Non-Technical Summary

St Edmundsbury Borough Council

Core Strategy Submission Document

Sustainability Appraisal Report

Overview of Process and Purpose of Sustainability Appraisal St Edmundsbury Borough Council is preparing a Local Development Framework (LDF) for the Borough, comprising a number of Development Plan Documents (DPDs) that set out the policies and proposals for the development and use of land. As part of the LDF, the Core Strategy DPD will set out the vision, objectives and key policies for the future development of St Edmundsbury. It will supersede the Replacement St Edmundsbury Borough Local Plan. This SA Report has been prepared to fulfil the requirements for SA arising from the Planning and Compulsory Purchase Act 2004 and the requirements for Strategic Environmental Assessment (SEA) arising from the SEA Directive. The purpose of SA is to promote sustainable development through better integration of sustainability (economic, social and environmental) considerations in the preparation and adoption of plans. The SEA Directive requires that certain plans and programmes undergo an environmental assessment, due to the likelihood that they will have significant environmental effects once implemented. This Sustainability Appraisal Report (SA Report) accompanies the Core Strategy Submission Document. It builds on the earlier SA work undertaken by the Council for the SA Scoping Report, the initial SA of the Core Strategy Issues and Options document (March 2008) and the SA Report of the Core Strategy Preferred Options and Strategic Sites document (November 2008). The Process Followed Throughout the report the term SA is used to describe the combined process SA/SEA, which involved four main stages. Stage 1 • Identifying other plans, programmes and sustainability objectives which inform and influence the development of the Core Strategy DPD; • Establishing an understanding of the social, environmental and economic conditions of St Edmundsbury (the baseline); • Identifying key sustainability issues in the borough; • Outlining SA objectives against which to later evaluate the Core Strategy DPD policies; • Gathering consultation feedback on the SA’s proposed breadth of coverage and level of detail. Stage 2 • An assessment was carried out on a series of spatial strategic options and reported in the initial SA of Core Strategy Issues and Options document (March 2008). Stage 3 • An assessment was carried out on a set of draft policies and reported in the SA Report of the Core Strategy Preferred Options and Strategic Sites document (November 2008). Stage 4 • An assessment was carried out of the strategic sites in the SA Report of the Core Strategy Preferred Options and Strategic Sites document (November 2008) and reported in this Sustainability Appraisal Report. • Taking into account the revised policy wording resulting from the Preferred Options consultation, a further iteration of assessment of policies contained in the Core Strategy Submission document has been undertaken and reported in this Sustainability Appraisal Report. Appropriate Assessment There are three European designations relating to nature conservation within the district: Breckland Special Protection Areas, Brecklands Special Areas of Conservation and Waveney and Little Ouse Valley Fens Special Areas of Conservation. There is a requirement for any policies, plans or projects with potential to affect European sites to undergo Appropriate Assessment under the European Habitats Directive. Although the requirement and process are separate from that for SA, the two processes have been run in parallel for the Core Strategy DPD. Appropriate Assessment screening of the Core Strategy DPD concluded that there will be no likely significant effects due to the implementation of the Core Strategy policies. These results are reflected in the SA Report. Contents and Main Objectives of the Core Strategy The St Edmundsbury Core Strategy DPD sets out the Council’s vision for future growth, objectives and strategic policy framework that will manage and guide development in the borough over the next twenty years and beyond. The St Edmundsbury vision includes a number of highlights, including ensuring that the distinctive local character, unique local heritage and environmental and cultural assets are retained and enhanced and employment growth and development will produce a prosperous sustainable economy. The Core Strategy objectives are as follows: A To deliver housing in a sustainable way, including specialist and affordable housing to meet the needs of the whole community, by providing an adequate and continuous supply of land for housing whilst seeking to maximise the amount of Previously Developed Land used. B To secure economic vitality and growth by delivering an adequate and continuous supply of land for employment to meet the needs and demands of different sectors of the economy and reduce the need for out-commuting. C To sustain and enhance rural communities by providing, where infrastructure and environmental capacity exists, new housing to grow settlements and safeguard existing rural services while, maintaining and, where possible, improving the rural environment. D To maintain and develop leisure, cultural, educational and community facilities, including access to green space, commensurate to the level of housing and employment growth to meet the needs of residents and visitors. E To provide opportunities for people to shop for all their needs by sustainable means in thriving and economically viable town, local and district centres. F To enable people and goods to move around efficiently and safely to the benefit of the economy and community, with minimum harm to the environment by seeking to reduce car dependency and encouraging more sustainable forms of transport. G To maintain and protect built and natural environment and ensure that new development protects and enhances assets of local design, cultural, historic and conservation importance, and character of the landscape. H To maintain, protect and enhance the biodiversity, geodiversity and natural environment and seek opportunities to increase the provision of green open space and access to the countryside. I To ensure that new development only occurs where there is adequate capacity in existing services, facilities and infrastructure or where this capacity can reasonably be provided. J To ensure new development addresses and tackles environmental and sustainability issues including climate change adaptation, carbon emissions reduction, renewable energy provision, recycling, waste reduction and water efficiency. The Core Strategy contains a set of fifteen policies developed to implement the vision and objectives, as follows: Policy CS1 St Edmundsbury Spatial Strategy Policy CS2 Sustainable Development Policy CS3 Design and Local Distinctiveness Policy CS4 Settlement Hierarchy and Identity Policy CS5 Affordable Housing Policy CS6 Gypsy and Traveller Accommodation Policy CS7 Sustainable Transport Policy CS8 Strategic Transport Improvements Policy CS9 Employment and the Local Economy Policy CS10 Retail, Leisure and Cultural Provision Policy CS11 Bury St Edmunds Strategic Growth Policy CS12 Haverhill Strategic Growth Policy CS13 Rural Areas Policy CS14 Sequential approach to sites development Policy CS15 Community infrastructure capacity and tariffs Sustainability Baseline and Key Issues The borough of St Edmundsbury is located in Western Suffolk. It has borders with Norfolk to the north, Mid Suffolk and Babergh Districts to the east, Essex to the south and Cambridgeshire and Forest Heath District to the west. While administratively St Edmundsbury’s links are with Suffolk County Council, increasingly the borough is playing a stronger role in the sub-region of Cambridge because of their common economic and social needs. The borough has two main towns - Bury St Edmunds to the north and Haverhill to the south. St Edmundsbury is scattered with a large number of villages and small settlements and retains a predominantly rural character despite its industrial nature. The main sustainability issues identified for St Edmundsbury, which the Core Strategy must address, are briefly summarised below. Significant Historic and Future Population Growth The population has grown significantly over the past two decades (by 16.9%). This growth is expected to continue, particularly with the identification of Bury St Edmunds as a key centre for development and change in the East of England Plan Historic growth in the number of older people in the Borough (+14.7% over 2002-07) has been significantly higher than that experienced in the East of England as a whole (+8.8% over 2002-07). However, the age profile broadly reflects that of the East of England. 43% of the borough’s population live in rural areas. This is an unusually high proportion (23% of England’s population live in rural areas), and reflects the largely rural nature of the borough. Relatively Low Education and Qualification Attainment The percentage of the population with no qualifications is more than double the figures for the East of England and England. Localised Deprivation Deprivation is increasing, with the borough’s IMD rank having decreased from 267 in 2004 to 260 in 2007. However, deprivation is not evenly located throughout the borough. The IMD rankings show that LSOAs in Haverhill are more consistently deprived; suggesting that deprivation in Haverhill is more widespread rather than just concentrated in small pockets. Furthermore, levels of deprivation in the rural areas have increased both relative to elsewhere in England and in absolute scores. Insufficient Amount of Housing, including Affordable Housing and High Level of Unfit Dwellings Although the number of houses built ie.housing completions in 2006/07 was above the H1 policy target included in the East of England Plan, in previous years the number of completions has not reached the target level. The uptake of housing benefits has steadily increased since 2003, suggesting that there is insufficient affordable housing available within St Edmundsbury. Furthermore, the housing affordability ratio of the borough has increased steadily since 2003, indicating that there are significant housing affordability problems, particularly as a result of year-on-year increases in house prices. Lack of Accommodation Provision for Gypsies and Travellers St Edmundsbury had 2 gypsy and traveller pitches in 2006. The borough is not on track to reach its East of England Policy H4 target which requires 17 pitches by 2011. Earnings below Regional Figures Whilst average earnings have increased over recent years, they are still below figures for the East of England and England. Furthermore, median wage figures indicate that there is an above average number of low paid jobs in the borough. Pressure on Rich Biodiversity St Edmundsbury contains a number of sites designated for their internationally important ecology. These are: • Breckland SPA; • Breckland SAC; and • Waveney & Little Ouse Valley Fens SAC. The borough also contains a number of SSSIs, National Nature Reserves, County Wildlife Sites, Local Nature Reserves and Country Parks. Although these sites are considered to be of significant ecological value, their integrity, and the habitats and species that they support are under pressure from the high level of development required in order to meet growth targets set within the East of England Plan. The majority of the ecological SSSIs in the borough are partly in an unfavourable or mixed condition with 2 of the Borough’s 23 SSSIs wholly in an unfavourable and deteriorating condition. There are a large number of designated BAP habitats and species in Suffolk, many of which will be present in St Edmundsbury. It is important that any permitted development does not detrimentally affect these habitats and species. Pressure on Landscape The borough contains 14 landscape types, which are distinct and individually important to the character of the Borough. Development pressures (e.g. suburbanisation, transport and industrial developments, agricultural rationalisation and tourism related development) as a result of past and projected future development within the borough have placed, and are likely to continue to place significant pressure on the landscape of St Edmundsbury. Rich Archaeology and Cultural Heritage St Edmundsbury contains over 3,000 listed buildings and a number of historic parks and gardens, scheduled monuments and conservation areas. It is vital that these valuable assets continue to be protected. Pressure on Water Resources The level of development required by the East of England Plan, and the population growth that this is likely to cause, will dramatically increase the pressure on existing water resources. These resources are already strained given that the amount of rainfall received in the East of England is significantly less than for other parts of the UK, and is likely to decrease as a result of projected climate change. Potential for Flood Risk Whilst a very low proportion of property is at risk of flooding, Bury St Edmunds, Haverhill and many of the borough’s villages are located in river valleys. Historic evidence has demonstrated that extreme weather conditions have the potential to cause damage through flooding in these areas. Need to Adapt to a Changing Climate The main expected climate changes in the East of England are increases in temperatures (hotter summers, milder winters); increases in seasonality (e.g. dryer summers, wetter winters); and increases in the intensity and frequency of storm events (e.g. extreme rainfall event leading to fluvial /groundwater flooding). St Edmundsbury needs to adapt to these unavoidable consequences of climate change. High Energy Consumption Average annual electricity consumption figures show a decrease in domestic electricity consumption but an increase in industrial energy consumption since 2003. Figures also indicate that average domestic and industrial energy consumption in the borough is above both that for the East of England and Great Britain. There are no commercial renewable energy facilities within the borough.

