Hundon Residents Group

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

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

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

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

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.

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.

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

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 prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;

Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

Effective – deliverable over the plan period, and based on effective joint working on cross- boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.”

2.7 In preparing these representations we have had full regard to the National Planning Policy Framework’s (NPPF) policies on the soundness of the emerging Local Plan. Our representations on the specific policies are made with reference to these tests.

3. The Village of Hundon

3.1 In the Plan at paragraph 4.9.1, Hundon is described as a Village “… located approximately nine kilometres north-east of Haverhill and approximately 18 kilometres south-east of Newmarket with a population of 1,915 (2018 mid-year estimate). Hundon has a reasonable range of facilities including: • Primary school; • Pre-school; • Public House; • Convenience food shop; and • A playground and artificial grass pitch”

3.2 There is also a Church and a Village Hall. The Community Village Shop is small and comprises approximately 25sqm of floor space and this also contains the Community Post Office. Hundon Hedgehogs offer a Pre-school at the Village Hall for 2- 4-year olds.

3.3 In the Plan, there are two important aspects to consider in relation to how the Village is described, firstly the location of the Village within the area and secondly the level of facilities and services available. We believe there have been errors in how Hundon has been assessed and this has led to decisions in relation to the Village being based on incorrect evidence and therefore contrary to Paragraph 31 of the NPPF. The following paragraphs explain our reasoning.

i) Background and the location of the Village

3.4 The Village is clearly defined with a settlement boundary in the current adopted Local Plan and this predominantly follows the physical boundaries that are clearly defined by the road network Lower Road to the south and Mill Road to the north.

3.5 The Village was initially established as an agricultural settlement according to heritage records and the existing Village is surrounded by agricultural land which is classified as Grade 1/2 forming some of the most versatile agricultural land. The Village is built on the south facing side of the valley with the stream at the bottom that feeds into the River Stour. The land to the north of the settlement is on higher ground which is open. The character of the Village is established by the physical boundaries formed by the road and the open green spaces formed by the recreational areas and the allotment in the centre of the Village running in a north/south axis. This includes the Village hall and recreational area.

3.6 As stated within the Plan, the Village is located 9km from the nearest main settlement at Haverhill and it is not located on any main roads or within close proximity to any classified roads.

3.7 The Village is considered to be remotely located with the nearest main supermarkets and services located in the main towns of Haverhill, Bury St Edmunds and Newmarket. At Clare, approximately 6.4km, a small Co-op exists.

3.8 The Village is served by rural unclassified roads. Hall Road links the Village to the B1063 that is situated to the north of the Village that then leads onto the A143 several kilometres away.

3.9 In relation to main roads, the A143 is approximately 4km from the Village Hall if accessed at Barnardiston to the west and 4.8km, if accessed at the Stradishall junction to the north via the B1063. Villagers tend to go via Barnardiston to access services in Haverhill, south or north Cambridge and via Stradishall for Newmarket or Bury St Edmunds. According to Google Maps, if villagers decide to visit Tesco’s at Haverhill, (the nearest large supermarket), there would be a journey time of approximately 12 minutes, (9.2km), via the narrow unclassified roads to Barnardiston or 19 minutes, (17.2km), via Hall Road, the B1063 and then on to the A143 at Stradishall. Haverhill has traditionally been the main destination for out-commuting and an additional 14 minute, (16km), round trip driving time/distance makes the Stradishall route to Haverhill impractical and is also contrary to the aim of the Plan to achieve sustainable travel patterns and development.

3.10 There are a limited number of roads that provide access to the Village, all of which are unclassified roads. The roads through Hundon to Barnardiston and on to the A143 are narrow with pinch points. Mill Road is single lane with informal passing places and two cars may only pass with care on Whitings Hill, (part of Church Street) and not at all for approximately 100m. North Street and Church Street are two lanes but cars usually park on one side. Lower Road and Valley Wash are two lanes but restrained by narrow bridges that only allow a single vehicle to pass and both are subject to flooding and surface water issues. The vehicle access to and from the Village is therefore constrained in all directions.

3.11 There are no cycleways within the Village and the pedestrian networks are restricted. In some areas of the Village a narrow footpath exists on one side of the road, and in other areas no footpaths exist at all, and pedestrians use the road.

3.12 With respect to public transport, when the Village was assessed as part of the previous adopted Local Plan, there was a commercial bus service. This no longer exists as acknowledged in the latest evidence base for this Plan where it states there is currently one bus service in the morning and one in the evening. On-line research has confirmed that the 14B service operated by Stephensons of Essex runs a service Monday to Friday from Haverhill to Bury St Edmunds with a stop at Hundon at 7.40. However, there appears to be no return service. There is a West Suffolk Hospital Ride that is a demand service with a dial up service.

3.13 Public transport options are therefore very restricted and overall, the Village is not considered to be a sustainable location as the majority of activities would involve the use of the private car.

3.14 The character of the Village including the road and footpaths in the area are shown in the photographs attached at Appendix 1 of this Report.

ii) The facilities within the Village

3.15 The Plan at Paragraph 4.9.1 considers the Village to have a reasonable range of facilities and lists the five facilities that are available within the Village. It is important to consider the nature of the services as follows:

The Primary School

3.16 The Village currently has a primary school which is acknowledged in the latest Ofsted Report as being “much smaller than the average-sized primary school.” The school serves the Village of Hundon and children from outside the Village can apply to attend. The school covers the age range of 4-11. There are currently 69 pupils on the role with 26 children that attend from outside of the Village which is approximately 37% of the total pupil numbers. The school operates in mixed years groups.

3.17 All staff drive to work and only 33% of pupils either walk or cycle to school despite 63% of the children living in the Village. This is considered to be partly due to the lack of pavements in the area and the reliance on the private car to access employment and other facilities in the area.

3.18 The school has a playground on site for playtimes and lunch times. The Village astro turf is used at lunchtimes for sport clubs and outdoor PE sessions. The playing field adjacent to the Village hall and cricket meadow on lower North Street are also used. This involves the children leaving the school and crossing North Street to get to the astro turf/playing field adjacent to the Village hall as there is no pavement on the west side of North Street. To reach the cricket meadow they cross over Church Street and then North Street.

3.19 The school site is therefore heavily constrained and would not be in a position to extend to accommodate additional pupils if required. In addition, the detached nature of the playing fields is not ideal.

The part-time Village Shop and Community Post Office

3.20 For the 5 years prior to 2019, the small Village shop ran at a loss or a very little over break even and was subsidised by the Village Hall and Playing Field Charity. The post mistress left in 2017 and Post Office Limited intended to close the post office as it was not commercially viable. A group of residents combined and created a scheme to subsidise a new post mistress.

3.21 The current Village shop opened in April 2000 and is run by volunteers, apart from one part time employee, as a service to the community and pays no rent. It is only open on a part-time basis, Monday to Saturday 8am to 1pm and Sunday 10am to 12pm. The community village

shop also allows the Community Post Office some space and this opens on a part time basis between 9am and 1pm. The community shop cannot therefore be considered to be a permanent commercially viable facility as it is subsidised by voluntary contributions from the community. Neither the community shop nor the community post office would survive without the subsidies as they are not commercially viable and the shop only operates due to volunteers in the community.

