon Residents Group in respect of the West Suffolk Local Plan, Regulation 18 Consultation - Issues and Options, (“the Plan”) published for consultation from 13 October 2020 to 22 December 2020 which covers the Plan period to 2040. The Group comprises a number of residents: Ed & Alison Turner Bears Farm, Valley Wash Jeremy Barker & Sarah Barrington Smiths, Street Farm, North Street Anne & Michael Brummitt Mary Lane Darren & Emma Butler Hill Farm, Barnadiston Road Nick & Tamsin Appell Bachelors Hall, Mary Lane Glenn Cass & Kay Frost Mary Lane Sarah & Colin Sherrington-Scales Clare House, Mary Lane Dominic Holmes Street Farm, North Street 3 further individuals who prefer to remain anonymous 2 households in the village of Hundon 1.2 This Report provides our representations to the Plan in relation to the manner in which the settlement hierarchy has been developed, the assessment of individual settlements with particular regard to Hundon, how these assessments have been carried out, the potential allocations and the potential impact on this rural Village. 3 2. Planning Policy 2.1 The National Planning Policy Framework (NPPF) was first published in March 2012, and subsequently updated in 2018 and 2019. This sets out the Government’s planning policies and how they are to be applied. The NPPF stresses the main purpose of the planning system is to help achieve sustainable development and sets out three overarching objectives to achieve this that are interlinked and include an economic, a social and an environmental objective. 2.2 There is a presumption in favour of sustainable development and local authorities are expected to positively seek opportunities to meet the development needs of their area and local plans are expected to meet objectively assessed housing needs with sufficient flexibility to adapt to rapid change. 2.3 The NPPF sets out the required approach to Plan-making in paragraphs 15 – 37. Each Planning Authority should set out the strategic polices for the area in the Local Plan including the homes and jobs needed in the area. Crucially, Local Plans should: “a) be prepared with the objective of contributing to the achievement of sustainable development; b) be prepared positively, in a way that is aspirational but deliverable; c) be shaped by early, proportionate and effective engagement between planmakers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees; d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals; e) be accessible through the use of digital tools to assist public involvement and policy presentation; and f) serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).” 2.4 Paragraph 31 seeks to ensure that the Local Plan is based on adequate, up to date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. This should be adequate and proportionate and focused tightly on supporting market signals and justifying the policies concerned taking into account market signals. 2.5 Paragraph 32 refers to the importance of the Sustainability Appraisal and how this should demonstrate how the plan has addressed the relevant economic, social and environmental 4 objectives and that significant adverse impacts on these objectives should be avoided wherever possible and that alternative options which reduce or eliminate such impact pursued. Soundness 2.6 Paragraph 35 of the NPPF states that during a Local Plan examination, an independent inspector will determine the soundness of that Plan in accordance with the four tests listed below: “Positively