High CO2 Emissions per Capita

Per capita domestic CO2 emissions (2.43 tonnes) are slightly lower than regional (2.48 tonnes) and national figures (2.54 tonnes). However, total CO2 emissions per capita in 2006 (13.44 tonnes) increased from 2005 level (12.10 tonnes) and are higher than regional and national figures, as a result of the industrial nature of the borough. Recent increases in total emissions are likely to be as a result of industrial growth in Haverhill. Need to Preserve Valuable Land and Soil The majority of farmland in the borough is either Grade 2 or 3 which are generally considered to be the best and most versatile types of agricultural land. The high level of growth required by the East of England Plan is likely to result in the loss of some of this valuable land. Low Completions on Previously Developed Land Whilst St Edmundsbury regularly meets its target of 40% of completions on Previously Developed Land, this target is significantly lower than that for the East of England as a whole. The proportion of completions on Previously Developed Land is likely to decrease in future if St Edmundsbury is to achieve the high level of growth required by the East of England Plan. High traffic volume and reliance on private car Traffic volumes within St Edmundsbury are high, with the proportion of journeys to work in the borough being undertaken by car being significantly higher in 2001 than that for the East of England and England. The proportion of journeys to work undertaken by public transport in the borough is significantly lower than that for the East of England and England. Available data suggests that the distance that residents commute to work is significantly higher than the national mean. Changing Employment Sectors The proportion of the population employed in agriculture and manufacturing is declining. There are major differences in prominent employment sectors within the borough. Haverhill is industrial in nature with more than three times the proportion of manufacturing employment compared to Bury St Edmunds which is dominated by public sector employment, accounting for almost one third of total employment. Sustainability Appraisal Framework The Sustainability Appraisal Framework is a key tool in completing the SA as it allows the assessment of the effects arising from the Core Strategy proposals in key areas in a systematic way. The St Edmundsbury Core Strategy SA Framework is based on the SEA Framework prepared by the Suffolk Sustainability Appraisal Group for all Suffolk authorities but it has been adapted to reflect the specific characteristics of St Edmundsbury. The adapted Core Strategy SA objectives are shown below: Social 1. To improve the health of the population overall and reduce health inequalities 2. To maintain and improve levels of education and skills in the population overall 3. To reduce crime and anti-social activity 4. To reduce poverty and social exclusion 5. To improve access to key services for all sectors of the population 6. To offer everybody the opportunity for rewarding and satisfying employment 7. To meet the housing requirements of the whole community 8. To improve the quality of where people live and to encourage community participation Environmental 9. To improve water and air quality 10. To conserve soil resources and quality 11. To use water and mineral resources efficiently, and re-use and recycle where possible 12. To reduce waste 13. To reduce the effects of traffic on the environment 14. To reduce contributions to climate change 15. To reduce vulnerability to climatic events 16. To conserve and enhance biodiversity and geodiversity 17. To conserve and where appropriate enhance areas of historical and archaeological importance 18. To conserve and enhance the quality and local distinctiveness of landscapes and townscapes Economic 19. To achieve sustainable levels of prosperity and economic growth throughout the plan area 20. To revitalise town centres 21. To encourage efficient patterns of movement in support of economic growth 22. To encourage and accommodate both indigenous and inward investment Compatibility between Core Strategy and SA Objectives Initial work on the Core Strategy DPD identified a set of objectives to achieve the overall vision for the area. Each of these objectives was evaluated in terms of its compatibility with each of the SA objectives above. The results of the compatibility assessment indicated that the overall compatibility between the initial set of the Core Strategy Objectives and the SA Objectives was relatively good. This was particularly true of the compatibility with the social and economic dimensions of sustainability. In contrast, there was a considerable amount of uncertainty with regards to the environmental objectives, which required addressing through the translation of the Core Strategy objectives into future policies which take fully into account environmental considerations. Plan Issues and Options Five main strategic options for the spatial strategy for the borough were set out in Part 5 of the Core Strategy Issues and Options document published in March 2008. These were: • Option 1: Business as usual – this maintains the hierarchy in the Replacement St Edmundsbury Borough Local Plan 2016 (adopted in 2006), to determine the scale of new development appropriate for each location. • Option 2: Urban Growth – under this option new development would be directed towards Bury St Edmunds and Haverhill and a slowing down in the recent rates of development in the rural settlements. • Option 3: Regeneration of Haverhill – the majority of new development would be split equally between Bury St Edmunds and Haverhill, and development in the rural areas would be much lower than recently experienced. • Option 4: Rural Development - under this option significantly more development would take place in the settlements outside Bury St Edmunds and Haverhill than at present. Development rates in Haverhill would reduce compared with the previous ten years, but growth rates in Bury St Edmunds would continue at the rate achieved over the same period, in order to reflect the strategy of the Draft East of England Plan. • Option 5: New Settlement – this option proposes a new settlement of at least 3,000 homes plus a commensurate level of jobs, services and community facilities to be constructed in the latter years of the LDF period. Some growth in the existing towns and villages would be required in the interim period to ensure that housing and the economy remain buoyant, but there would be a lower rate of development in those settlements in parallel with the construction of a new settlement. The assessment revealed varying degrees of sustainability across the options. Key general findings which emerged from the assessment were: • The assessment results show that Options 2 and 3 perform well in the sustainability terms with no significant differences between them, as both options direct further growth to Bury St Edmunds and Haverhill and slow down and restrict development in the rural areas. The main benefits that these two options are expected to deliver include better opportunities for development on previously developed land, the provision of good cycle and pedestrian links to employment, services and facilities, the provision of education and skills training, the efficient use of energy, etc. • Option 1 is a business as usual scenario, which supports a more disperse growth by directing development to Bury St Edmunds and also allowing development in the rural service centres. This option is also expected to deliver positive effects against the SA objectives overall, although of lower level than Options 2 and 3. • Option 5 supporting the development of new settlement was also identified as being likely to deliver beneficial effects overall. The main advantages associated with this option include the use of more sustainable modes of transport, accessibility to key services and ability to provide homes for all, and also by providing opportunities to adopt sustainable development measures throughout the development and from the outset. However, disadvantages of this option are loss of significant amount of greenfield land and potentially diverting from opportunities in the existing settlements. • Option 4, promoting growth in the countryside scores the lowest against the SA objectives due to such effects as restricting access to the key services and facilities with little or no scope for employment, exacerbating the reliance on the private car, loss of green space and natural habitats and inability accommodate the required level of growth and meet the housing needs of the whole community. Positive effects of helping avoid the demise of rural facilities are likely to be outweighed by the listed negative effects. Although the Council ultimately held responsibility for selecting the preferred option for each strategic policy, the SA assessment differentiated the various policy options for each objective and helped to identify the most sustainable options. Development of Strategic Sites Strategic sites identified in the Core Strategy Preferred Options and Strategic Sites document (November 2008) have been subject to an assessment in order to determine their performance in sustainability terms, with reference to social, environmental and economic factors. These sites are located around Bury St Edmunds and Haverhill. Assessment of Plan Policies Drawn from the options previously identified as being the most sustainable, the Core Strategy policies seek to implement the Core Strategy vision and objectives. As already indicated, there are 15 policies in total which have been assessed in order to predict and evaluate the nature (positive, negative or neutral), scale (significant or non-significant) and timeframe (short-term, medium-term or long-term) of the social, environmental and economic effects. The assessment indicates that the Core Strategy document performs with mixed results against the SA framework, but on the whole achieves a balance of positive significant effects. The Core Policies offer potentially significant positive effects on all SA social and economic objectives, therefore addressing suitably the issues associated with health, education, crime and fear of crime, poverty and social exclusion, access to key services, employment, housing requirements, revitalisation of town centres, economic growth and investment. However, a range of both significant positive and negative effects have also identified with regard to the environmental SA objectives. The predicted negative effects are associated with Policies aiming to accommodate the provision of approximately 10,000 new homes and required infrastructure in St Edmundsbury, including Greenfield land take, which will have negative effects on the environment. Specifically, the assessment has identified negative effects of varying scale and significance on water and air quality, soils resources and quality, mineral resources, waste, effects of traffic on the environment, climate change, vulnerability to climatic events, biodiversity, heritage and local landscape and townscape. Recommendations in terms of broadening aspects covered by particular policies or strengthening their requirements have been provided to mitigate potential negative effects and enhance positive ones. Mitigation Although the Core Strategy will have a positive significant effect in sustainability terms overall, certain policies have the potential for negative significant effects relating primarily to the impact of physical development on the environment. Measures to prevent, reduce or offset any significant adverse effects have been proposed on a policy by policy basis in this SA Report, most of which involve further outlining during the preparation of related Development Plan Documents (DPDs), Supplementary Planning Documents (SPDs), Area Action Plans (AAPs) and project-level Environmental Impact Assessment. Monitoring Recommendations for the monitoring of significant sustainability effects of the implementation of the Core Strategy DPD have been set out in this SA Report. The SA guidance recommends SA monitoring to be incorporated into Local Authority’s existing monitoring arrangements. In accordance with Regulation 48 of the Town and Country Planning Regulations, the Council is required to prepare an Annual Monitoring Report (AMR) to assess the implementation of the Local Development Framework and the extent to which core policies are being achieved and to identify any changes if a policy is not working or if the targets are not met. The Council will integrate the monitoring of the Core Strategy’s significant sustainability effects in these wider monitoring arrangements. Conclusions The Core Policies within the St Edmundsbury Core Strategy DPD meet to a large extent the range of sustainability objectives identified in the SA framework. Recommendations for improving the sustainability performance of the Core Strategy, where appropriate, are provided in this SA Report. In some cases, cross-referencing of policies can clarify the application of all Core Policies to specific development proposals. In others, recommendations have been made as to how strengthen the policies’ wording by expanding aspects of the issues they cover and improving the clarity of policies’ wording. The remaining negative effects can be minimised to acceptable levels by undertaking Environmental Impact Assessment of projects arising from the implementation of the Core Strategy. The wording of policies has been further refined (and expanded in some cases) in the finalised version of the Core Strategy Submission Document, as a result of further Council’s internal work and taking into account recommendations arising from both the SA and AA processes and changes proposed by the Planning Inspectorate. In addition, a new policy covering (policy CS13 Rural Areas) has been added setting out how development in rural areas will be controlled. Refinements to the policies, by providing clarification and further detail, have further enhanced the sustainability performance of St Edmundsbury Core Strategy. As indicated previously, the Core Policies offer potentially significant positive effects on all SA social and economic objectives. However, a range of both significant positive and negative effects have also identified with regard to the environmental SA objectives. The extent of the significance of the identified negative effects associated with new development and the subsequent mitigation will need to be assessed in greater detail in the SA of subsequent DPDs and AAPs. Consequently, careful wording of more specific policies could minimise these potential significant effects identified in the assessment of the Core Strategy policies as well as ensuring that there is adequate provision for the protection of the environment.

St Edmundsbury Borough Council Local Development Framework

Core Strategy Submission Document

Sustainability Appraisal Report

Main Report

July 2009

Notice This report was produced by Atkins for St Edmundsbury Borough Council for the specific purpose of the Core Strategy Development Plan Document Sustainability Appraisal.

This report may not be used by any person other than St Edmundsbury Borough Council without St Edmundsbury Borough Council's express permission. In any event, Atkins accepts no liability for any costs, liabilities or losses arising as a result of the use of or reliance upon the contents of this report by any person other than St Edmundsbury Borough Council.

Document History

JOB NUMBER: 5081433 DOCUMENT REF: Final Main Report CS SAR 5081433 SEBC.doc

2 Final CS/OP/PN OP CW CW 14/07/09

1 1st Draft for Comment CS/OP/PN OP CW CW 23/06/09

Revision Purpose Description Originated Checked Reviewed Authorised Date St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Contents Section Page List of Abbreviations 5 Non-Technical Summary 7 Overview of Process and Purpose of Sustainability Appraisal 7 The Process Followed 7 Appropriate Assessment 8 Contents and Main Objectives of the Core Strategy 8 Sustainability Baseline and Key Issues 9 Sustainability Appraisal Framework 11 Compatibility between Core Strategy and SA Objectives 12 Plan Issues and Options 12 Development of Strategic Sites 13 Assessment of Plan Policies 14 Mitigation 14 Monitoring 14 Conclusions 14 1. Introduction 16 Local Development Framework 16 St Edmundsbury Core Strategy 16 Geographical Area 18 Requirement for Sustainability Appraisal 20 Requirement for Strategic Environmental Assessment 21 The SA Process 22 Purpose of the SA Report 23 Programme and Responsibility 24 Consultation 25 Appropriate Assessment 25 2. Appraisal Methodology 27 Overview of Approach 27 Stage A: Setting the Context and Objectives, Establishing the Baseline and Deciding on Scope 27 Stage B: Developing and Defining Options 29 Stage C: Preparing the Sustainability Appraisal Framework 33 Stage D: Consulting on the Draft Plan and Sustainability Appraisal Report 33 Meeting the requirements of the SEA Directive 33 3. Other Relevant Plans and Programmes 35 Introduction 35 Key Sustainability Themes 41 4. Baseline 50 Introduction 50 Baseline Data Collection 50 Baseline Information 50 5. Key Sustainability Issues 68

2 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Introduction 68 6. Sustainability Appraisal Framework 79 Introduction 79 St Edmundsbury Core Strategy SA Framework 79 SA Baseline Data and Trends 90 7. Compatibility between Core Strategy Objectives and SA Objectives 96 Introduction 96 Overview 96 8. Plan Issues and Options 102 Introduction 102 Development of Spatial Strategic Options 102 Results of Assessment 103 Development of Strategic Sites 105 Introduction 105 Assessment Methodology 105 Assessment Results 111 9. Assessment of Core Strategy Policies 117 Core Strategy Policies 117 Results of the Assessment 117 Cumulative, Synergistic and Indirect Effects 135 10. Mitigation 137 11. Monitoring 138 12. Conclusions 149 13. References 160

List of Tables Table 1.1 – Core Strategy Strategic Objectives 17 Table 1.2 - Incorporating SA in the DPD Preparation Process 23 Table 1.3 – Key SA Tasks and Outputs 24 Table 2.1 – Key to Compatibility of Objectives 29 Table 2.2 – Scoring of Options Assessment 30 Table 2.3 - Key to Strategic Sites Assessment 30 Table 2.4 – Sustainability Effects Scoring 31 Table 2.5 – Sustainability Assessment Scoring 32 Table 2.6 - Schedule of SEA Requirements 34 Table 3.1 – Relevant Plans and Programmes 35 Table 3.2 – Sustainability Themes 42 Table 4.1 – 2001 Population and 10 year change between 1991 and 2001 51 Table 4.2 – Population by age (% of total population) 51 Table 4.3 – Birth place 2001 (% of total population) 52 Table 4.4 – Ethnic groups 2007 (% of total population) 52 Table 4.5 – Ethnic groups 2001 (% of total population) 52 Table 4.6 – Housing Tenure 55 Table 4.7 – Household Composition 55 Table 4.8 – Commuting destinations from St Edmundsbury 2001 60 Table 4.9 – VAT registrations and De-registrations in 2007 62 Table 4.10 – VAT registrations and De-registrations in 2004 62

3 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Table 4.11 – Housing Prices in 2006 62 Table 4.12 – Short and medium term house price changes 63 Table 4.13 – Housing Affordability for 1st Quarter 2006 63 Table 4.14 – Economic Activity and Employment Rates 64 Table 4.15 – Employment by sector, 2004 64 Table 4.16 – Sector growth within St Edmundsbury 2004-2006 65 Table 4.17 - Sector growth within St Edmundsbury 1998-2004 65 Table 4.18 – Unemployment rate within St Edmundsbury June 2006 66 Table 4.19 – Average Earnings for 2005 66 Table 5.1 – Key Sustainability Issues 69 Table 6.1 – SA Framework 80 Table 6.2 – SA Current and Predicted Future Baseline Data Trends 91 Table 7.1 – Compatibility Matrix between draft Core Strategy objectives and SA Objectives 98 Table 7.2 – Discussion of Results of Assessment of draft Core strategy Objectives with the SA objectives 99 Table 8.1 – Scoring of Options Assessment 103 Table 8.2 – Summary of Assessment of Strategic Options for Spatial Strategy 104 Table 8.3 – Strategic Sites Sustainability Appraisal Framework 106 Table 8.4 - Key to Strategic Sites Assessment 111 Table 8.5 – Summary of the strategic sites assessment 113 Table 9.1 - Core Strategy Policies 118 Table 9.2 – Assessment Rationale for Policies Assessment 125 Table 9.3 – Summary of Significance of Direct Effects of the Preferred Policies 129 Table 9.4 – Summary of Cumulative, Synergistic and Indirect Effects 135 Table 11.1 - Proposed Monitoring Programme 140 Table 12.1 –Core Strategy Policies (as in Core Strategy Submission Document) 150

List of Figures Figure 1.1 – St Edmundsbury Borough 19 Figure 2.1 – Relationship between SA Stages and Tasks 28 Figure 4.1 – Environmental Designations in St Edmundsbury 58

Appendices (standalone document) Appendix A - Baseline Data Tables Appendix B – Strategic Options Assessment Table Appendix C – Strategic Sites Assessment Tables Appendix D – Assessment of Plan Policies Appendix E - Consultation Comments on Scoping Report Appendix F - Consultation Comments on Initial Sustainability Appraisal (Issues and Options Report) Appendix G - Consultation Comments on Preferred Options and Strategic Sites Issues and Options SAR