Recreational facilities

3.22 There is a small playground for very young children, the cricket meadow, other playing fields and an artificial grass pitch within the Village along with allotments. The latter are operated by the Hundon Allotment Tenants Association who have been given permission to improve the value of the allotment field by developing a Community Orchard and Meadow. These form an important open area within the centre of the Village providing recreational facilities and fall within the conservation area designation. These open areas also provide multiple interconnecting pedestrian ways across green spaces between different parts of the village, offsetting in part the lack of roadside footpaths. They provide vital connectivity and areas for social interaction.

Summary

3.23 Whilst the Plan and supporting evidence describe the Village, it is essential that this evidence in relation to the location of the Village within the wider area, the accessibility of the Village to and from the surrounding area, the availability of public transport and access within the Village itself by road and footpaths and the services/facilities available is adequate. We believe that The Plan does not adequately describe the characteristics of Hundon as required by the NPPF and therefore that conclusions based on the evidence in the Plan should be revisited.

3.24 Paragraph 31 of the NPPF requires the Plan to be based on adequate, up to date and relevant evidence. The above information is considered essential in order to fully assess the nature of the settlement within the hierarchy. If this evidence is fully taken into account, in our view Hundon would not be considered to be a sustainable settlement as currently assessed by the Council. We therefore object to the current assessment of the Village and believe this should be updated in the light of the information submitted.

4. Existing Planning Policy

4.1 Hundon falls within the former St Edmundsbury Borough Council jurisdiction in relation to the local planning policies. The Development Plan for the area comprises:

• The Core Strategy adopted in December 2010;

• Vision 2031 that comprises, St Edmundsbury Vision 20131, Haverhill Vision 2031 and Rural Vision 2031. The latter is relevant to Hundon and was adopted in September 2014;

• Joint Development Management Policies Document adopted February 2015; and

• Former St Edmundsbury area policies map.

4.2 The historical evidence that informed the development plan for the area is important to understand the current status of the settlement hierarchy and how this has evolved. This will be outlined in the following paragraphs.

4.3 The Core Strategy (CS) was informed by a variety of evidence including the Sustainability Appraisal Report that was produced in September 2010. The CS was submitted to the Secretary of State for assessment and following the Examination in Public, (EIP), the Inspector produced a Report in August 2010 that required a number of small changes to be made in order for the Core Strategy to be found sound. The settlement hierarchy was discussed at the EIP including settlement identity on the basis of a settlement hierarchy split between towns, key service centres, local service centres, infill villages and the countryside.

4.4 Hundon was considered to be a Local Service Centre in the Core Strategy in recognition of the range of local services and facilities it had to serve the community and surrounding rural population. The Council acknowledged that there were various constraints to development in Hundon as follows:

• Constrained by Lower Road to the south and Mill Road to the north

• The southern boundary of the Village is covered by a flood zone which will prevent any further development in this area

• The village is situated on the south facing slope of the valley and the land rises in a northerly direction

• There are various heritage assets that include a conservation area that covers most of the eastern part of the Village and various listed buildings that follow North Street, in the east of the Village. There are also designated archaeological sites in the area

• Ecology matters including two locations where biodiversity action plan species have been identified to the east of North Street

4.5 The Core Strategy at page 77, paragraph 7.34 acknowledged that “The village has very few local employment opportunities and a limited bus service to Haverhill, …”

4.6 There are two key policies in the CS that are of importance, namely CS1, St Edmundsbury Spatial Strategy and CS4 Settlement Hierarchy and Identity.

4.7 Policy CS1 set the spatial strategy for the area with the aim to focus growth around Bury St Edmunds and Haverhill and protect the identity of those villages that surround the towns. The following table included within the policy identifies the possibility of 14% of new housing development within the rural area.

4.8 The following is an extract of the Key Diagram from page 35 of the CS which shows the key infrastructure in the area with regard to road networks and the main settlements. Hundon is noticeable due to the distance from any main roads or towns.

Hundon nn

4.9 Policy CS4 refers to the settlement hierarchy and identity of the settlement. Whilst the main focus for large scale growth for employment and housing was proposed in Bury St Edmunds and Haverhill, a high proportion was expected to be located in the rural area in those villages which have a range of services and facilities to meet local needs. The settlement allocations were based on surveys of local services and facilities surveys undertaken in Spring 2009. This led to decisions on where development should be focused having regard to the widest range of services that would reduce the need to rely on the private car. This was caveated in the Plan that regard would also be had to the impact of development on the natural and built environment.

4.10 Paragraphs 4.55 to 4.57 of the CS identified the criteria used for a settlement to be considered a Local Service Centre and identified 13 villages that met the criteria that meant each village had to have at least three of the following:

• a primary school; • community, leisure and social facilities; • convenience goods shop; • local employment opportunities; or, • a good journey to work public transport service to higher order towns.

4.11 In these villages that included Hundon, only limited growth was anticipated with small scale housing of up to 10 units and some employment development would be encouraged. The scale of growth would also be dependent upon the local environmental and infrastructure capacity of each settlement. Further details were expected through the Rural Site Allocations Development Plan Document and it was anticipated that proposed development sites would normally be adjacent to existing housing settlement boundaries.

4.12 The final paragraph of Policy CS4 is of significance and states:

“Careful consideration will be given to maintaining the identity, character and historical context of settlements, to ensure new development does not detract from the environmental quality, townscape, functional vitality and setting of the settlement as a whole. The coalescence of towns with surrounding settlements through new development will not be allowed to happen.”

4.13 There are a number of points that are important in respect of this with regard to Hundon. It was acknowledged that there were constraints to development in Hundon as listed in paragraph 4.4 above. The settlement status also relied on 3 out of 5 criteria being met. Hundon only met the first 3 criteria as there were no employment opportunities and public transport was restricted.

4.14 Policy CS7 refers to Sustainable Transport and all developments were expected to provide alternative means of travel rather than the private car and be accessible to a range of people including all abilities and those with mobility impairments. A hierarchy of sustainable transport was produced as follows: • Walking • Cycling • Public Transport (including taxis) • Commercial vehicles • Cars

4.15 Chapter 7 and paragraphs 7.24 to 7.39 refer to the rural area and local service centres are defined as “These Local Service Centre villages with a few services and facilities, such as a shop and a school, tend to be local centres for a wider rural area than the settlement alone. These villages will be able to accommodate some small scale growth which will be dependent upon local environmental and infrastructure capacity of the village concerned.”

4.16 For Hundon, on page 77, paragraph 7.34 states as of Spring 2009:

“Hundon has a population of 1061. The village has very few local employment opportunities and a limited bus service to Haverhill, but does have a primary school, community shop, two pubs and a community centre.”

4.17 Policy C13 relates to development in the rural area and that the scale in the “… Key Service Centres, Local Service Centres and Infill Villages, as defined in Policy CS1, will reflect the need to maintain the sustainability of local services for the communities they serve, the diversification of the economy and the provision of housing for local needs.”

4.18 The CS clearly acknowledged the importance of sustainability in transport and environmental terms. CS7 provided a transport hierarchy with the use of the car at the bottom of the list. It is difficult to see how development in Hundon could have met these criteria.

4.19 Local Service Centres are also expected to serve the wider rural area with services and facilities and it would appear that the only main criteria in this regard that relates to Hundon is the primary school due to the small scale of the shop and location. It is difficult to see how Hundon would have fulfilled this role as a local service centre in the last decade, let alone the current circumstances. The NPPF was introduced after the CS was adopted and now places sustainability at the forefront of the planning agenda with an economic, social and environmental role to be filled. The current circumstances have materially changed as outlined in paragraphs 3.4 to 3.24 above and this needs to be considered as part of the current settlement assessments.