4 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

List of Abbreviations

Term Meaning/ Definition AMR Annual Monitoring Report AQMA Air Quality Management Area BAP Biodiversity Action Plan

BVPI Best Value Performance Indicator

CO2 Carbon Dioxide CS Core Strategy

CWS County Wildlife Site DCLG Department of Communities and Local Government DPD Development Plan Document IMD Index of Multiple Deprivation LDD Local Development Document LDF Local Development Framework LNR Local Nature Reserve LPA Local Planning Authority NNR National Nature Reserve ODPM Office of the Deputy Prime Minister ONS Office of National Statistics PDL Previously Developed Land

PM10 Particulate Matter up to 10 micrometers in size PPG Planning Policy Guidance Note PPPs Plans, Programmes and Policies PPS Planning Policy Statement RIGS Regionally Important Geological/Geomorphological Site RPG Regional Planning Guidance SA Sustainability Appraisal SM Scheduled Monument SEA Strategic Environmental Assessment SEBC St Edmundsbury Borough Council

SINC Site of Importance for Nature Conservation SPD Supplementary Planning Document

5 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Term Meaning/ Definition SSAG Suffolk Sustainability Appraisal Group SSSI Site of Special Scientific Interest SUDS Sustainable Urban Drainage Systems

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Non-Technical Summary

7 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Appropriate Assessment There are three European designations relating to nature conservation within the district: Breckland Special Protection Areas, Brecklands Special Areas of Conservation and Waveney and Little Ouse Valley Fens Special Areas of Conservation. There is a requirement for any policies, plans or projects with potential to affect European sites to undergo Appropriate Assessment under the European Habitats Directive. Although the requirement and process are separate from that for SA, the two processes have been run in parallel for the Core Strategy DPD. Appropriate Assessment screening of the Core Strategy DPD concluded that there will be no likely significant effects due to the implementation of the Core Strategy policies. These results are reflected in the SA Report. Contents and Main Objectives of the Core Strategy The St Edmundsbury Core Strategy DPD sets out the Council’s vision for future growth, objectives and strategic policy framework that will manage and guide development in the borough over the next twenty years and beyond. The St Edmundsbury vision includes a number of highlights, including ensuring that the distinctive local character, unique local heritage and environmental and cultural assets are retained and enhanced and employment growth and development will produce a prosperous sustainable economy. The Core Strategy objectives are as follows: A To deliver housing in a sustainable way, including specialist and affordable housing to meet the needs of the whole community, by providing an adequate and continuous supply of land for housing whilst seeking to maximise the amount of Previously Developed Land used. B To secure economic vitality and growth by delivering an adequate and continuous supply of land for employment to meet the needs and demands of different sectors of the economy and reduce the need for out-commuting. C To sustain and enhance rural communities by providing, where infrastructure and environmental capacity exists, new housing to grow settlements and safeguard existing rural services while, maintaining and, where possible, improving the rural environment. D To maintain and develop leisure, cultural, educational and community facilities, including access to green space, commensurate to the level of housing and employment growth to meet the needs of residents and visitors. E To provide opportunities for people to shop for all their needs by sustainable means in thriving and economically viable town, local and district centres. F To enable people and goods to move around efficiently and safely to the benefit of the economy and community, with minimum harm to the environment by seeking to reduce car dependency and encouraging more sustainable forms of transport. G To maintain and protect built and natural environment and ensure that new development protects and enhances assets of local design, cultural, historic and conservation importance, and character of the landscape. H To maintain, protect and enhance the biodiversity, geodiversity and natural environment and seek opportunities to increase the provision of green open space and access to the countryside. I To ensure that new development only occurs where there is adequate capacity in existing services, facilities and infrastructure or where this capacity can reasonably be provided. J To ensure new development addresses and tackles environmental and sustainability issues including climate change adaptation, carbon emissions reduction, renewable energy provision, recycling, waste reduction and water efficiency. The Core Strategy contains a set of fifteen policies developed to implement the vision and objectives, as follows: Policy CS1 St Edmundsbury Spatial Strategy

8 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Policy CS2 Sustainable Development Policy CS3 Design and Local Distinctiveness Policy CS4 Settlement Hierarchy and Identity Policy CS5 Affordable Housing Policy CS6 Gypsy and Traveller Accommodation Policy CS7 Sustainable Transport Policy CS8 Strategic Transport Improvements Policy CS9 Employment and the Local Economy Policy CS10 Retail, Leisure and Cultural Provision Policy CS11 Bury St Edmunds Strategic Growth Policy CS12 Haverhill Strategic Growth Policy CS13 Rural Areas Policy CS14 Sequential approach to sites development Policy CS15 Community infrastructure capacity and tariffs

Sustainability Baseline and Key Issues The borough of St Edmundsbury is located in Western Suffolk. It has borders with Norfolk to the north, Mid Suffolk and Babergh Districts to the east, Essex to the south and Cambridgeshire and Forest Heath District to the west. While administratively St Edmundsbury’s links are with Suffolk County Council, increasingly the borough is playing a stronger role in the sub-region of Cambridge because of their common economic and social needs. The borough has two main towns - Bury St Edmunds to the north and Haverhill to the south. St Edmundsbury is scattered with a large number of villages and small settlements and retains a predominantly rural character despite its industrial nature. The main sustainability issues identified for St Edmundsbury, which the Core Strategy must address, are briefly summarised below. Significant Historic and Future Population Growth The population has grown significantly over the past two decades (by 16.9%). This growth is expected to continue, particularly with the identification of Bury St Edmunds as a key centre for development and change in the East of England Plan Historic growth in the number of older people in the Borough (+14.7% over 2002-07) has been significantly higher than that experienced in the East of England as a whole (+8.8% over 2002-07). However, the age profile broadly reflects that of the East of England. 43% of the borough’s population live in rural areas. This is an unusually high proportion (23% of England’s population live in rural areas), and reflects the largely rural nature of the borough. Relatively Low Education and Qualification Attainment The percentage of the population with no qualifications is more than double the figures for the East of England and England. Localised Deprivation Deprivation is increasing, with the borough’s Index of Multiple Deprivation (IMD) rank having decreased from 267 in 2004 to 260 in 2007. However, deprivation is not evenly located throughout the borough. The IMD rankings in Haverhill suggest that deprivation in Haverhill is more widespread rather than just concentrated in small pockets. Furthermore, levels of deprivation in the rural areas have increased both relative to elsewhere in England and in absolute scores.

9 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Insufficient Amount of Housing, including Affordable Housing and High Level of Unfit Dwellings Although the number of houses built i.e. housing completions in 2006/07, was above the H1 policy target included in the East of England Plan, in previous years the number of completions has not reached the target level. The uptake of housing benefits has steadily increased since 2003, suggesting that there is insufficient affordable housing available within St Edmundsbury. Furthermore, the housing affordability ratio of the borough has increased steadily since 2003, indicating that there are significant housing affordability problems, particularly as a result of year-on-year increases in house prices. Lack of Accommodation Provision for Gypsies and Travellers St Edmundsbury had 2 gypsy and traveller pitches in 2006. The borough is not on track to reach its East of England Policy H4 target which requires 17 pitches by 2011. Earnings below Regional Figures Whilst average earnings have increased over recent years, they are still below figures for the East of England and England. Furthermore, median wage figures indicate that there are an above average number of low paid jobs in the borough. Pressure on Rich Biodiversity St Edmundsbury contains a number of sites designated for their internationally important ecology. These are: • Breckland SPA; • Breckland SAC; and • Waveney & Little Ouse Valley Fens SAC. The borough also contains a number of SSSIs, National Nature Reserves, County Wildlife Sites, Local Nature Reserves and Country Parks. Although these sites are considered to be of significant ecological value, their integrity, and the habitats and species that they support are under pressure from the high level of development required in order to meet growth targets set within the East of England Plan. The majority of the ecological SSSIs in the borough are partly in an unfavourable or mixed condition with 2 of the Borough’s 23 SSSIs wholly in an unfavourable and deteriorating condition. There are a large number of designated BAP habitats and species in Suffolk, many of which will be present in St Edmundsbury. It is important that any permitted development does not detrimentally affect these habitats and species. Pressure on Landscape The borough contains 14 landscape types, which are distinct and individually important to the character of the Borough. Development pressures (e.g. suburbanisation, transport and industrial developments, agricultural rationalisation and tourism related development) as a result of past and projected future development within the borough have placed, and are likely to continue to place significant pressure on the landscape of St Edmundsbury. Rich Archaeology and Cultural Heritage St Edmundsbury contains over 3,000 listed buildings and a number of historic parks and gardens, scheduled monuments and conservation areas. It is vital that these valuable assets continue to be protected. Pressure on Water Resources The level of development required by the East of England Plan, and the population growth that this is likely to cause, will dramatically increase the pressure on existing water resources. These resources are already strained given that the amount of rainfall received in the East of England is significantly less than for other parts of the UK, and is likely to decrease as a result of projected climate change.

10 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Potential for Flood Risk Whilst a very low proportion of property is at risk of flooding, Bury St Edmunds, Haverhill and many of the borough’s villages are located in river valleys. Historic evidence has demonstrated that extreme weather conditions have the potential to cause damage through flooding in these areas. Need to Adapt to a Changing Climate The main expected climate changes in the East of England are increases in temperatures (hotter summers, milder winters); increases in seasonality (e.g. dryer summers, wetter winters); and increases in the intensity and frequency of storm events (e.g. extreme rainfall event leading to fluvial /groundwater flooding). St Edmundsbury needs to adapt to these unavoidable consequences of climate change. High Energy Consumption Average annual electricity consumption figures show a decrease in domestic electricity consumption but an increase in industrial energy consumption since 2003. Figures also indicate that average domestic and industrial energy consumption in the borough is above both that for the East of England and Great Britain. There are no commercial renewable energy facilities within the borough.

High CO2 Emissions per Capita

11 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Social 1. To improve the health of the population overall and reduce health inequalities 2. To maintain and improve levels of education and skills in the population overall 3. To reduce crime and anti-social activity 4. To reduce poverty and social exclusion 5. To improve access to key services for all sectors of the population 6. To offer everybody the opportunity for rewarding and satisfying employment 7. To meet the housing requirements of the whole community 8. To improve the quality of where people live and to encourage community participation Environmental 9. To improve water and air quality 10. To conserve soil resources and quality 11. To use water and mineral resources efficiently, and re-use and recycle where possible 12. To reduce waste 13. To reduce the effects of traffic on the environment 14. To reduce contributions to climate change 15. To reduce vulnerability to climatic events 16. To conserve and enhance biodiversity and geodiversity 17. To conserve and where appropriate enhance areas of historical and archaeological importance 18. To conserve and enhance the quality and local distinctiveness of landscapes and townscapes Economic 19. To achieve sustainable levels of prosperity and economic growth throughout the plan area 20. To revitalise town centres 21. To encourage efficient patterns of movement in support of economic growth 22. To encourage and accommodate both indigenous and inward investment Compatibility between Core Strategy and SA Objectives Initial work on the Core Strategy DPD identified a set of objectives to achieve the overall vision for the area. Each of these objectives was evaluated in terms of its compatibility with each of the SA objectives above. The results of the compatibility assessment indicated that the overall compatibility between the initial set of the Core Strategy Objectives and the SA Objectives was relatively good. This was particularly true of the compatibility with the social and economic dimensions of sustainability. In contrast, there was a considerable amount of uncertainty with regards to the environmental objectives, which required addressing through the translation of the Core Strategy objectives into future policies which take fully into account environmental considerations. Plan Issues and Options Five main strategic options for the spatial strategy for the borough were set out in Part 5 of the Core Strategy Issues and Options document published in March 2008. These were: • Option 1: Business as usual – this maintains the hierarchy in the Replacement St Edmundsbury Borough Local Plan 2016 (adopted in 2006), to determine the scale of new development appropriate for each location.

12 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

• Option 2: Urban Growth – under this option new development would be directed towards Bury St Edmunds and Haverhill and a slowing down in the recent rates of development in the rural settlements. • Option 3: Regeneration of Haverhill – the majority of new development would be split equally between Bury St Edmunds and Haverhill, and development in the rural areas would be much lower than recently experienced. • Option 4: Rural Development - under this option significantly more development would take place in the settlements outside Bury St Edmunds and Haverhill than at present. Development rates in Haverhill would reduce compared with the previous ten years, but growth rates in Bury St Edmunds would continue at the rate achieved over the same period, in order to reflect the strategy of the Draft East of England Plan. • Option 5: New Settlement – this option proposes a new settlement of at least 3,000 homes plus a commensurate level of jobs, services and community facilities to be constructed in the latter years of the LDF period. Some growth in the existing towns and villages would be required in the interim period to ensure that housing and the economy remain buoyant, but there would be a lower rate of development in those settlements in parallel with the construction of a new settlement. The assessment revealed varying degrees of sustainability across the options. Key general findings which emerged from the assessment were: • The assessment results show that Options 2 and 3 perform well in the sustainability terms with no significant differences between them, as both options direct further growth to Bury St Edmunds and Haverhill and slow down and restrict development in the rural areas. The main benefits that these two options are expected to deliver include better opportunities for development on previously developed land, the provision of good cycle and pedestrian links to employment, services and facilities, the provision of education and skills training, the efficient use of energy, etc. • Option 1 is a business as usual scenario, which supports a more disperse growth by directing development to Bury St Edmunds and also allowing development in the rural service centres. This option is also expected to deliver positive effects against the SA objectives overall, although of lower level than Options 2 and 3. • Option 5 supporting the development of new settlement was also identified as being likely to deliver beneficial effects overall. The main advantages associated with this option include the use of more sustainable modes of transport, accessibility to key services and ability to provide homes for all, and also by providing opportunities to adopt sustainable development measures throughout the development and from the outset. However, disadvantages of this option are loss of significant amount of greenfield land and potentially diverting from opportunities in the existing settlements. • Option 4, promoting growth in the countryside scores the lowest against the SA objectives due to such effects as restricting access to the key services and facilities with little or no scope for employment, exacerbating the reliance on the private car, loss of green space and natural habitats and inability accommodate the required level of growth and meet the housing needs of the whole community. Positive effects of helping avoid the demise of rural facilities are likely to be outweighed by the listed negative effects. Although the Council ultimately held responsibility for selecting the preferred option for each strategic policy, the SA assessment differentiated the various policy options for each objective and helped to identify the most sustainable options. Development of Strategic Sites Strategic sites identified in the Core Strategy Preferred Options and Strategic Sites document (November 2008) have been subject to an assessment in order to determine their performance in sustainability terms,

13 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report with reference to social, environmental and economic factors. These sites are located around Bury St Edmunds and Haverhill. Assessment of Plan Policies Drawn from the options previously identified as being the most sustainable, the Core Strategy policies seek to implement the Core Strategy vision and objectives. As already indicated, there are 15 policies in total which have been assessed in order to predict and evaluate the nature (positive, negative or neutral), scale (significant or non-significant) and timeframe (short-term, medium-term or long-term) of the social, environmental and economic effects. The assessment indicates that the Core Strategy document performs with mixed results against the SA framework, but on the whole achieves a balance of positive significant effects. The Core Policies offer potentially significant positive effects on all SA social and economic objectives, therefore addressing suitably the issues associated with health, education, crime and fear of crime, poverty and social exclusion, access to key services, employment, housing requirements, revitalisation of town centres, economic growth and investment. However, a range of both significant positive and negative effects have also identified with regard to the environmental SA objectives. The predicted negative effects are associated with Policies aiming to accommodate the provision of approximately 10,000 new homes and required infrastructure in St Edmundsbury, including Greenfield land take, which will have negative effects on the environment. Specifically, the assessment has identified negative effects of varying scale and significance on water and air quality, soils resources and quality, mineral resources, waste, effects of traffic on the environment, climate change, vulnerability to climatic events, biodiversity, heritage and local landscape and townscape. Recommendations in terms of broadening aspects covered by particular policies or strengthening their requirements have been provided to mitigate potential negative effects and enhance positive ones. Mitigation Although the Core Strategy will have a positive significant effect in sustainability terms overall, certain policies have the potential for negative significant effects relating primarily to the impact of physical development on the environment. Measures to prevent, reduce or offset any significant adverse effects have been proposed on a policy by policy basis in this SA Report, most of which involve further outlining during the preparation of related Development Plan Documents (DPDs), Supplementary Planning Documents (SPDs), Area Action Plans (AAPs) and project-level Environmental Impact Assessment. Monitoring Recommendations for the monitoring of significant sustainability effects of the implementation of the Core Strategy DPD have been set out in this SA Report. The SA guidance recommends SA monitoring to be incorporated into Local Authority’s existing monitoring arrangements. In accordance with Regulation 48 of the Town and Country Planning Regulations, the Council is required to prepare an Annual Monitoring Report (AMR) to assess the implementation of the Local Development Framework and the extent to which core policies are being achieved and to identify any changes if a policy is not working or if the targets are not met. The Council will integrate the monitoring of the Core Strategy’s significant sustainability effects in these wider monitoring arrangements. Conclusions The Core Policies within the St Edmundsbury Core Strategy DPD generally meet the range of sustainability objectives identified in the SA framework. Recommendations for improving the sustainability performance of the Core Strategy, where appropriate, are provided in this SA Report. In some cases, cross-referencing of policies can clarify the application of all Core Policies to specific development proposals. In others, recommendations have been made as to how strengthen the policies’ wording by expanding aspects of the issues they cover and improving the clarity of

14 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report policies’ wording. The remaining negative effects can be minimised to acceptable levels by undertaking Environmental Impact Assessment of projects arising from the implementation of the Core Strategy. The wording of policies has been further refined (and expanded in some cases) in the finalised version of the Core Strategy Submission Document, as a result of further Council’s internal work and taking into account recommendations arising from both the SA and AA processes and changes proposed by the Planning Inspectorate. In addition, a new policy covering (policy CS13 Rural Areas) has been added setting out how development in rural areas will be controlled. Refinements to the policies, by providing clarification and further detail, have further enhanced the sustainability performance of St Edmundsbury Core Strategy. As indicated previously, the Core Policies offer potentially significant positive effects on all SA social and economic objectives. However, a range of both significant positive and negative effects have also identified with regard to the environmental SA objectives. The extent of the significance of the identified negative effects associated with new development and the subsequent mitigation will need to be assessed in greater detail in the SA of subsequent DPDs and AAPs. Consequently, careful wording of more specific policies could minimise these potential significant effects identified in the assessment of the Core Strategy policies as well as ensuring that there is adequate provision for the protection of the environment.

15 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

1. Introduction Local Development Framework 1.1 Local Development Frameworks (LDFs) are to be prepared by Local Planning Authorities (LPAs). LDFs comprise a portfolio of Local Development Documents (LDDs). LDDs may be divided into three categories: • Development Plan Documents (DPDs) - subject to independent examination and have the weight of development plan status. DPDs form part of the statutory development plan together with the Regional Spatial Strategy (RSS) prepared by the Government Office, in this case for the East of England (GO-East). • Supplementary Planning Documents (SPDs) - not subject to independent examination and do not have development plan status. SPDs build upon policy and the guidance specified in DPDs. SPDs cannot be used to allocate land. • Statement of Community Involvement (SCI) - outlines how the LPA will consult with key stakeholders and the community. The SCI is subject to independent examination. 1.2 The St Edmundsbury LDF comprises a number of Development Plan Documents (DPDs) that set out the policies and proposals for the development and use of land. At present the main DPD documents that will be produced as part of the St Edmundsbury LDF are: • A Core Strategy: This will provide the vision, objectives and key policies for the future development of St Edmundsbury; • Site Specific Allocations: These will identify and protect land to meet the future needs of St Edmundsbury; and • Development Management Policies: These are the detailed policies against which planning applications will be determined. St Edmundsbury Core Strategy 1.3 The St Edmundsbury Core Strategy DPD sets out the Council’s vision for future growth, objectives and strategic policy framework that will manage and guide development in the borough over the next twenty years and beyond. The Core Strategy lists the policies required to implement this vision, which will be supported by the Site Specific Allocations and Development Control Policies DPDs. In addition to these policies, the Core Strategy identifies broad locations for growth in Bury St Edmunds and Haverhill, the development of which is proposed in order to meet the significant housing growth targets set out in the East of England Plan (RSS) adopted in May 2008. 1.4 In accordance with St Edmundsbury vision, by 2031 the borough will: • ‘remain a vibrant part of Suffolk and a region where the distinctive local character, unique local heritage and environmental and cultural assets are retained and enhanced for the enjoyment of all • The Borough will be a safe place to live with strong communities • Employment growth and development will produce a prosperous sustainable economy including sustainable tourism • All residents of the Borough will have an equal opportunity to access services, jobs and leisure facilities to maximise their potential to live and work • A hierarchy and network of town and village centres will grow and develop to provide a wide range of services in a good environment and accessible to all, appropriate to the size of settlement.

16 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

• The Borough will respond to the challenge of delivering growth in a manner that does not just respect the heritage and culture of St Edmundsbury but actually strives to enhance them in an environmentally sustainable way • The natural and built environment and local biodiversity of the Borough will be protected and where possible enhanced to increase access to the countryside and the provision of green open space. • The challenges of climate change will be addressed to ensure that the specific threats that Suffolk faces are mitigated but that other adaptations are also made such as an increase in renewable energy and water efficiency and an active decrease in carbon emissions. • All new development will respect the Brecks Special Protection Area, Special Areas of Conservation and Sites of Special Scientific Interest. • Bury St Edmunds and Haverhill will be the cultural and economic hearts of the Borough with strong, sustainable links to the surrounding key services centres, villages and countryside.” 1.5 It is essential that the Core Strategy provides measurable objectives (termed strategic aims) designed to implement the Core Strategy spatial vision. They set the context for spatial policies and proposals in the Local Development Framework. The Core Strategy adopts strategic objectives for planning in the borough from the recent Replacement St Edmundsbury Borough Local Plan (A to I), with some amendments, and adds an additional objective (J) to address climate change issues. The Core Strategy strategic objectives are detailed in Table 1.1. Table 1.1 – Core Strategy Strategic Objectives

Strategic Objectives Strategic Objective A To deliver housing in a sustainable way, including specialist and affordable housing to meet the needs of the whole community, by providing an adequate and continuous supply of land for housing whilst seeking to maximise the amount of Previously Developed Land used.

Strategic Objective B To secure economic vitality and growth by delivering an adequate and continuous supply of land for employment to meet the needs and demands of different sectors of the economy and reduce the need for out-commuting. Strategic Objective C To sustain and enhance rural communities by providing, where infrastructure and environmental capacity exists, new housing to grow settlements and safeguard existing rural services while, maintaining and, where possible, improving the rural environment.

Strategic Objective D To maintain and develop leisure, cultural, educational and community facilities, including access to green space, commensurate to the level of housing and employment growth to meet the needs of residents and visitors.

Strategic Objective E To provide opportunities for people to shop for all their needs by sustainable means in thriving and economically viable town, local and district centres.

Strategic Objective F To enable people and goods to move around efficiently and safely to the benefit of the economy and community, with minimum harm to the environment by seeking to reduce car dependency and encouraging more sustainable forms of transport.

Strategic Objective G To maintain and protect built and natural environment and ensure that new development protects and enhances assets of local design, cultural, historic and conservation importance, and character

17 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Strategic Objectives of the landscape.

Strategic Objective H To maintain, protect and enhance the biodiversity, geodiversity and natural environment and seek opportunities to increase the provision of green open space and access to the countryside.

Strategic Objective I To ensure that new development only occurs where there is adequate capacity in existing services, facilities and infrastructure or where this capacity can reasonably be provided. Strategic Objective J To ensure new development addresses and tackles environmental and sustainability issues including climate change adaptation, carbon emissions reduction, renewable energy provision, recycling, waste reduction and water efficiency.

1.6 The Core Strategy Submission Document contains a set of fifteen policies developed to implement the vision and objectives, titled as follows: Policy CS1 St Edmundsbury Spatial Strategy Policy CS2 Sustainable Development Policy CS3 Design and Local Distinctiveness Policy CS4 Settlement Hierarchy and Identity Policy CS5 Affordable Housing Policy CS6 Gypsy and Traveller Accommodation Policy CS7 Sustainable Transport Policy CS8 Strategic Transport Improvements Policy CS9 Employment and the Local Economy Policy CS10 Retail, Leisure and Cultural Provision Policy CS11 Bury St Edmunds Strategic Growth Policy CS12 Haverhill Strategic Growth Policy CS13 Rural Areas Policy CS14 Sequential approach to sites development Policy CS15 Community infrastructure capacity and tariffs

1.7 Additional policies which will shape the way in which development in St Edmundsbury is undertaken, and which will ensure that future development is as sustainable as possible, will be set out in SEBC’s Development Management DPD. 1.8 The Core Strategy also identifies the broad locations for the future strategic growth in Bury St Edmunds and Haverhill. These are sites that will primarily be capable of delivering a mix of uses including homes, jobs, community and social facilities that will be developed over a longer period. The government describe strategic sites as those that are “central to the achievement of the strategy.” The Area Action Plans for Bury St Edmunds and Haverhill will provide more detail about the boundaries and mix of uses to be accommodated in these locations. Geographical Area 1.9 The borough of St Edmundsbury is located in Western Suffolk. It has borders with Norfolk to the north, Mid Suffolk and Babergh Districts to the east, Essex to the south and Cambridgeshire and Forest Heath District to the west. While administratively St Edmundsbury’s links are with Suffolk County Council, increasingly St Edmundsbury is playing a stronger role in the sub-region of Cambridge because of their common economic and social needs.

18 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

1.10 The borough has two main towns Bury St Edmunds to the north and Haverhill to the south. St Edmundsbury is scattered with a large number of villages and small settlements and retains a predominantly rural character. 1.11 The geographical boundary of the borough is shown in Figure 1.1. 1.12 This SA is primarily concerned with effects arising from implementation of the St Edmundsbury Core Strategy. Although the SA will mostly focus on effects within St Edmundsbury Borough, it will also consider the effects of the policies on surrounding areas, the region, and on national and global issues where deemed relevant. Figure 1.1 – St Edmundsbury Borough

19 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Requirement for Sustainability Appraisal

1.13 Under the regulations1 implementing the provisions of the Planning and Compulsory Purchase Act 2004, Sustainability Appraisal (SA) is required for all Local Development Documents (LDDs). The Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 removed the requirement for SA for Supplementary Planning Documents (SPD), although LPAs are still required to screen their SPDs in relation to both SA and SEA. The purpose of SA is to promote sustainable development through better integration of sustainability considerations in the preparation and adoption of plans. The regulations stipulate that SA of LDDs should meet the requirements of the SEA Directive. 1.14 Planning Policy Statement 1 (PPS1) describes Sustainability Appraisal in Paragraph 9 of Annex B: ‘A Sustainability Appraisal is intended to assess the impact of plan policies from an environmental, economic and social perspective. It is intended to test the performance of a plan against the objectives of sustainable development and thereby provide the basis for its improvement. Guidance on carrying out the Sustainability Appraisal will show how they can comply with the requirements of the Strategic Environmental Assessment (SEA) Directive’. 1.15 SA thus helps planning authorities to fulfil the objective of contributing to the achievement of sustainable development in preparing their plans. 1.16 There are many definitions of sustainable development. However, the most commonly used and widely accepted is that coined by the World Commission of Environment and Development in 1987 as: ‘Development which meets the needs of the present without compromising the ability of future generations to meet their own needs.’ 1.17 The UK Government’s Sustainable Development Strategy ‘Securing the Future’, published in March 2005, outlines a set of shared UK principles which will be used to achieve the goal of sustainable development. The guiding principles have been agreed by the UK government, Scottish Executive, Welsh Assembly Government and the Northern Ireland Administration. They bring together and build on the various previously existing UK principles to set out an overarching approach. The five guiding principles will form the basis for policy in the UK. For a policy to be sustainable, it must respect all five of these principles in order to integrate and deliver simultaneously sustainable development: • Living within environmental limits – respecting the limits of the planet’s environment, resources and biodiversity to improve our environment and ensure that the natural resources needed for life are unimpaired and remain so for future generations; • Ensuring a Strong, Healthy and Just Society – meeting the diverse needs of all people in existing and future communities, promoting personal wellbeing, social cohesion and inclusion, and creating equal opportunity for all; • Achieving a Sustainable Economy – Building a strong, stable and sustainable economy which provides prosperity and opportunities for all, and in which environmental and social costs fall on those who impose them (polluter pays); and efficient resource use incentivised; • Promoting Good Governance – Actively promoting effective, participative systems of governance in all levels of society – engaging people’s creativity, energy and diversity; • Using Sound Science Responsibly – Ensuring policy is developed and implemented on the basis of strong scientific evidence, whilst taking into account scientific uncertainty (through the precautionary principle) as well as public attitudes and values.