St Edmundsbury Local Plan All Sites: Submitted and Officer Identified, June 2013

4.20 This document provides a useful summary of sites that have been submitted to the Council during a variety of consultation stages including the original Local Plan, Core Strategy (2010) and Vision 2031. In relation to Hundon, there are several sites that have been regularly put forward for development that include:

• Babel Green Farm, Lower Road

• Land at Mill Road

• Land at the junction with Valley Wash and Church Street

• Land between Vale Wash and Church Street

• Land off Valley Wash

• Land south of Lower Road and west of Mare Hill

• Land to the south east of the cricket pitch

4.21 In the site assessments, the Council considered that parts of the sites may be suitable for development in principle due to the fact that Hundon had been designated a local service centre in the Core Strategy. However, no sites were formally allocated in the Rural Vision 2031, as alternative sites were considered better suited.

Rural Vision 2031, adopted September 2014

4.22 Rural Vision 2031 provides the framework for growth in the rural area of St Edmundsbury. Paragraphs 34.1 to 34.6 refer to Hundon specifically and state there is reasonably good road access to the A143 for Bury St Edmunds and Haverhill although local roads and junctions within the village may require upgrading in order to cope with additional development. There is also reference to a bus service from Hundon to Haverhill that was considered satisfactory in

terms of travel to work but not for travel from work. For travel to Bury St Edmunds, the service was considered to be less than satisfactory.

4.23 Paragraph 34.5, identified a number of key issues identified by the Village that included:

• the need for a new/enhanced facility for early years’ educational provision in the Village

• Ensure the existing shop and pub in the Village continue to thrive and that affordable homes are provided in the Village for local people.

St Edmundsbury Borough Council, Local Plan Policies Map, February 2015

4.24 The following extract from the proposals map identifies the areas designated as recreational space and the conservation area within Hundon. This central area of open land forms an integral part of the Village and its overall character.

5. Evidence Base for the Emerging Local Plan

West Suffolk Strategic Housing and Economic Land Availability Assessment (SHELAA), February 2020

5.1 The SHELAA provides the evidence to support the local plan process and broadly considers sites with the potential for development. Sites have been assessed in relation to their suitability for development, is the site available and is development achievable. The analysis within the SHELAA results in a shortlist of ‘included’ sites with the remaining sites being ‘deferred’ for consideration that could be drawn on in future years and potentially allocated for specific uses. The SHELAA involved collating and reviewing 738 sites for residential uses with 223 sites included for allocation, 398 were deferred and 92 excluded. More sites were “included” than are required to meet West Suffolk’s housing need.

5.2 The SHELAA confirms that the assessments for sites was carried out in the following stages: • Initial suitability assessment: firstly, the sites that were not policy compliant were removed from the review process • Availability assessment: secondly the availability of sites was considered so that sites that would be unlikely to come forward for development were removed • Full suitability: thirdly, a thorough review of the suitability of sites was carried out to assess the extent to which the remaining sites conform with the local strategy and policies, and the extent to which constraints could be overcome • Achievability: lastly, all the sites that were considered to be both available and suitable were assessed to understand if there was a reasonable prospect of the development coming forward.

5.3 The SHEELA assessed various sites and appendices A to L includes a variety of background information. In relation to Hundon the following sites were classified as “included”: WS115 – Land at Mill Road WS116 – Land between Church Street and Lower Road WS117 – Land at Mill Lane WS200 – Land between Valley Wash and Church Street

5.4 Appendix E includes site proforma sheets for these sites and the following map (extract from Appendix L of the SHELAA) summarises the results and plots the “included sites” and the “deferred sites”.

5.5 Appendix I of the SHELAA includes the response from the Parish Council who expressed concern in relation to access, drainage and historical matters in relation to site WS115 and restrictive covenants in relation to WS116.

5.6 At page 12 of the SHELAA it states:

“The assessment of a site’s suitability also looked at instances where there was a potential loss of a community facility or service, such as a community building or open space, or land that serves the community such as education, leisure, or cultural land uses.”

5.7 Paragraph 4.16, “Physical limitations such as gradient, ground conditions, hazardous risks, pollution or contamination are being considered in a constraints study that will be sit alongside the SHELAA as evidence for the local plan. These factors were considered on a site by site basis in the SHELAA, and where these constraints were considered to be significant, sites were deferred.”

5.8 The three sites apart from WS117 represent significant areas of land and proposed development would not meet the assessment criteria within the SHELAA. WS116 forms an area of open land used by the community for allotments, a future orchard/wildlife area and general recreation. Any loss would be contrary to paragraphs 96 and 97 of the NPPF that seeks to retain such areas in the interest of health and well-being for the community and the details of referred to in the SHELAA at paragraph 5.6 above. WS116 also provides footways across green spaces (characteristic of the village) that connect parts of the village – Farmerie Road, Lower Road, Rogerons Close x2 and Church Street. WS117 provides similar footpath connections to Mill Lane, Windmill Rise x2, the village hall playing field and the football pitch.

5.9 In relation to physical constraints this appears to relate to the development of a site itself and would be assessed in a separate study. However, this fails to assess the impact on the character of a settlement. Settlement identity was a matter of importance in the Core Strategy and this should remain the case in the emerging Local Plan.

Sustainable Settlements Study July 2020

5.10 This Study forms part of the evidence base to inform the Plan. The purpose of the Study is to identify those settlements in the district which would be the most appropriate to deliver sustainable growth having regard to the following:

• “An audit of the current provision of services and infrastructure in settlements across West Suffolk.

• The grouping of settlements into categories reflecting their provision of services and common characteristics.

• A new proposed settlement hierarchy for West Suffolk, with the most sustainable locations for growth at the top, and the least sustainable at the bottom.”

5.11 The Study sets out the methodology the Council has used to assess settlements in West Suffolk in terms of services, facilities and accessibility. The report acknowledges that the last time services and facilities studies were formally undertaken was in 2008 to 2009 to inform the Core Strategy. In relation to the assessment of settlement sustainability, the following paragraphs are relevant:

Paragraph 3.6 states:

“The purpose of a settlement hierarchy is to identify the most sustainable locations for future development based on their provision of services and facilities and accessibility. What the settlement hierarchy does not do is identify the capacity and level of growth appropriate in each settlement. Identifying constraints and opportunities for growth is work that is being undertaken in other evidence base documents to support the local plan. The results from all these studies will be combined to identify suitable sites for development.”

Paragraph 3.14 “Once the settlements had been ranked the next step was to develop a hierarchy that reflects the quantity and quality of the services and facilities present, and other sustainability criteria, such as accessibility to a town or larger settlement with a good level of services. This final point reflects advice in paragraph 78 of the NPPF that states, “planning policies should identify the opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.”

5.12 Paragraph 3.14 clearly states that the hierarchy reflects the quantity and quality of the services and facilities present. However, in our opinion this has not occurred in relation to Hundon as the small part-time community shop and post office that are not commercially viable are considered on an equal basis to larger commercially viable shops in other settlements such as Wickhambrook and Clare.