1 Town and Country Planning (Local Development) (England) Regulations 2004. The Regulations came into force on 28 September 2004. 20 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

1.18 St Edmundsbury Borough Council is committed to sustainable development, placing the ideologies which underpin it at the centre of its activities. Sustainable development in St Edmundsbury is defined as that which balances the needs of a growing economy with protecting the built and natural environment. 1.19 The importance of sustainability for St Edmundsbury is demonstrated by the formation in 2006 of a Sustainable Development Panel within the Council who are specifically concerned with sustainability issues within the borough. This work is supported by that of the Suffolk Sustainability Appraisal Group (SSAG), whose advice and opinion has been sought throughout the Sustainability Appraisal process. This group, whose role is to monitor a range of social, economic and environmental indicators in order to assess Suffolk's progress towards sustainable development, is a partnership between Suffolk County Council, the seven district/borough councils which comprise Suffolk and other statutory organisations. Requirement for Strategic Environmental Assessment 1.20 The EU Directive 2001/42/EC on the assessment of effects of certain plans and programmes on the environment (the ‘SEA Directive’) came into force in the UK on 20 July 2004 through the Environmental Assessment of Plans and Programmes Regulations 2004. 1.21 The Directive applies to a variety of plans and programmes including those for town and country planning and land use. The Local Development Framework is prepared and adopted by an authority at the local level and is required by legislative provisions. It is prepared for the purposes of town and country planning/land use and is likely to have significant effects on the environment. It is therefore the case that the DPDs and SPDs prepared as part of the St Edmundsbury LDF are required to be subject to environmental assessment, under the SEA Directive. 1.22 The overarching objective of the SEA Directive is: “To provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans… with a view to promoting sustainable development, by ensuring that, in accordance with this Directive, an environmental assessment is carried out of certain plans… which are likely to have significant effects on the environment.” (Article 1) 1.23 SEA is an iterative assessment process which plans and programmes are now required to undergo as they are being developed, to ensure that potential significant environmental effects arising from the plan/programme are identified, assessed, mitigated and communicated to plan- makers. SEA also requires the monitoring of significant effects once the plan/programme is implemented. 1.24 The SEA Directive and the SEA Regulations state that the SEA must consider the following topic areas: • Biodiversity; • Population; • Human Health; • Flora and Fauna; • Soil; • Water; • Air; • Climatic Factors; • Material assets; • Cultural heritage, including archaeological and built heritage; • Landscape; 21 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

• And the interrelationship between these factors.

The SA Process

1.25 The requirements to carry out SA and SEA are thus distinct, but guidance2 from the Office for the Deputy Prime Minister (ODPM) states that it is possible to satisfy both through a single appraisal process and provides a methodology for doing so. 1.26 According to the same guidance, the main stages in the SA process are as follows: • Stage A – Setting the context and objectives, establishing the baseline and deciding on scope; • Stage B – Developing and refining options and assessing effects; • Stage C – Preparing the Sustainability Appraisal Report; • Stage D – Consultation on the plan and the Sustainability Appraisal Report; and • Stage E – Monitoring the significant effects of implementing the plan. 1.27 The ODPM’s guidance emphasises that SA is an iterative process which identifies and reports on the likely significant effects of the plan and the extent to which its implementation will achieve the social, environmental and economic objectives by which sustainable development can be defined. The intention is that SA is fully integrated into the plan making process from the earliest stages, both informing and being informed by it. The guidance also sets out a requirement for the preparation of the following reports: • Scoping Report (documenting Stage A work) which should be used for consultation on the scope of the SA; • Sustainability Appraisal Report (documenting Stages A and B work) which should be used in the public consultation on the Preferred Options version of the draft DPD. The SA Report fully encompasses the requirement to produce an Environmental Report under the SEA Directive. 1.28 Table 1.2 sets out the various SA stages, tasks and relationships with the DPD preparation, as set out in the ODPM guidance.

2 Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents, ODPM, November 2005 22 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Table 1.2 - Incorporating SA in the DPD Preparation Process

DPD Stage 1: Pre-production – Evidence Gathering SA Stages and tasks Stage A: Setting the context and objectives, establishing the baseline and deciding upon the scope A1: Identifying other relevant policies, plans and programmes, and sustainability objectives A2: Collecting baseline information A3: Identifying sustainability issues and problems A4: Developing the SA framework A5: Consulting on the scope of the SA DPD Stage 2: Production SA Stages and tasks Stage B: Developing and refining options and assessing effects B1: Testing the DPD objectives against the SA framework B2: Developing the DPD options B3: Predicting the effects of the DPD B4: Evaluating the effects of the DPD B5: Considering ways of mitigating adverse effects and maximising beneficial effects B6: Proposing measures to monitor the significant effects of implementing the DPD Stage C: Preparing the Sustainability Appraisal Report C1: Preparing the SA Report Stage D: Consulting on the preferred options of the DPD and SA Report D1: Public participation on the preferred options of the DPD and SA Report D2 (i): Appraising significant changes DPD Stage 3: Examination SA Stages and tasks D2 (ii): Appraising significant changes resulting from representations DPD Stage 4: Adoption and Monitoring SA Stages and tasks D3: Making decisions and providing information Stage E: Monitoring the significant effects of implementing the DPD E1: Finalising aims and methods for monitoring E2: Responding to adverse effects

Purpose of the SA Report 1.29 The SA is needed to inform the decision making process during the preparation of the Core Strategy. This will ensure that potential sustainable development implications of the Core Strategy are identified and recognised in the choices made by the local planning authority (LPA). The SA must also test the performance of the Core Strategy in order to determine whether it appears to be appropriate for the task intended. 1.30 The requirement to prepare a Sustainability Appraisal Report arises directly from Article 5.1 of the SEA Directive which states that: ‘An Environmental Report shall be prepared in which the likely significant effects on the environment of implementing the plan or programme, and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme, are identified, described and evaluated.’ 1.31 In sustainability appraisal the Sustainability Appraisal Report replaces the Environmental Report as required under the SEA Directive. 1.32 This Sustainability Appraisal Report reports on the work undertaken during the initial stages of the SA process and takes the process further by reporting on the significant social, environmental and economic effects of the preferred policies, proposed mitigation measures and proposals for monitoring significant sustainability effects.

23 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Programme and Responsibility 1.33 The SA process up to completion of the Core Strategy Preferred Options and Strategic Sites Issues and Options Sustainability Appraisal Report was carried out by Council Officers. The preparation of the Sustainability Appraisal Report for the Core Strategy Submission Document has been undertaken by Atkins Limited independently of St Edmundsbury Borough Council. 1.34 Table 1.3 outlines the timetable and process undertaken to prepare the Sustainability Appraisal. Table 1.3 – Key SA Tasks and Outputs

Task / Output Date Comments

Draft SA Scoping Report October 2006 Report considered available data and experience of Council Officers/LDF and took into account responses to an informal consultation, undertaken between December 2004 and January 2005 with the statutory bodies, relevant Primary Care Trusts, EERA, Suffolk Development Agency, Suffolk Wildlife Trust and other Local Authority services. Consultation October 2006 Natural England, English Nature, English Heritage, Suffolk Primary Care Trust, EERA, East of England Development Agency, Suffolk Wildlife Trust, Suffolk County Council and Go – East were consulted on the draft SA Scoping Report.

Updated SA Scoping Report April 2007 Sustainability Appraisal Scoping Report completed

Draft Core Strategy Issues March 2008 The document included the compatibility and Options Initial assessment of the Core Strategy objectives Sustainability Appraisal and appraisal of five identified potential options for the location of growth in the borough.

Consultation March/April A wide variety of public/stakeholder events. 2008 30 responses made in relation to the Sustainability Appraisal.

Core Strategy Preferred November 2008 The document included the appraisal of Options and Strategic Sites Core Strategy policies and Development Issues and Options Control Policies. Sustainability Appraisal Consultation November 2008 A wide public consultation. 40 Comments – January 2009 received in relation to the Sustainability Appraisal.

Submission Core Strategy July 2009 The document is this SA Report. It reviews Document SA Report and updates information previously presented in the SA Scoping Report, Issues and Options Initial SA and Core Strategy Preferred Options and Strategic Sites Issues and Options SA and presents the appraisal of the final set of the Core Strategy policies.

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Consultation 1.35 The Draft Scoping Report was issued for consultation in October 2006 in accordance with the following regulations: • Article 5(4) of EU Directive 2001/42/EC; • The Environmental Assessment of Plans and Programmes Regulations 2004; and • Regulation 25 of the Town and Country Planning (Local Development) (England) Regulations 2004. 1.36 Copies of the draft Scoping Report were sent to the following statutory consultees: • English Nature (now Natural England); • English Heritage; • Environment Agency; and • Countryside Agency (now Natural England). 1.37 Copies of the Draft SA Report were also directly sent to the Suffolk Primary Care Trust, East of England Regional Authority, East of England Development Agency, Suffolk Wildlife Trust, Suffolk County Council and Go – East. 1.38 For the Draft Core Strategy Issues and Options Report and Core Strategy Preferred Options and Strategic Sites Issues and Options Report and their accompanying SA Reports a wide variety of public/stakeholder events in accordance with the council’s adopted Statement of Community Involvement (2008) was undertaken including the following: • Library drop in sessions at all public libraries in the borough; • Parish Council presentations in Bury St Edmunds and Haverhill; • Leaflet drops at supermarkets and distribution to village shops/services; • Articles in the councils ‘Community Spirit’ magazine which is distributed to all households in the borough; • Engagement with the Western Suffolk Local Strategic Partnership; • Focus Groups comprising key stakeholders to discuss and help form specific elements of the strategy; • Public community presentations in Bury St Edmunds and Haverhill; and • Website: for the Preferred Options consultation an interactive document was available to view on the council’s public consultation pages. An interactive questionnaire was also available so that comments could be submitted electronically. 1.39 This SA Report will accompany the Core Strategy Submission Document on consultation which will take place 12th August – 7th October 2009. Appropriate Assessment 1.40 Under Regulation 48(1) of the Conservation (Natural Habitats, &C) (Amendment) (England and Wales) Regulations 2006 an Appropriate Assessment needs to be undertaken in respect of any plan or project which: a. either alone or in combination with other plans or projects would be likely to have a significant effect on a European Site, and b. is not directly connected with the management of the site for nature conservation.

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1.41 European sites include Special Areas of Conservation (SAC) and Special Protection Areas (SPA). There are three European designations within the Borough: Breckland SPA, Brecklands SAC and Waveney and Little Ouse Valley Fens SAC. 1.42 The requirement for and process of Appropriate Assessment is separate from that for SA. For the Core Strategy DPD the two processes have been run in parallel and the Appropriate Assessment results have been taken into account in the preparation of the SA.

26 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

2. Appraisal Methodology

Overview of Approach 2.1 The approach used in the SA of the St Edmundsbury Core Strategy is based on the process set out in the guidance3 from the Office of the Deputy Prime Minister (ODPM – now the Department for Communities and Local Government (DCLG)) on SA of Regional Spatial Strategies (RSSs) and Local Development Documents (LDDs). The SA has been conducted to also meet the requirements of the Strategic Environmental Assessment (SEA) Regulations4. 2.2 The methodology adopted involved the completion of SA stages A, B, C and D and associated tasks as outlined in Figure 2.1. 2.3 The sections below describe the methodology used for Stages A, B, C and D tasks, the results of which are documented in this report. Stage A: Setting the Context and Objectives, Establishing the Baseline and Deciding on Scope 2.4 Scoping work was undertaken in 2006 (Draft Scoping Report) and revised in 2007 (Updated Scoping Report) to help ensure that the SA covered the key sustainability issues which are relevant to St Edmundsbury within the context of the Core Strategy. Other Relevant Plans and Programmes 2.5 Both the Core Strategy and the SA Scoping Report should be set in the context of national, regional and local objectives along with strategic planning, transport, social, economic and environmental policies. This being the case a comprehensive review of all relevant plans, policies and programmes (PPPs) was carried out as part of the SA scoping process. This ensures that the objectives in the SA Report generally adhere to, and are not in conflict with, objectives found in other PPPs and also assists in the setting of sustainability objectives for the SA. In addition to this it can also be used to ascertain potential conflicts between objectives which may need to be addressed as part of the process. 2.6 In order to fully assess relevant PPPs a list was drawn up by the Council using the ODPM SA guidance and local knowledge. For the purposes of comprehensiveness higher tier PPPs were included in the list to show the hierarchy and relationships between the various plans, policies and programmes. The plans, policies and programmes reviewed are outlined in Section 3.

3 Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents, ODPM, November 2005. 4 Environmental Assessment of Plans and Programmes Regulations July 2004, which transposed EU Directive 2001/42/EC on assessment of effects of certain plans and programmes on the environment (the ‘SEA Directive’) into UK law. 27 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Figure 2.1 – Relationship between SA Stages and Tasks

Source: Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents, ODPM, November 2005.

Baseline Data 2.7 To predict accurately how the Core Strategy proposals will affect the environment, and social and economic factors, it is first important to understand the current state of these factors and then examine their likely evolution without the implementation of the plan. 2.8 Baseline information and data are summarised in section 4. Full baseline datasets are presented in Appendix A where data are listed under social, environmental and economic groupings covering: • General indicator; • Quantified data within the plan area; • Comparators and targets (if applicable); • Problems/constraints; and • Source of the information.