5.13 The proposed hierarchy includes towns, key service centre, local service centres, Type A and B villages and the countryside. The definitions for the local service centre and Type A village are shown below:

5.14 Hundon is classified as a Local Service Centre within this assessment and paragraph 4.5 states:

“These settlements tend to have fewer dwellings than the category above and a smaller range of services but will have as a minimum a school and convenience shop.”

5.15 Appendix B of the Study includes the results of Parish Council Survey, September 2019 and Hundon Parish Council confirmed the settlement profile. The overall findings are produced in Appendix C - settlement matrix and rankings. The note attached to this Appendix confirms that each settlement has scored 1 even if there is more than one of that particular service available, (for example, if there are two or more shops the score will still be 1). Hundon scores 6 on the basis of primary school, early years, public house, convenience food shop, permanent post office and a play/recreational area although the settlement is noted as not being within 2km or 5km of the nearest town. The following extract includes the assessment:

5.16 The conclusions confirm that the Study forms part of the evidence base for the Plan and “… identifies those settlements in West Suffolk which are the most sustainable based on the level

of services and facilities and accessibility to higher order settlements.”, and the next steps will be to appraise the constraints and opportunities to development in the most sustainable settlements.

5.17 However, we object to the methodology of the assessment and believe that the evidence base is flawed. We do not believe that Hundon is a settlement that meets the criteria for being classified as local service centre and is not a sustainable village as defined within the NPPF or the definitions for the settlement hierarchy within the Plan for the following reasons:

• The National Planning Policy Framework (NPPF) includes key principles which are relevant when considering a new hierarchy for West Suffolk and this includes focusing new development in the most sustainable locations, with a range of services, shops, public transport and employment. Hundon is noted at not being within 5km of the nearest town and public transport services are considered to be extremely poor. The quality of services available within the Village in relation to the community shop and post office are restricted and not commercially viable. The Village is therefore not in a sustainable location or able to offer suitable services.

• There are no employment areas within Hundon and this therefore leads to the need to travel to work. There is was previously a bus service, number 344 that operated to Haverhill and this no longer operates. The only bus service is irregular or a dial up service for the hospital. The lack of employment means out commuting.

• The primary school has been extended in the past and there is no further scope to provide additional accommodation. The playing fields for the school are also separate and involve the children walking to other sites within the Village as referred to in section 3 of this Statement.

• There are limited footpaths within the village and even children with the Village are driven to school.

• The scoring system is incorrect. The Village does not contain a permanent post office. As stated above the Village shop was not financially self-sustaining for the 5 years prior to 2019 and the Post Mistress left in 2017 as the business was not viable and Post Office Limited intended to close the facility permanently. These facilities only operate on a part-time basis and the shop is staffed by volunteers and run by a committee of volunteers. Neither the shop nor the post office is commercially viable.

• We also query the population estimate of 1915 for the mid-year estimate 2018. The previous population estimate was 1061 in 2009 (CS page 77, paragraph 7.34). With an approximate dwelling stock of 338 dwellings, the new population figure implies on average 5.67 people per dwelling which does not seem accurate.

Sustainability Appraisal (SA) of the West Suffolk Local Plan Interim IIA Report October 2020

5.18 The SA is a mechanism for considering and communicating the likely effects of an emerging plan, and alternative options, with a view to minimising adverse effects and maximising the positives. The SA is a legal requirement and includes consideration of 'reasonable alternatives’. The Council is consulting on:

• The site options that have been identified as realistic contenders for allocation and referred to as ‘included’ sites within the Strategic Housing and Economic Availability Assessment (SHELAA), 2020; and

• A set of four options for distributing housing growth across the District.

5.19 Paragraph 8.2 refers to Methodology and 8.2.1 to Appendix II: GIS site options appraisal that presents the findings of a quantitative, GIS-based exercise to appraise the “included” sites within the SHELAA. The aim of the appraisal is to differentiate the performance of the 225 “included” SHELAA sites in respect of a range of criteria including proximity (e.g. distance to a GP surgery) / intersect (e.g. intersect with flood risk zone 2) etc. The second note on the appendix states that distance has been calculated in a straight line/as the crow flies but acknowledges it may be possible to calculate distances by road moving forward.

5.20 We object to the manner the assessment has been calculated in respect of distance, as the actual distance that is travelled could be materially different to the result of the assessment. In a rural area this can make a dramatic difference to the results and is a fundamental flaw of the SA and undermines the credibility of the entire SA.

5.21 The extract for the four sites within Hundon is shown below:

6. Response to the Plan Policies

6.1 We have reviewed the Plan and respond as follows:

Part 1 – developing a spatial strategy

Section 1 - Introduction

Paragraph 1.13

6.2 We agree with the Council’s statement regarding the importance of the main towns and transport links in the area. The linkages are important in relation to economic, social and environmental issues that impact growth and improve the outcome for people that live and work in the area. We agree with the main road linkages that are shown on the West Suffolk District Map.

Paragraphs 1.17 to 1.19

6.3 These paragraphs refer to the evidence base that includes the Sustainable Settlements Study, the SHELAA and the Environmental Constraints Study and the Sustainability Appraisal.

6.4 We object to the methodology and the assessments within these documents for the reasons identified in the previous sections 3, 4 and 5. 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, we therefore also object to how this has then been used to inform subsequent proposals in the Plan with regard to the settlement hierarchy and the sustainability assessment for sites referred to as “included” as part of the SHELAA. In relation to Hundon, we consider that the overall assessment is incorrect and not in compliance with the NPPF. The use of this evidence base for further decision making has therefore led to flawed assessments in relation to the settlement hierarchy and subsequent decisions within each individual settlement.

Part 1 Section 2

6.5 The Council at paragraph 2.4 to 2.5 refer to demographic change and that from 2018 to 2038 the number of residents over 65 is predicted to almost double with the proportion of the population aged over 65 to be one in three.

6.6 It is important that the increase in the age of residents is fully considered in relation to transport sustainability and to try and reduce the reliance on the private car. In addition, for more remote villages, the potential for isolation due to the lack of alternative means of sustainable transport needs to be fully considered in relation to overall well-being and access to services.

6.7 We agree with the Council’s Statement at Paragraph 2.8 to 2.9 that states:

• the area is predominantly rural in character

• the key roads for connectivity are the A14 linking east to west and the A11 to Cambridge and Norwich and A1307 to Cambridge and Stansted

• The rural nature of the District limits access to main roads

In order to support sustainable development, we believe growth should be promoted in the most sustainable areas. Hundon is not located near to any of the main towns or major roads for connectivity. Access is predominantly via unclassified roads and the Village is therefore considered to be remotely located.

Part 1 Section 3 – Vision for West Suffolk

6.8 We agree with the Council’s Statement at Paragraph 3.1 and 3.2 regarding the vision for the area and how this will be achieved with provision of housing in towns and rural areas in appropriate locations creating settlements that are safe and create healthy living with access to education, leisure, health and cultural facilities and open space that reduce the need to travel. We agree with the vision that new development should not adversely impact a settlement and that the character of the built and natural environment will be protected and enhanced.