2.9 The datasets have been extracted from a wide range of available publications and datasets. Sources have included, among others, national government and government agency websites, census data, and the Office for National Statistics. No primary research has been conducted. 28 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Sustainability Issues 2.10 Analysis of key sustainability issues relevant to the Core Strategy area was carried out. This work was based on the review of relevant plans and programmes and an analysis of the baseline data. 2.11 The key sustainability issues for St Edmundsbury were derived by analysing the baseline data and contextual information from other plans and assessing what the likely significant issues will be over the longer term i.e. 10 years +. 2.12 In addition to this the consultation responses to Scoping Report provided further information relating to the identification of sustainability issues for the Borough. These issues were set out in a table under the three sustainable development dimensions (economic, social and environmental) and covered the most relevant topics. The key sustainability issues table is presented in Section 5. Sustainability Appraisal Framework 2.13 A framework of objectives, indicators and targets, against which the proposals in the Core Strategy can be assessed, was drawn up under the three sustainable development dimensions: social, economic and environmental. These were developed using an iterative process, based on the review of relevant plans and programmes, the evolving baseline and developing analysis of key sustainability issues. The SA framework has been based on the SEA Framework prepared by the Suffolk Sustainability Appraisal Group for all Suffolk authorities to use and adapt in their SA work. 2.14 A revised framework was then developed taking on board comments from the consultation on the original Scoping Report. The SA Framework is presented in Section 6. Consulting on the Scope of the Sustainability Appraisal 2.15 At this stage the Council sought the views of the Consultation bodies and others on the scope and level of detail of the ensuing Sustainability Appraisal Report. A Scoping Report was prepared to that effect. The consultation results were taken into account in the 2007 Update Scoping Report and have influenced and helped shape this SA Report.

Stage B: Developing and Defining Options Compatibility Assessment of Core Strategy Objectives against SA objectives 2.16 A compatibility matrix was developed to identify to what extent the objectives of the Core Strategy are compatible with the SA objectives as set out in the SA framework. When testing compatibility the following scale was used:

Table 2.1 – Key to Compatibility of Objectives

Broadly Compatible 9

X Potential Conflict

? Dependent on Nature of Implementation Measures

Not Relevant

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Assessment of Strategic Options 2.17 An assessment of the strategic options for the spatial strategy developed for the Core Strategy was then conducted. The assessment used a broad-brush and qualitative approach, which is generally accepted as good practice by the SA guidance for the earlier strategic stages of the appraisal. 2.18 Potential sustainability effects for each of the strategic options were assessed in terms of progress towards achieving the relevant SA objective using the scoring system presented in Table 2.2. In addition to a symbol, each element of the assessment scale was also assigned a numeric value, to assist in the analysis of the assessment. To further assist in rapid visual assimilation and comparison of assessment scores numeric values were also colour coded using the following basic scheme: • Green – positive • Red – negative 2.19 The numeric scoring system was used to attribute an average score for each strategic option based on its performance against all SA objectives. The assessment of the Core Strategy policies allowed the most and least sustainable aspects of each policy to be identified, with the aim of, where necessary, amending the policies in order to promote their likely sustainable effects and reduce their likely unsustainable effects. This assessment also enabled the identification of those strategic options considered to be the most and least sustainable, and informed the selection of options to be taken forwards as preferred options within the Core Strategy. The results of the assessment are presented in Section 8 and full details can be found in Appendix B. These results were presented in a different format in the initial SA of Core Strategy Issues and Options document (March 2008).

Table 2.2 – Scoring of Options Assessment Scoring of Assessment 3 +++ Major positive - likely to result in substantial progress towards the objective 2 ++ Medium positive - likely to result in some progress towards the objective 1 + Minor positive - likely to result in very limited progress towards the objective 0 0 Neutral outcome -0.5 +/- Range of possible positive and negative outcomes 0 ? Uncertain outcome -1 - Minor negative - likely to be to the very limited detriment of achieving the objective -2 -- Medium negative - likely to be to the limited detriment of achieving the objective -3 --- Major negative - likely to be substantially detrimental to achieving the objective

Assessment of Strategic Sites 2.20 The proposed strategic sites were also assessed in order to identify those potential development sites with the most sustainable effects. SA criteria for the sites assessment was devised based on the SA Framework, consultation comments and questions listed in the Core Strategy Preferred Options and Strategic Sites Issues and Options Document (November 2008) to ensure that the assessment of the strategic sites is fit for purpose. The assessment of the sites was undertaken using the following qualitative assessment scale: Table 2.3 - Key to Strategic Sites Assessment Not relevant to criterion /

In conformity with the criterion Neutral effects ? Partially meets the criterion / possibly in conflict Insufficient information is available with the criterion/ some constraints identified

In conflict with the criterion

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2.21 Matrices were used to record likely sustainability effects of each strategic site against each objective in the SA framework. Full details of the sites assessments can be found in Appendix C and summary of the assessment is presented in Section 8.

Detailed Assessment of Core Strategy Policies 2.22 A detailed assessment of each of preferred Core Strategy policy was conducted using a separate assessment sheet. The results of the policy assessments were then brought together in a single sheet summarising the assessment across all policies. 2.23 The detailed assessment comprised a systematic two-stage process, described below. Prediction of Effects 2.24 Using the baseline data and supporting information, the effects of the policies have been predicted for each of the SA objectives. A six point scale was used to characterise the magnitude of predicted effects in terms of the change to the current baseline. Effects were also characterised in terms of their geographical extent, their duration (short, medium or long term), whether they are likely to be temporary or permanent, and the degree of certainty with which the prediction was made. Predictions were made using the evidence of the baseline data wherever possible. Short term, medium and long term effects were defined as those predicted to commence within the first five, five to ten and ten or more years of implementation of the Core Strategy, respectively 2.25 Table 2.4 details the scoring scales used to characterise the various features of the predicted effects. Table 2.4 – Sustainability Effects Scoring

Magnitude Scale Duration Permanence Certainty 99 Major positive Local Within or in proximity to St Edmundsbury ST-MT Short term - Medium term Temp Temporary Low 9 Minor positive Sub-Reg Western Suffolk and surrounding districts ST-LT Short term - Long term Perm Permanent Med

- No effect Reg/Nat East of England and beyond MT-LT Medium term - Long term High ? Unclear effects ST Short term

2 Minor negative MT Medium term

22 Major negative LT Long term

2.26 Magnitude of effects was defined in terms of progress towards achieving the relevant SA objective: • Major Positive - likely to result in substantial progress towards the objective • Minor Positive - likely to result in limited progress towards the objective • Major Negative - likely to be substantially detrimental to achieving the objective • Minor Negative - likely to be to the limited detriment of achieving the objective Assessment of the Significance of Effects 2.27 The effects predicted for each SA objective for each policy and preferred strategic site were assessed for significance using a simple, systematic process. An assessment score was derived for each objective based on the scores for each effect characteristic (magnitude, duration, scale, permanence and certainty) for short, medium and long term effects, using the assessment scale shown in Table 2.5.

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Table 2.5 – Sustainability Assessment Scoring +++ Strongly positive ++ Moderately positive + Slightly positive 0 No effect - Slightly negative -- Moderately negative --- Strongly negative +/- Combination of positive and negative effects / neutral effect

2.28 For the purposes of analysing the results of the assessment, significant effects are those that result in strongly or moderately negative or positive effects. Secondary and Cumulative Effects Assessments 2.29 Annex I of the SEA Directive requires that the assessment of effects include secondary, cumulative and synergistic effects. 2.30 Secondary or indirect effects are effects that are not a direct result of the plan, but occur away from the original effect or as a result of the complex pathway e.g. a development that changes a water table and thus affects the ecology of a nearby wetland. These effects are not cumulative and have been identified and assessed primarily through the examination of the relationship between various objectives during the Assessment of Environmental Effects. 2.31 Cumulative effects arise where several proposals individually may or may not have a significant effect, but in-combination have a significant effect due to spatial crowding or temporal overlap between plans, proposals and actions and repeated removal or addition of resources due to proposals and actions. Cumulative effects can be: • Additive- the simple sum of all the effects; • Neutralising- where effects counteract each other to reduce the overall effect; • Synergistic– is the effect of two or more effects acting together which is greater than the simple sum of the effects when acting alone. For instance, a wildlife habitat can become progressively fragmented with limited effects on a particular species until the last fragmentation makes the areas too small to support the species at all. 2.32 Many environmental problems result from cumulative effects. These effects are very hard to deal with on a project by project basis through Environmental Impact Assessment. It is at the SA level that they are most effectively identified and addressed. 2.33 Cumulative effects assessment is a systematic procedure for identifying and evaluating the significance of effects from multiple activities. The analysis of the causes, pathways and consequences of these effects is an essential part of the process. 2.34 Cumulative (including additive, neutralising and synergistic) effects have been considered throughout the entire SA process, as described below: • As part of the review of relevant strategies, plans and programmes and the derivation of draft SA objectives, key receptors have been identified which may be subject to cumulative effects. • In the process of collecting baseline information cumulative effects have been considered by identifying key receptors (e.g. specific wildlife habitats) and information on how these have changed with time, and how they are likely to change without the implementation of the Local Development Framework. Targets have been identified (where possible), that identify how close to capacity the key receptor is, which is a key determining factor in assessing the likelihood of cumulative and synergistic effects occurring, and their degree of significance.

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• Through the analysis of environmental issues and problems, receptors have been identified that are particularly sensitive, in decline or near to their threshold (where such information is available). • The development of SA objectives, indicators and targets has been influenced by cumulative effects identified through the process above.. • The likely cumulative effects of the strategic alternatives have been identified which highlighted potential cumulative effects that should be considered later in the SA process. • Testing the consistency between the Core Strategy and SA objectives has highlighted the potential for cumulative effects against specific Core Strategy objectives. • Cumulative effects of the policies have been predicted and assessed through the identification of key receptors and SA objectives that consider cumulative effects assessment. Mitigation 2.35 Mitigation measures have been identified during the evaluation process to reduce the scale/importance of significant negative effects and, where possible, enhance positive effects. Monitoring 2.36 SA monitoring involves measuring indicators which will enable the establishment of a causal link between the implementation of the plan and the likely significant effect (positive or negative) being monitored. It thus helps to ensure that any adverse effects which arise during implementation, whether or not they were foreseen, can be identified and that action can be taken to address them. Stage C: Preparing the Sustainability Appraisal Framework 2.37 The SA Report was prepared by the Council to accompany the Preferred Options Core Strategy DPD on consultation. Stage D: Consulting on the Draft Plan and Sustainability Appraisal Report Appraising significant changes 2.38 The SA Report has now been revised to take into account significant changes to policies arising from consultation. This SA Report accompanies the Core Strategy Submission Document.

Meeting the requirements of the SEA Directive 2.39 As mentioned in Section 2 there is a fundamental difference between the SA and SEA methodologies. SEA is primarily focused on environmental effects and the methodology addresses a number of topic areas namely Biodiversity, Population, Human Health, Flora and Flora, Soil, Water, Air, Climatic Factors, Material Assets, Cultural Heritage and Landscape and the interrelationship between these topics. SA, however, widens the scope of the appraisal to assess the effects of a plan to include social and economic, as well as environmental topics. 2.40 This Sustainability Appraisal has been undertaken so as to meet the requirements of the SEA Directive for environmental assessment of plans. Table 2.6 sets out where the specific SEA requirements have been met in this SA Report.

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Table 2.6 - Schedule of SEA Requirements

Requirements of the Directive Where Covered in Report Preparation of an environmental report in which the likely significant effects on the environment of implementing the plan or programme, and reasonable alternatives taking into account the objectives and geographical scope of the plan or programme, are identified, described and evaluated. The information to be given is: a) An outline of the contents, main objectives of the plan or Section 2, Section 3, programme and relationship with other relevant plans and programmes

b) The relevant aspects of the current state of the environment and Sections 4 and 7, the likely evolution without implementation of the plan or Appendix A programme

c) The environmental characteristics of areas likely to be Section 4, Appendix A significantly affected

d) Any existing environmental problems which are relevant to the Section 4 and 5, plan or programme including, in particular, those relating to any Appendix A areas of a particular environmental importance, such as areas designated pursuant to Directive 79/409/EEC and 92/43/EEC

e) The environmental protection objectives established at Section 3 international, community or national level which are relevant to the programme and the way those objectives and any environmental considerations have been taken into account during its preparation f) The likely significant effects on the environment, including: short, Section 7, 8 and 9, medium and long term; permanent and temporary; positive and Appendix B,C and D negative; secondary, cumulative and synergistic effects on issues such as: biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors. g) The measures envisaged to prevent, reduce and, as fully as Sections 10 possible, offset any significant adverse effects on the environment Appendix D. of implementing the plan or programme.

h) An outline of the reasons for selecting the alternatives dealt with Section 8, Appendices B and a description of how the assessment was undertaken including and C any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information i) A description of measures envisaged concerning monitoring (in Section 11 accordance with regulation 17) j) A non-technical summary of the information provided under the Non-technical summary above headings

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3. Other Relevant Plans and Programmes Introduction 3.1 The SEA Directive states that the Environmental Report should provide information on: ‘The plan’s relationship with other relevant plans and programmes’ and “the environmental protection objectives, established at international, [European] Community or national level, which are relevant to the plan... and the way those objectives and any environmental considerations have been taken into account during its preparation” (Annex 1 (a), (e)). 3.2 Prior to drafting the SA Objectives, a review of all relevant plans and programmes was undertaken (see SEBC SA Scoping Report). This review identified the relationships between the SA and plans and programmes which, in turn, enabled potential synergies to be exploited and, conversely, conflicting initiatives to be identified. 3.3 The purpose of this review was not only to list relevant plans and programmes, but to highlight the influence that the plans and programmes may have upon the SA and Core Strategy in terms of themes set out within them. This review represented the first step in the derivation of the Sustainability Appraisal Framework for the Core Strategy Table 4.1 lists the documents reviewed in the Core Strategy SA Scoping Report and any plans or programmes that have been published or updated since production of the Core Strategy SA Scoping Report. Table 3.1 – Relevant Plans and Programmes International/European context