Part 1 Section 4 - Strategic objectives

6.9 We support the strategic objectives listed SO1 to SO19 and in particular:

• SO5 Improving flood resilience by innovative methods

• SO6 Support a range of dwelling types and tenures that reflect communities’ needs

• SO7 Seek to focus homes in sustainable locations

• SO10 Sustain and support rural areas through safeguarding local centres and services

• SO11 Meet the housing needs of rural areas appropriate to the requirements of the individual settlements

• SO12 Conserve and enhance the character and quality, appearance of the natural, historic and distinct landscapes

• SO15 Ensure development maximises the potential to reduce its environmental impact, noise, air quality water efficiency etc

• SO18 Reduce the need for travel and make access to jobs, facilities and green space by public transport, walking and cycling safer and easier

• SO19 Recognise the difference in urban and rural areas, achieve an integrated sustainable travel network

Part 1, Section 5 - Strategic Issues for West Suffolk

6.10 Paragraphs 5.8 to 5.14 acknowledge the complexities of assessing housing need and that the minimum number of homes to be constructed over the 20-year plan period is 16,000.

6.11 We agree with the comments in paragraph 5.21 that refers to the rural character of the area with many settlements located away from the primary transport route network and with limited access to very high-speed broad band. This restricts home working and leads to a need to travel. It is therefore important that any settlement assessments have regard to actual travel distances and to what permanent facilities are available for residents in the area.

6.12 Paragraphs 5.23 to 5.25 refer to types of place and the settlement hierarchy. We support the broad principle of a settlement hierarchy. However, this needs to be defined in terms of the locational sustainability and the range of services and facilities that are offered in reality on a commercial and permanent basis and this should inform the overall level of sustainability. At present, this does not appear to have been carried out accurately and the findings are therefore mis-guided.

6.13 We agree with paragraph 5.24 that those settlements at the top, have a wide range of services with good transport links and those at the bottom, less facilities and more isolated in respect of transport links. However, it is essential that the individual assessments of the settlements are carried out accurately and that future development is proposed in areas that would support a reduction in the need to travel.

6.14 At paragraph 5.25, we agree that the first stage of the Plan is to assess the settlements and the results of this have been published by the Council in the Sustainable Settlements Study, July 2020. This Study considered the provision of services and facilities within settlements. We acknowledge the Council’s statement at paragraph 5.26 that the evidence is only a point in time and that services and facilities will change and should be kept under review.

6.15 However, we disagree with how this Study has been carried out and the resulting conclusions that informed the current suggestions in the Plan. As stated at paragraph 5.15 Hundon currently scores 6 but it does not have a full-time retail shop or post office. As stated at paragraph 3.21 the community village shop allows the post office some floor area but the shop itself is only approximately 25sqm in floor area. The shop is operated by volunteers and are

subsidised by the community. The maximum score should have been 5. The current evidence base for Hundon is not a complete picture of the facilities available in Hundon and should be updated accordingly.

6.16 Paragraph 5.27 of the Plan refers to the matrix attached at Appendix 2 of the Plan that is derived from the Sustainable Settlements Study. We object to the evidence contained within this and the classifications that have evolved as a result of the assessments. This is a result of the methodology used and the general assessment criteria as stated above.

6.17 Paragraph 5.29 refers to the previous local planning policies that only allowed allocations in the top three tiers of settlement hierarchy. The current Plan considers where rural allocations could be made and suggests a more flexible approach to development.

6.18 We support this broad principle, but it is essential that the sustainability criteria of a settlement are accurately assessed in order for this approach to be acceptable and the requirements of the NPPF complied with.

6.19 We support the principles at Paragraph 5.30 that refer to 6 potential settlement types within the hierarchy with the addition of Type A and Type B villages. We agree that this would provide a wider degree of flexibility for new homes in the rural area but it is essential that this approach is fully supported by accurate evidence within the Council’s supporting evidence base. The errors we have identified need to be corrected.

6.20 Paragraphs 5.32 to 5.37 refer to the descriptions of the settlement type. We support the general definition for the key service centre and the local service centre within paragraphs 5.33 and 5.34. However, the assessments of the facilities need to be robust, carried out in accordance with the Council’s own methodology in the Settlement Study 2020 and the transport sustainability needs to be based on actual measurements and not straight lines or as the crow flies. The current evidence base is not accurate, and this is essential in a rural area otherwise the entire approach to sustainable settlements is flawed.

6.21 In relation to the following three categories, Type A, Type B villages and the countryside, the key difference appears to be that only Type A villages would receive any form of allocation. The reasoning behind the two other categories is therefore questionable.

6.22 We believe the introduction of a Type A village in the rural area acknowledges the guidance within paragraph 83 of the NPPF that supports a prosperous rural economy with the retention of local services, community facilities including open space. Paragraph 84 of the NPPF acknowledges this can be difficult in rural areas but it is important to ensure that any development is sensitive to its surroundings and does not make an unacceptable impact on the local road network and exploits the opportunity to make a location more sustainable by improving pedestrian or cycle access and public transport. Limited sized allocations within a Type A village would provide clarity on sites to be developed but these decisions must be informed by detailed assessments of an area, the local community need to be met, including

transport connectivity and in particular the impact on the character of an area if allocations were supported at this stage in the Plan process. This does not appear to have taken place to date.

6.23 The draft settlement hierarchy has been established on the basis of the scoring within the Sustainability of Settlements assessment set out at Appendix 2. Hundon is classified as a Local Service Centre and we object to this for the reasons stated above. When the criteria are appropriately assessed the Village should fall within either a Type A or B village.

6.24 Paragraphs 5.39 to 5.49 refer to the “Broad options for distribution of growth” until 2040. The current strategy in the adopted local plans has 71% of growth in the main towns and 29% in the rural areas. Paragraph 5.40 refers to the wide range of factors that need to be considered to inform the way forward and one important element is the settlement strategy. The Council confirms that the SHELAA has been prepared to provide a “clear understanding of housing and land available in the district taking into account availability, suitability and achievability.”

6.25 However, we have identified concerns in relation to the evidence base contained within the SHEELA, the Sustainable Settlements Study and the SA that are referred to as key documents for the Plan. It would appear that the definitions for settlements such as the local service centre has not changed since the evidence base was produced for the Core Strategy that was adopted in 2008. The nature of facilities, how they are accessed over the last 10 years with the use of the internet has changed considerably and yet this does not seem to have been taken into account.

6.26 There are four options for growth identified at paragraphs 5.44 to 5.49 of the Plan. In accordance with sustainable development, options 1 to 3 appear to be the most appropriate where growth would be focused on towns, key service centres and local service centres. However, the text at paragraph 5.48 refers to “larger villages where constraints allow” but it is unclear as to the distinction between those villages within the local service centre and what would be classified as a “larger village”. If a larger village is considered to be the same as a Type A villages, we would object to this being included within the growth strategy. The terminology should be used in a consistent manner to avoid any confusion and reflect the potential appropriate growth for the settlement.

6.27 Option 3 implies that that there would be lower growth in villages, and this would limit the amount of local needs housing that could be delivered and affordability. We do not agree with this statement as the Council can consider an exceptions policy that would be based on a local housing needs survey that could include an element of market housing if a subsidy was required.

6.28 Option 4 suggests a dispersal option for growth but we do not believe that this would meet the strategic objectives of the Plan that in relation to achieving sustainable development and patterns of travel that reduce the need for the use of the private car.

Part 2, Section 1 local issues

Part 2, Section 2 Climate change

6.29 We support the principles outlined in paragraphs 2.1 to 2.3 regarding sustainable development.

Part 2 - 3. Housing

6.30 We agree with the Council’s aim to improve housing delivery and ensure that local community needs are met as set out in paragraph 3.1 to 3.4 with reference to housing of the right size, type, tenure, in the right place. At paragraph 3.4, there is reference to a study regarding housing needs across the Cambridgeshire housing sub region, due to be published in Autumn 2020, that would inform the Plan. We are not aware that this study has been published.

6.31 We support the comment at paragraph 3.8 that refers to the focus for new homes to be provided in the most sustainable locations.

6.32 We support the approach at paragraph 3.11 for rural exception sites to meet the needs for affordable housing. This should be genuinely available for the local community and immediate family and if not taken up, a cascade system should be introduced for the wider community. A proportion of market housing reflecting local need in terms of size and tenure could be considered to subsidize this coming forward if necessary.

6.33 We do not support the use of lower thresholds in the rural area as suggested in paragraph 3.13 as a blanket approach is not appropriate or likely to achieve the desired result. This could lead to fewer but larger dwellings being constructed to avoid affordable housing provision that would not necessarily reflect local need.

6.34 We support paragraph 3.16 that seeks to ensure housing is provided for different groups, but this needs to be informed by local need to support the overall strategic objectives of the Plan.

Part 2 - 5. Transport

6.35 We fully support the Council’s approach within paragraph 5.1 to promote a hierarchy of sustainable means of transport with walking, cycling and public transport (including taxis) at the top, followed by commercial vehicles with cars (fossil fuel-powered) at the bottom.

6.36 We agree with the comments at paragraph 5.5 that rural bus services or circular bus services are often poor or non-existent.

6.37 We agree with the comments at paragraph 5.7 and the SA scoping report that states:

• It will be important for future development to support reduced reliance on the private vehicle and improved access to sustainable modes of transport.

• Development should seek to maximise trends for active travel and improve opportunities for walking and cycling.

• There are opportunities to capitalise on existing transport routes and maximise sustainable access opportunities along key routes.

Part 2 - 6. Retail, leisure and wellbeing

6.38 Paragraph 6.6. states that local centres fulfil an important role as they provide a good range of retail, community facilities (including health, education and cultural) and leisure services that meet local needs as well as the immediately surrounding villages. This paragraph also confirms that a “Retail and Leisure Study was carried out in 2016 for the former Forest Heath and St Edmundsbury areas which included an audit of the town centres in the towns named above, as well as an audit of the local centres within Clare, Lakenheath and Red Lodge.” The Council has stated that this evidence base will be updated to determine the retail and other town centre needs over the plan period. This confirms that an update to date audit of all local service centres has not taken place. In respect of Hundon, the evidence in relation to the nature of retail facilities that are currently available in the Village as submitted within this Statement, should therefore inform the Local Plan.

6.39 Paragraphs 6.8 to 6.10 refer to access to open space, sport and recreation facilities to support wellbeing and education.

6.40 We agree with these statements but it is important that detailed and accurate assessments for the settlements take place to inform the decisions that are currently taking place for each of the settlements.

Part 2 -7. Rural Communities

6.41 We agree with the statement at paragraph 7.6 that refers to National research that has shown some rural areas fare less well than urban areas in terms of access to services, transport, affordable housing, and job opportunities. Whilst planning policy can help tackle these issues, it is essential that any form of development supports the principles of sustainable development in terms of locational impacts and built form.

Part 2 - 8. Natural and historic environment

6.42 Paragraph 8.2 refers to the distinct landscape character areas that have special landscape designations. We agree with the statement that “… for many residents the natural environment is best represented by the trees close to their homes, and the open spaces, parks and woodlands to which they have access.”

6.43 Paragraph 8.3 refers to the SA scoping report and identifies the following key sustainability issues: • Future development should seek to maximise opportunities for biodiversity net gain

• Development should seek to enhance green infrastructure networks that maximise the benefits of landscape features but minimise impacts on the most sensitive landscape areas.

• New development and settlement expansion should not impact upon the varied and rich landscape character and settlement identities.

6.44 We agree with the sustainability issues identified above but it is important these relate to the local level assessments for a settlement prior to any formal site allocations taking place. At present only statutory designations appear to have been used in the assessments and yet the Council acknowledge that for local people, it is their immediate area that is highly valued.

6.45 Paragraph 8.18 identifies the following key sustainability issues with regard to natural resources as follows:

• Fluvial flood risk affects a number of settlement areas across the district

• Surface water flood risk is more widespread across the district and affects most settlement areas. It will be important for new development to ensure that measures are taken to reduce surface water flood risk and manage the effects of surface water run-off

• The high-quality and 'best and most versatile' agricultural land is likely to face increasing pressures from development. Settlement expansion options in the south are likely to lead to the loss of higher-quality soils

6.46 Hundon is known for localised flooding and the southern boundary has been identified as within the flood zone but flood zone 3 extends to the south and east of the Village. In 2014 the Village was severely affected by flooding that led to the Village school being closed and overflowing of the sewer system. In addition, the roads to and from the Village can be prone to flooding. These matters need to be fully considered in relation to the sustainability of the Village overall and the limited options for access on the rural roads.

6.47 The Village is also surrounded by some of the most versatile land that is classified as Grade 1/ 2.

Historic environment

6.48 We agree with the statements within paragraph 8.21 that refer to the diverse historic environment that contributes significantly to the area and provides a distinctive character and cultural identity to the towns, villages and countryside.

6.49 We agree with the reference in paragraph 8.23 that acknowledges:

• The importance of designated and non-designated heritage assets in an area. This includes the setting of the designated assets such as listed buildings and conservation areas and associated views.

• These heritage assets should be protected, conserved and enhanced including their setting and significance. New development should ensure the assets are maintained and the historic character enhanced through the design, layout and setting of new development.

Part 3 – Settlements

Part 3 – 1. Introduction

6.50 We accept that at paragraph 1.2 the Council acknowledge that the maps included only show the most significant constraints. At paragraph 1.3, the text confirms “A map is included for each settlement showing the current red line development boundary and the sites submitted by landowners, developers or agents for residential, employment or mixed uses that have passed the initial analysis in the SHELAA and are identified as included sites and potentially suitable for development.”

6.51 We are concerned for the reasons stated above, that the sites within Hundon have been considered to have passed the initial tests and considered potentially suitable for development.

6.52 We acknowledge that at paragraph 1.5 of the Plan the Council state that “… no decisions have been made on whether the sites in this document will necessarily be taken forward to the next stage of the local plan as a preferred allocation to meet the district’s housing requirement. We are seeking your views at this stage to assist with making these decisions.”

6.53 We therefore lodge our strong objections to the manner Hundon has been assessed in the settlement hierarchy and the resulting “included” allocations with the Plan for the reasons stated in sections 3, 4 and 5 of this Statement.

6.54 We agree with the general principle referred to at paragraphs 1.8 and 1.9 that as a general guide the initial assessment for a site should be of 30 dwellings per hectare and this figure may change following further analysis.

Part 3 - 2. Towns

6.55 We agree with paragraphs 2.1 to 2.5 that identify the key towns in the area as Brandon, Bury St Edmunds, Haverhill, Mildenhall and Newmarket.

Part 3 -3. Key Service Centres

6.56 We agree with paragraph 3.1 to 3.7 that identify Barrow, Clare, Ixworth, Kedington, Lakenheath, Red Lodge and Stanton at key service centres on the basis of the range of shops, services and amenities.