The Johannesburg Declaration on Sustainable Development – Commitments arising from summit. Sept 2002 The UN Millennium Declaration and Millennium Development Goals – Sept 2000 (RSS) Kyoto Protocol and the UN Framework Convention on Climate Change – May 1992 (RSS) Bern Convention on the Conservation of European Wildlife and Natural Habitats – 1979 (RSS) Ramsar Convention on Wetlands of international importance especially as waterfowl habitat – 1971 (RSS) Bonn Convention on the Conservation of Migratory Species of Wild Animals (1979) (RSS) A New Partnership for Cohesion – Third Report on Economic and Social Cohesion (Feb 04) and Draft New Regulations for Renewed Structural Funds (July 2004) Aarhus Convention (1998) EU Sixth Environmental Action Plan (2002) European Spatial Development Perspective (May 1999) Renewed EU Sustainable Development Strategy (2006) European Biodiversity Strategy (1998) EU Thematic Strategy on Air Quality (2005) Espoo Convention on Environmental Impact Assessment in a Transboundary Context (1991) EU Biodiversity Strategy (1998) OSPAR Biological Diversity and Ecosystems Strategy (2003) UN Convention on Biological Diversity (1992) Strategy on Climate Change: Control Measures Through Until 2020 and Beyond (2007) The Climate action and renewable energy package 2008 European Landscape Convention (2000) EU Thematic Strategy for Soil Protection (2004) The European Convention on the Protection of Archaeological Heritage (Revised) UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage

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(1972) European Directives Air Quality Framework Directive – 96/62/EC (RSS) Directive to Promote Electricity from Renewable Energy – 2001/77/EC (RSS) Directive for the Encouragement of Bio-Fuels for Transport – 2003/30/EC (RSS) Water Framework Directive – 2000/60/EC (RSS) Urban Waste Water Treatment Directive – 91/271/EEC (RSS) Water Pollution caused by Nitrates from Agricultural Sources: Nitrates Directive – 91/676/EEC (RSS) Bathing Water Quality Directive – 76/160/EEC (RSS) Drinking Water Directive – 98/83/EC (RSS) Environmental Impact Assessment (EIA) 85/337/EEC (RSS) Strategic Environmental Assessment (SEA) – 2001/42/EC (RSS) Directive 79/409/EEC on the Conservation of Wild Birds (RSS) Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora (RSS) Framework Waste Directive – 75/442/EEC, as amended (RSS) Directive 99/31/EC on the landfill of waste (RSS) Packaging and Packaging Waste Directive – 94/62/EC of 20 Dec 1994 (RSS) Hazardous Waste Directive 91/689/EEC Energy Performance in Building Directive 2002/91/EEC EU Soil Framework Directive (Proposed) IPPC Directive 96/61/EC – Integrated Pollution Prevention and Control Groundwater Directive (GDW) 2006/118/EC Surface Water Abstraction Directive 75/440/EEC National, regional and local context

National Planning Policy Guidance, Planning Policy Statements and Minerals Policy Statements PPS1 – Creating Sustainable Communities (Feb 04) PPS 1 Supplement Climate Change (Dec 2007) PPG2 – Green Belts (Jan 95) PPS3 – Housing (Nov 06) PPG4 – Industrial and Commercial Development and Small Firms (Nov 92) PPG5 – Simplified Planning Zones (Nov 92) PPS6 – Planning for Town Centres (March 2005) PPS7 – Sustainable Development in Rural Areas (Aug 2004) PPG8 – Telecommunications (August 2001) PPS9 – Biodiversity and Geological Conservation (August 2005) PPS10 – Planning for Sustainable Waste Management (July 2005) PPS11 – Regional Spatial Strategies (2004) PPS12 – Local Development Frameworks (Aug 04) PPG13 – Transport (March 94) PPG14 – Development on Unstable Land (April 90) PPG15 – Planning and the Historic Environment (Sept 94) PPG16 – Archaeology and Planning (Nov 90) PPG17 – Planning for Open Space, Sport and Recreation (July 02) (RSS) PPG20 – Coastal Planning (Sept 92) Review of PPS21: Tourism (March 2003) PPG21 – Tourism (Nov 92)

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PPS22 – Renewable Energy (Aug 04) PPS23 – Planning and Pollution Control (2004) PPG24 – Planning and Noise (Sept 94) PPS25 - Development and Flood Risk (Dec 06) MPS 1: Planning and Minerals Climate Change Act 2008 Strategies and Plans Urban Our Towns and Cities: The Future – Delivering an Urban Renaissance (Nov 2000) Towns and Cities Strategy and Action Plan, Urban Renaissance in the East of England (RSS) Rural Government Rural White Paper: Our Countryside – the future – a fair deal for rural England, DETR (2000) (RSS) The Countryside and Rights of Way Act 2000 Rural Strategy, DEFRA (2004) Sustainable Communities The UK Government Sustainable Development Strategy: Securing the Future (March 2005) Sustainable Communities Plan: Building for the Future (2003) (RSS) A Sustainable Development Framework for the East of England, October 2001 (RSS) Sustainable Communities in the East of England 2003 Strategy for Sustainable Construction (June 2008) The Code for Sustainable Homes: Setting the standard in sustainability for new homes (2008) Creating Sustainable Communities – In the East of England (Jan 2005) A Better Quality of Life: a Strategy for Sustainable Development in the UK (1999), Taking it on: Developing UK Sustainable Development Strategy Together (Consultation: 2004) Regional Spatial Strategy Regional Spatial Strategy – RSS (banked version April 2004) RSS14 for the East of England SEA Scoping Report (17 September 2004) East of England Plan: RSS for the East of England (EERA, 2008) Other Regional Strategies An Integrated Regional Strategy for the East of England (Feb 2005) East of England European Strategy 2003 – 2004, June 2003 (RSS) Towards Sustainable Construction – A Strategy for the East of England, Draft 2003 (RSS) Regeneration Haverhill Masterplan (30 August 2005) Transport Aviation White Paper (Dec 2003) Government/DFT 10 Year Transport Plan 2000 (RSS) DfT – Meeting the Energy Challenge – Energy White Paper (May 2007) DfT – Building Sustainable Transport into New Developments: A Menu of Options for Growth Points and Eco-towns (specially designed for Designated Growth Points) (April 2008) Manual for Streets (2007) The Future of Transport: a Network for 2030 – White Paper (2004) The Future of Rail – White Paper (July 2004) Suffolk Local Transport Plan 2006 - 2011 Suffolk Bus Strategy, 2003 East of England Regional Transport Strategy (April 2003) (Incorporated as a chapter in RPG14) St Edmundsbury Borough Council SPG7 – St Edmundsbury Borough Council Cycling Strategy (September 1995) Suffolk County Council and St Edmundsbury Borough Council - Haverhill Local Transport

37 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Action Plan (May 2003) A Pedestrian Strategy for Bury St Edmunds (January 2001) Bury St Edmunds Transport Strategy (2006) Community Strategies and Community Development Strategies Altogether a better Suffolk – Suffolk’s Community Strategy 2004 (Consultation Draft) West Suffolk Local Strategic Partnership –Community Strategy 2006 - 2016 (June 2004) St Edmundsbury Borough Council Community Development Plan (Jan 2004) Suffolk Structure Plan Suffolk Structure Plan – 2001 All Structure Plan Policies will be replaced by RSS14, except ‘saved’ policies. Saved policies will be valid until at least 28 September 2007. Neighbouring Authority and National Park Local Plans/Local Development Documents Mid Suffolk Local Plan (September 1998) Babergh Local Plan ( 2006) Forest Heath Local Plan (December 1995) Breckland Local Plan (September 1999) Braintree District Local Plan Review (July 2005) South Cambridgeshire Local Plan (February 2004) East Cambridgeshire District Local Plan (June 2000) Parish Plans Bardwell Parish Plan Group – Action Plan 2002 – 2010 Barningham Parish Plan 2003 – 2010 Barrow cum Denham Community Action Plan 2002 – 2005 Cavendish Village Report and Action Plan December 2003 Chedburgh Action Plan 2002 - 2005 Horringer cum Ickworth Parish Plan 2005 - 2015 Ixworth and Ixworth Thorpe Parish Plan 2005 Market Weston Parish Plan 2005 – 2010 Whepstead Parish Plan 2005 - 2015 Local Authority Corporate Plans and Strategies Suffolk County Council Policy and Performance Plan 2004 Local Area Agreement: Suffolk 2 2008-2011 (2008) St Edmundsbury Borough Council Capital Strategy (September 2005) Corporate Plan (Jun 2009) St Edmundsbury Borough Council Equality Scheme (2008) St Edmundsbury Borough Council Asset Management Plan and Capital Strategy – Performance Management and Implementations Plan July 05 – 06 Social – National, regional and local context

Social Inclusion Regional Social Strategy for the East of England (May 2004) Suffolk County Council Equalities Policy (April 2003) St Edmundsbury Borough Council Health and Wellbeing Strategy 2004 - 2008 St Edmundsbury Borough Council People Strategy (July 2004) Health Choosing Health: Making healthy choices easier (Nov 2004) Healthy Futures: A Regional Health Strategy for the East of England 2005-2010 (EERA) Draft 22nd July 05 Social Care Annual Plan 2003-4 Norfolk, Suffolk and Cambridgeshire NHS Strategic Health Authority – Health Strategy 2005-

38 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

2010 Bury and The Rural North – Locality Profile - Suffolk West NHS PCT (Dec 2004) Haverhill - Locality Profile - Suffolk West NHS PCT (Dec 2004) Culture Culture: a catalyst for change. A Strategy for Cultural Development for the East of England, Living East (June 2004) Cultural Strategy for Suffolk (March 2002) St Edmundsbury Borough Council Vision 2025: Leisure and Culture Action Plan (Dec 2005) Education Suffolk’s Strategy for Learning 2004-9 (updated version): The Single Plan (May 2005) Suffolk County Council – School Organisation Plan 2004-9 (Jan 2005) Schools in Suffolk: Developing New Roles and Relationships in Support of Children and Young People (January 2005) Suffolk County Council – Key Stage 2 in the Three Tier System – a 3 Year Project (2005) Suffolk County Council – Building Schools for the Future (2004) Suffolk 14-19 Strategy (2004) Housing Revised Regional Housing Strategy for the East of England: Strategy Document 2005-2010 (Draft) (February 2005) Homes for the Future: More Affordable, More Sustainable (July 2007) Affordable Housing Study: The Provision of Affordable Housing in the East of England 1996- 2021, 2003 (RSS) East of England Affordable Housing Study Stage 2: Provision for Key Workers and Unmet Housing Need, 2005 St Edmundsbury Borough Council Housing Strategy 2004 – 2008 Cambridgeshire Sub-Regional Housing Strategy 2004 – 2008/9 St Edmundsbury Borough Council Empty Homes and Wasted Space Strategy 2005 – 2009 St Edmundsbury Borough Council Urban Capacity Study (January 2003) – reviewed September 2005 St Edmundsbury Housing Requirements Study (October 2005) St Edmundsbury Strategic Housing Land Availability Assessment (July 2009) Affordable Housing Economic Viability Study (July 2009) Community safety Suffolk Community Strategy (Transforming Suffolk 2008-2028) Creating a Safer Stronger Suffolk - Western Suffolk Crime and Disorder Reduction Partnership Strategy 2005 – 2008 Environmental – National, regional and local context

Environmental Strategies Environment, Our future: Regional Environment Strategy for the East of England, East of England Regional Assembly and East of England Environment Forum, July 2003 (RSS) St Edmundsbury Borough Council Vision 2025: Sustainable Environment Action Plan (Dec 2005) Soil Farming and Food Strategy, Facing the Future, DEFRA, (Dec 2002) The First Soil Action Plan for England: 2004 – 2006 (2004) Contaminated Land Strategy for the Borough of St Edmundsbury (Nov 2005) Climate Climate Change – UK Programme, DETR, November 2000 (RSS) UK Climate Change Bill (2008)

39 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Building a Greener Future Towards Zero Carbon Development – Consultation (Dec 2006) Living with Climate Change in the East of England – Summary report supported by technical report (2003) (RSS) St Edmundsbury Borough Council Climate Change Action Plan – in draft form to be reviewed once adopted Air quality Air Quality Strategy for England, Scotland, Wales and Northern Ireland (DEFRA, 2007) Updating and Screening Assessment of Air Quality in St Edmundsbury (2006) Environment Act 1995 Local Air Quality Management Progress Report, St Edmundsbury (2007) Heritage English Heritage Strategy 2005 – 2010 Historic Environment: A Force For the Future (2001) Heritage Counts: State of the Historic Environment (2004) Water Water Resources for the Future – A Strategy for England and Wales (EA, 2001) Water Resources for the Future: A Strategy for Anglian Region (RSS) Water for People and the Environment – Consultation Document (EA, 2007) Biodiversity and nature conservation Working with the Grain of Nature: A Biodiversity Strategy for England (2002) (RSS) Wildlife and Countryside Act (1981, as amended) (RSS) Butterfly Conservation – Regional Action Plan for Anglia (2000) Suffolk Biodiversity Action Plan, Updated December 2004 State of Nature – Lowlands – Future Landscapes for Wildlife (2004) (RSS) The Countryside and Rights of Way Act (2000) The Conservation (Natural Habitats, &c.) Regulations (1994) Regional Biodiversity Action Plan Countryside management Suffolk Rights of Way Improvement Plan – in preparation Suffolk Countryside Strategy Woodland Keepers of Time – A Statement of Policy for England’s Ancient and Native Woodlands: Action Plan 2005 – Woodlands for Life: The Regional Woodland Strategy for the East of England, November 2003 (RSS) Minerals and waste Suffolk Minerals Local Plan Adopted May 1999 Regional Waste Management Strategy (2002) (RSS) Suffolk Waste Local Plan – Revised Deposit Draft (January 2004). English Nature Policy Position Statement: Waste Management (2002) Joint Municipal Waste Management Strategy for Suffolk 2020 (Oct 2003) Economic – National, regional and local context

Economic and Employment Strategies A Shared Vision – The Regional Economic Strategy for the East of England (Nov 2004) Prioritisation in the East of England. June 2003 (RSS) Regional Emphasis Document SR2004, December 2003 (RSS) Framework for Regional Employment and Skills Action (FRESA) (2003) (RSS) International Business Strategy, Consultation Draft, December 2003 (RSS) Expanding Suffolk’s Horizons: 2004-7 – A New Economic Strategy for Suffolk Objective 2 Local Area Framework (2004-2005)

40 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Economic Development Strategy – St Edmundsbury (Dec 2005) St Edmundsbury Rural Action Plan (2008) Tourism Regional Tourism Strategy 2000 – 2010 Tomorrows Tourism Today (August 04) Sustainable Tourism Strategy for the East of England (March 2004)

Key Sustainability Themes 3.4 The relevant plans and programmes identified were analysed to derive a set of key sustainability themes relevant to the national, regional and local context. These key sustainability themes provide important clues in terms of the SA objectives which are likely to require consideration in the Sustainability Appraisal Framework for the Core Strategy. Table 3.2 presents the results of the analysis of key sustainability themes, which includes cross references to the documents in which they feature, and highlights their relevance to the SEA topics stated in the SEA Directive and the SA objectives in Table 6.1.