Part 3-4. Local Service Centres

4.9 Hundon

6.57 This section refers to the detailed assessment of Hundon. Paragraph 4.9.1 identifies the Village site as 9km north-east of Haverhill and approximately 18 km south-east of Newmarket and considers the range of facilities in the Village to be reasonable as listed below: • a primary school • a pre-school • a Public House • a convenience food shop • a playground and artificial grass pitch.

6.58 The location of Hundon in relation to the main towns demonstrates the remoteness of the Village in relation to the key areas where the main services and facilities will be available. In Section 3 of this Statement, paragraphs 3.4 to 3.14 provide details on accessibility to and within the Village in relation to road/footpaths, paragraph 3.21 refers to the part time opening of the village shop, the fact that it is run by volunteers, the community post office is not permanent and neither is commercial viable and each is currently subsidised by the community.

6.59 We believe this evidence demonstrates that Hundon is not situated in a sustainable location and does not fulfil the essential criteria for the settlement to be considered as a local service centre in relation to the range of permanent and commercially viable facilities in the Village.

6.60 The following paragraph in the Plan identifies the constraints and opportunities within the Village. We agree with the main elements listed apart from the last bullet point that states:

“Hundon has reasonably good road access to the A143 for Bury St Edmunds and Haverhill. Local roads and junctions within the village may require upgrading in order to cope with additional development.”

6.61 There are two points to this statement. Firstly, we do not agree that there is “reasonably good access to the A143.” When the Village is considered in the wider context it is remotely located, only accessed by unclassified roads which are single carriageway width in some locations as stated in paragraphs 3.7 to 3.14 of this Statement. If the Council wishes to affirm its statement it should inspect the roads.

6.62 Secondly, the general statement that local roads and junctions within the Village may require upgrading is a significant matter and cannot be considered in isolation. There should be a

detailed assessment of the implication of any transport improvements that may be required to or from and within the Village prior to any allocations being made. This would ensure the character of the Village is not adversely affected. In addition, any growth should be supported by the necessary infrastructure at the start to avoid development taking place with no improvements to the detriment of existing residents.

6.63 Paragraph 4.9.2 refers to settlement status and that in the current adopted Local Plan Hundon was classified as a local service centre and it appears that this is the main reason for the current designation. It is pertinent that at paragraph 4.9.3 that the St Edmundsbury area Rural Vision 2031 (2014) did not allocate any sites for development in the Village.

6.64 We support the comments at paragraph 4.9.4 that state the level of development will be influenced by the distribution across the district and the existing environmental and physical constraints that would affect the capacity for growth in the settlement.

6.65 Paragraph 4.9.5 refers to sites that have been submitted for potential inclusion and that they “passed the initial tests of being suitable, available and achievable, and so are more likely to be sites that could be suitable for allocation in the local plan.” We object to this on the basis of the information within this Statement that challenges the background evidence that has informed the Plan and that the current assessments are based on desk top assessment and information from a developer’s perspective.

6.66 The statement within paragraph 4.9.6 is of critical importance that confirms the included sites have not been selected as preferred sites for development. The representations within this Statement should be considered in respect of the settlement hierarchy and the facilities within the Village prior to any housing allocations being made.

6.67 Paragraph 4.9.7 refers to the settlement constraints that are identified on the map as shown in the following extract:

6.68 We object to the key for this map that distinguishes between “significant constraints” and “other constraints” and how these have been separated/defined with road/footpath constraints and access not included.

6.69 We believe designated heritage assets are significant constraints and yet the key to the map suggests these are less important than a Flood Zone 2 designation. This suggests that heritage assets are considered a lower level of importance despite the references within the NPPF as stated at paragraph 184 that these assets are irreplaceable resource and add to the quality of life for future generations. Paragraph 185 of the NPPF states that Plans should set out a positive strategy for conservation and enjoyment of the historic environment. The current Plan does not appear to acknowledge this or the importance the historic environment to an area as a whole in terms of social and cultural benefits.

Heritage Assets

6.70 The two main designated heritage assets fall into the conservation area and the listed buildings within the Village and immediate area. The map does not identify the constraints listed within paragraph 4.9.1 that refers to the archaeological sites close to the Village and around the Village that are also heritage assets.

6.71 Paragraph 185 and 194 of the NPPF state that new development should make a positive contribution to the local character and distinctiveness and that that any harm to or the loss of an asset including setting should require clear and convincing justification. It is therefore essential that prior to any allocations being considered, such impacts are considered. In

relation to Hundon there are a variety of listed buildings and the conservation that are designated assets along with other buildings of historic interest. Whilst a conservation area appraisal may not exist for the area, it is clear that the open space within the centre of the Village clearly forms part of the character and represents an important part of the Village.

Topography

6.72 The constraints map does not provide any information on the topography of the area. This is a major concern as the Village is located on the valley side extending up the hill in a northerly direction. The next map “Hundon settlement map showing SHELAA included sites”, includes height contours that demonstrate the highest points are to the north west of the Village ranging from 70m in the valley bottom to 100/110m. On the opposite side of the valley, to the south of Chimney Street, the valley is more open and climbs to 105m and is far less developed. To the north west of the Village, towards Steeplechase, the land ranges from 85 to 95m as shown on the map and is open in character.

6.73 The land to the north west of the Village therefore forms some of the highest land within the area and is visible from the surrounding area. This higher land forms part of the included allocation for WS115. It is clear that the Village topography is an important constraint that is not referred to in the assessment for the Plan. We therefore object to the omission of this information that is considered to have a significant impact on any development proposals in the Village.

Transport Sustainability

6.74 The constraints map does not include any information in relation to the transport accessibility of the Village or other sustainable forms of transport within the Village. These are of significant importance as they affect the overall sustainable approach to a settlement and impact the character of an area. The NPPF and the Council’s approach to sustainable development has emphasised the importance of prioritising walking and cycling to ensure less dependence on the private car.

6.75 As stated at paragraphs 3.8 to 3.13 of this Statement, access to and from the Village is via unclassified roads, some of which are single carriageway with passing areas and others restricted by single width bridges. The reference to “reasonably good road access to the A143” in the Constraints and Opportunities section is therefore incorrect in particular with respect of access to Haverhill and Cambridge.

6.76 The last bullet point within the Constraints and Opportunities section states that “Local roads and junctions within the village may require upgrading in order to cope with additional development.” This fails to consider the accessibility to the Village in the first instance or the exiting character of the Village. The photographs attached at Appendix 1 clearly demonstrate how the nature of the roads and footpaths add to the character of the area. In our opinion, it is clear that there are limited opportunities to improve walking and cycling within the Village without significantly affecting not only the designated heritage assets within the Village but destroying the wider character of the area. Any new development would be expected to meet

modern standards in relation to road and footpath widths that would adversely impact the overall character of the Village.

6.77 There are also a variety of listed buildings in the Village. Whilst the majority follow the line of North Streets there is an important cluster of four buildings along Valley Wash at the north western part of the Village at Mary Lane. There are further listed buildings at Bears Farm on the northern party of Valley Wash. These are important designated heritage assets that need to be formally considered and their setting. At present, the listed buildings outside of the conservation area are noticeable due to the lack of built form around them creating a rural and open setting.

6.78 We therefore believe the heritage assets and transport constraints have not been given due weight in this document or as part of the constraint’s analysis. Hundon is an attractive Village and yet there is no mention of this or development needing to respect the landscape as stated for other villages such as Kedington or Wickhambrook in the Plan. We therefore object to this part of the Plan.

6.79 Paragraph 4.9.8 seeks view on the sites that have been included with the Council’s SHELAA as shown in the following extract:

6.80 In the first instance, the matrix referred to as Appendix 2 in the Plan confirms that the Village currently has a housing stock of 338 dwellings. There are four sites within the SHELAA that are recommended for inclusion with each varying from 16 to 254 dwellings. Even the smallest

proposed allocation of 16 dwelling would represent a significant number of dwellings for a Village of this size. The larger allocations, or the potential for all the site to come forward, would dramatically change the Village and run contrary to the Council’s vision for the area to protect the rural area and its own Strategic Objectives. In addition, there is only limited infrastructure available in the Village and in relation to the school site, this is highly constrained and unlikely to be extended.

6.81 In respect of the four individual sites, we have the following comments:

WS200 - Land between Valley Wash and Church Street, (also known as field adjacent to Mizon Close)

6.82 The site area is stated as 3.65 ha with the capacity of 66 dwellings at a density of 30 dwellings per ha. This would lead to a 20 % increase in the overall housing stock in the Village. The southern boundary of the site runs along the edge of the floodplain and the site slopes up to Church Street. The exact position of the floodplain is unlikely to be known until exact levels are taken that could render the lower part of the site undevelopable.

6.83 The site forms an open area of land that if developed could provide a continuous form of development. This western approach to the Village contains a number of listed buildings, the cluster of listed buildings at Mary Lane, the junction of Valley Wash and Church Street and Bears Farm, Valley Wash. The area is noted for the dispersal of dwellings and the heritage assets. Development on this site would form a continuous frontage along Valley Wash and whilst on the opposite side of the road, would adversely affect the setting of the listed buildings by the very built form and destruction of openness of the area.

6.84 Development on the northern part of the site would be highly prominent in the landscape as is evident from the recent development on Church Street that has already taken place as shown in the following photograph:

Recent two storey developm ent

6.85 Photographs 3, 4, 6, 7, 8, 9, 10, 11 and 24 are attached at Appendix 1 to this Statement and show the character of this part of the Village. Development on the northern part of the site would be highly prominent in the landscape in particular when viewed from the opposite side of the valley along Buntry Lane as shown in photograph 1 attached to Appendix 1.

6.86 The “Y” shaped access that approaches the Village from the west, as shown in photograph 7, reinforces the rural nature of the Village. There are no footpaths on either side of Valley Wash or Church Street. The latter is single track (for part of its length adjacent to the site) and has high banks and hedging as shown in photographs 8 and 9 attached at Appendix 1. The siting of an access to accommodate development would have a significant impact on the character and appearance of the Village.

WS115 - Land at Mill Road

6.87 This site would form 14.11 ha of land with a capacity of up to 254 dwellings. This would lead to a 75 % increase in the overall housing stock in the Village which would have a significant adverse impact on the character and nature of the Village as a whole.

6.88 The majority of the site is situated on the highest and most visible part of the landscape in the area as shown by the following photographs 8, 9, 13, 14, 15, and 16 attached at Appendix 1. The contour lines on the settlement map clearly demonstrate this with the land rising to 110m in the north west corner of the site. Any development would be clearly visible from the surrounding area, Steeplechase to the northwest, Buntry Lane on the opposite side of the valley to the south and the entrance to the Village from along Valley Wash and the public footpaths shown on the map.

6.89 In addition, the roads surrounding the site are of a rural character with no footpaths as shown in photographs 13, 17 and 18 that are attached to Appendix 1. Development of a modern standard with road widths and associated footpaths would change the overall character of the area.

WS116 - Land between Church Street and Lower Road

6.90 This site would form 2.75 ha of land with a capacity for 83 dwellings. This would lead to a 25 % increase in the overall housing stock in the Village which would have a significant adverse impact on the character and nature of the Village as a whole.

6.91 The land forms an important part of the conservation area and the green space within the Village that contributes to recreational use. The gap in the frontage along Lower Road is an important open area with a footpath running along the western boundary. We object to the description of the land being classified as vacant land as it forms part of an important area to the Village. Any development in this area would lead to the loss of open space that would be contrary to the Council’s vision for the area and the guidance within the NPPF.

6.92 Vehicle and pedestrian access to modern standards would also be difficult to achieve without adversely impacting the character of the area.

WS117 - Land at Mill Lane

6.93 This site would form 0.53 ha of land with a capacity for 16 dwellings. This would lead to a 5% % increase in the overall housing stock in the Village. The land falls within the main Village boundary and development would lead to the loss of open space and the green connecting paths within the Village.

7. Conclusions

7.1 Whilst we support the principle of a settlement hierarchy, we believe there are fundamental errors in how the evidence base has been produced that has led to a flawed assessment and allocations of settlements within the suggested hierarchy. This evidence needs to be updated and the assessments for the “included” sites within the SHELAA re-evaluated in the light of the information contained within this Statement. 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 not, therefore, lead to sustainable development.

7.2 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.

7.3 We believe the amendments requested in these representations are essential to ensure the Plan will be found sound on the basis the four tests as set out in the NPPF have been met that require the Plan to be positively prepared, justified, effective and consistent with National Policy and that the Council’s own strategic objectives are met.

Appendix 1

APPENIDX 1 - VILLAGE PHOTOGRAPHS

1. Identification of location for site photographs

Extract from the Council’s Regulation 18 Document

Photograph 1 - Views south west across the Valley from the new development at Church Street

Photograph 2 - Mill Road and the junction with Windmill Rise looking north east. Site WS115 to the left-hand side of the photo

Photograph 3 - Views looking north westerly from Church Street across WS200

Photograph 4 - Views looking northwest along Church Street towards Valley Wash

Photograph 5- Views looking north easterly from land at Bears Farm, Valley Wash to show the ridgeline of dwellings along Mill Road

Photograph 6 - Views from land at Bears Farm, Valley Wash looking south east up to the new development on Church Street

Photograph 7 - Junction of Valley Wash with Church Street – no pavements narrow road

Photograph 8 - Church Street – views down towards Valley Wash to the north west

Photograph 9 - Church Street – views south easterly up Church Street

Photograph 10 - Land the subject of WS200, looking south west across the site towards Valley Wash

Photograph 11 - View of the new development on Church Street – two storeys dwelling prominent in the landscape

Photograph 12 - View looking north along Mill Road

Photograph 13 - Northern part of Mill Road looking south with the land for WS115 to the right-hand side

Photograph 14 - Northern part of Mill Road looking south west across WS115

Photograph 15 - Northern part of Mill Road looking south west across WS115

Photograph 16 - Northern part of Mill Road looking west

Photograph 17 - Hall Road heading north out of the village

Photograph 18 - Hall Road to the north of the Village

Photograph 19 - North Street

Photograph 20 - Church Street with the school on the right-hand side

Photograph 21 - School playground

Photograph 22 - Village allotment and land forming part of WS116

Photograph 23 - Lower Road

Photograph 24 - View from Valley Wash looking north to Church Street – ridgeline of new development visible

Photograph 25 - View from Buntry Lane on the opposite side of the Valley through to Church Street and Mill Road

Photograph 26 - Views looking north west across WS115

Photograph 27 - View looking north along North Street towards the School