41 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Table 3.2 – Sustainability Themes

No Sustainability Theme SEA Topic Relationship to SA Objectives 1. Improve the health and The UN Millennium Declaration and Millennium Development Goals; PPS1; Population, Human 1 well-being of the PPG2; PPG17; PPG24, The Countryside and Rights of Way; A Sustainable Health population Development Framework for the East of England; East of England Plan: RSS for the East of England; The Future of Transport: a Network for 2030; Suffolk’s Community Strategy 2004; Choosing Health: Making Healthy Choices Easier; Healthy Futures: A Regional Health Strategy for the East of England 2005-2010; Social Care Annual Plan 2003-4; Norfolk, Suffolk and Cambridgeshire NHS Strategic Health Authority – Health Strategy 2005-2010; Bury and The Rural North – Locality Profile - Suffolk West NHS PCT; Haverhill - Locality Profile - Suffolk West NHS PCT; St Edmundsbury Borough Council Health and Wellbeing Strategy 2004 – 2008; Farming and Food Strategy, Facing the Future; National Air Quality Strategy for England, Wales, Scotland and Northern Ireland; Suffolk Waste Local Plan. 2. Reduce social exclusion The Johannesburg Declaration on Sustainable Development; Human health, 4, 5, 6 and improve equality of The UN Millennium Declaration and Millennium Development Goals; A New Population opportunity Partnership for Cohesion – Third Report on Economic and Social Cohesion; European Spatial Development Perspective; Renewed EU Sustainable Development Strategy; PPS1; PPS7; Rural Strategy; The UK Government Sustainable Development Strategy: Securing the Future; Sustainable Communities Plan: Building for the Future; A Sustainable Development Framework for the East of England; Creating Sustainable Communities – In the East of England; A Better Quality of Life: a Strategy for Sustainable Development in the UK; RSS for the East of England; East of England European Strategy; Corporate Plan - St Edmundsbury: Improving the quality of life for everyone in the borough; St Edmundsbury Borough Council Equality Framework; St Edmundsbury Borough Council Disability Equality Scheme 06 – 09; Regional Social Strategy for the East of England; Suffolk County Council Equalities Policy; St Edmundsbury Borough Council Health and Wellbeing Strategy 2004 – 2008; St Edmundsbury Borough Council People Strategy; St Edmundsbury Borough Council Race Equality Scheme 2005 – 2008.

3. Improve opportunities The Johannesburg Declaration on Sustainable Development; Human health, 1, 2, 5, 6, 8 for access to education, The UN Millennium Declaration and Millennium Development Goals; European Landscape,

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

No Sustainability Theme SEA Topic Relationship to SA Objectives employment, recreation, Spatial Development Perspective; Renewed EU Sustainable Development Population health, community Strategy; PPS1; PPG4; PPS6; PPS7; PPS11; PPS12; PPG20; Our Towns and services and cultural Cities: The Future – Delivering an Urban Renaissance; Towns and Cities opportunities Strategy and Action Plan, Urban Renaissance in the East of England; The Countryside and Rights of Way Act; Rural Strategy; Government Rural White Paper: Our Countryside – the future; The UK Government Sustainable Development Strategy; Sustainable Communities Plan: Building for the Future; A Better Quality of Life: a Strategy for Sustainable Development in the UK; Creating Sustainable Communities – In the East of England; A Sustainable Development Framework for the East of England; East of England Plan: RSS for the East of England; East of England European Strategy 2003 – 2004; Government/DFT 10 Year Transport Plan; Building Sustainable Transport into New Developments; The Future of Transport: a Network for 2030 – White Paper; The Future of Rail – White Paper; Suffolk Local Transport Plan; Suffolk Rights of Way Improvement Plan; Suffolk Countryside Strategy. 4. Raise educational and The Johannesburg Declaration on Sustainable Development; Human health, 2, 6 achievement levels and The UN Millennium Declaration and Millennium Development Goals; A New Population develop opportunities for Partnership for Cohesion – Third Report on Economic and Social Cohesion; everyone to acquire the Renewed EU Sustainable Development Strategy; SEA 2001/42/EC; PPS1; skills needed to find and PPS11; PPS12; The Countryside and Rights of Way Act; The UK Government remain in work Sustainable Development Strategy; Sustainable Communities Plan: Building for the Future; A Sustainable Development Framework for the East of England; Sustainable Communities in the East of England; Creating Sustainable Communities; A Better Quality of Life: a Strategy for Sustainable Development in the UK; Altogether a better Suffolk – Suffolk’s Community Strategy; Corporate Plan - St Edmundsbury: Improving the quality of life for everyone in the borough; Suffolk County Council – Key Stage 2 in the Three Tier System; Suffolk County Council – School Organisation Plan 2004-9; Suffolk’s Strategy for Learning 2004- 9; Suffolk County Council – Building Schools for the Future; Suffolk 14-19 Strategy; Schools in Suffolk; Framework for Regional Employment and Skills Action. 5. Promote levels of The Johannesburg Declaration on Sustainable Development; Population 6 employment The UN Millennium Declaration and Millennium Development Goals; A New Partnership for Cohesion – Third Report on Economic and Social Cohesion; Renewed EU Sustainable Development Strategy; PPS1; PPG4; PPS7; PPG5;

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

No Sustainability Theme SEA Topic Relationship to SA Objectives PPG21; Rural Strategy; The UK Government Sustainable; Development Strategy: Securing the Future; A Sustainable Development Framework for the East of England; A Better Quality of Life: a Strategy for Sustainable Development in the UK; Regional Tourism Strategy 2000 – 2010; Tomorrows Tourism Today; Sustainable Tourism Strategy for the East of England; Economic Development Strategy – St Edmundsbury; Expanding Suffolk’s Horizons: 2004-7; Framework for Regional Employment and Skills Action.

6. Reduce the fear of crime European Spatial Development Perspective; PPS1; PPG5; PPS6; PPS7; PPG20; Human Health, 3 Our Towns and Cities: The Future – Delivering an Urban Renaissance; Towns Population and Cities Strategy and Action Plan; A Sustainable Development Framework for the East of England; A Better Quality of Life: a Strategy for Sustainable Development in the UK; Creating Sustainable Communities – In the East of England; Haverhill Masterplan; Altogether a better Suffolk – Suffolk’s Community Strategy; St Edmundsbury Borough Council Community Development Plan Local Area Agreement: Suffolk 2005-2008; Suffolk Community Safety Strategy; Creating a Safer Stronger Suffolk – Western; Suffolk Crime and Disorder Reduction Partnership Strategy 2005 – 2008.

7. Reduce air pollution The Johannesburg Declaration on Sustainable Development; Air, Human Health, 9 The UN Millennium Declaration and Millennium Development Goals; EU Population Thematic Strategy on Air Quality; Air Quality Framework Directive; Directive for the Encouragement of Bio-Fuels for Transport; PPG2; PPG13; PPS23; PPS6; PPS7; Government Rural White Paper: Our Countryside – the future – a fair deal for rural England; Our Towns and Cities: The Future – Delivering an Urban Renaissance; Towns and Cities Strategy and Action Plan; The Countryside and Rights of Way Act; A Sustainable Development Framework for the East of England; The UK Government Sustainable Development Strategy: Securing the Future; Government/DFT 10 Year Transport Plan; Building Sustainable Transport into New Developments; The Future of Transport: a Network for 2030; Suffolk Local Transport Plan 2001-6; Suffolk Bus Strategy; East of England Regional Transport Strategy; Haverhill Local Transport Action Plan; A Pedestrian Strategy for Bury St Edmunds; Choosing Health: Making healthy choices easier; National Air Quality Strategy for England, Wales, Scotland and Northern Ireland; Air Quality Strategy for England, Scotland, Wales and Northern Ireland; Suffolk

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

No Sustainability Theme SEA Topic Relationship to SA Objectives Rights of Way Improvement Plan; Updating and Screening Assessment of Air Quality in St Edmundsbury.

8. Reduce road traffic and European Spatial Development Perspective; PPS1; PPS6; PPS11; Our Towns Air, Human Health, 13 congestion and Cities: The Future – Delivering an Urban Renaissance; Towns and Cities Landscape Strategy and Action Plan; Urban Renaissance in the East of England; A Population Sustainable Development Framework for the East of England; East of England Plan: RSS for the East of England; Government/DFT 10 Year Transport Plan; Building Sustainable Transport into New Developments; Manual for Streets; The Future of Transport: a Network for 2030 – White Paper; Suffolk Local Transport Plan; Suffolk Bus Strategy; Haverhill Local Transport Action Plan; East of England Regional Transport Strategy; St Edmundsbury Borough Council SPG7; Choosing Health: Making healthy choices easier; Climate Change – UK Programme; Bury St Edmunds Transport Strategy (2006).

9. Reduce waste Urban Waste Water Treatment Directive; Framework Waste Directive; Directive Soil, Water 12 generation and disposal 99/31/EC on the landfill of waste; Packaging and Packaging Waste Directive; and achieve sustainable Hazardous Waste Directive; PPG4; PPS10; PPS23; A Sustainable Development management of waste Framework for the East of England; Towards Sustainable Construction – A Strategy for the East of England; Regional Waste Management Strategy; Suffolk Waste Local Plan; Joint Municipal Waste Management Strategy for Suffolk 2020; English Nature Policy Position Statement: Waste Management. 10. Maintain and improve Urban Waste Water Treatment Directive; Water Pollution caused by Nitrates from Biodiversity, Flora 9 the quality of surface Agricultural Sources: Nitrates Directive; Water Framework Directive; Bathing and Fauna, Soil, and groundwater Water Quality Directive; Drinking Water Directive; IPPC Directive 96/61/EC – Water Integrated Pollution Prevention and Control; Groundwater Directive (GDW); Surface Water Abstraction Directive; PPG20 PPG21; PPS23; PPS25; Water Resources for the Future – A Strategy for England and Wales; Water for People and the Environment – Consultation Document; Water Resources for the Future: A Strategy for Anglian Region.

11. Reduce the use of non- The Johannesburg Declaration on Sustainable Development Climatic Factors, 11 renewable resources Material Assets,

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

No Sustainability Theme SEA Topic Relationship to SA Objectives and protect local mineral MPS 1: Planning and Minerals; The UK Government Sustainable Development Soil, Water assets Strategy: Securing the Future; The Code for Sustainable Homes; East of England Plan: RSS for the East of England; Suffolk Minerals Local Plan.

12. Manage and mitigate UN Framework Convention on Climate Change; Strategy on Climate Change: Climatic Factors, 15 the risk of flooding Control Measures Through Until 2020 and Beyond; PPS 1 Supplement Climate Population, Water Change; PPS6; PPG20; PPS25; A Sustainable Development Framework for the East of England; Sustainable Communities Plan: Building for the Future ; The UK Government Sustainable Development Strategy: Securing the Future; Creating Sustainable Communities – In the East of England; A Better Quality of Life: a Strategy for Sustainable Development in the UK; Government/DFT 10 Year Transport Plan ; The Future of Transport: a Network for 2030. 13. Address the causes of The Johannesburg Declaration on Sustainable Development ; UN Framework Climatic factors 14 climate change through Convention on Climate Change; EU Sixth Environmental Action Plan; Strategy on reducing emissions of Climate Change: Control Measures Through Until 2020 and Beyond; PPS 1 greenhouse gases Supplement Climate Change; PPS6; PPG13; A Sustainable Development (GHGs) Framework for the East of England; The UK Government Sustainable Development Strategy: Securing the Future; The Code for Sustainable Homes; Creating Sustainable Communities – In the East of England; Building Sustainable Transport into New Developments: A Menu of Options for Growth Points and Eco-towns; The Future of Transport: a Network for 2030 – White Paper; Suffolk Local Transport Plan; Government/DFT 10 Year Transport Plan; Climate Change – UK Programme; UK Climate Change Bill; St Edmundsbury Borough Council Climate Change Action Plan; Living with Climate Change in the East of England; Building a Greener Future Towards Zero Carbon Development – Consultation.

14. Increase energy PPS22; A Sustainable Development Framework for the East of England; Strategy Climatic factors 14 efficiency and increase for Sustainable Construction; The UK Government Sustainable Development renewable energy Strategy: Securing the Future; Homes for the Future: More Affordable, More production Sustainable; Energy Performance in Building Directive; The Code for Sustainable Homes.

15. Protect and enhance The European Convention on the Protection of Archaeological Heritage; Cultural Heritage, 17

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

No Sustainability Theme SEA Topic Relationship to SA Objectives heritage assets and their UNESCO Convention Concerning the Protection of the World Cultural and Landscape, setting Natural Heritage; PPS6; PPG15; Population PPG16; Heritage Counts: State of the Historic Environment; Historic Environment: A Force For the Future; English Heritage Strategy 2005 – 2010; East of England Plan: RSS for the East of England; St Edmundsbury Borough Council Vision 2025: Sustainable Environment Action Plan.

16. Protect, manage and EU Thematic Strategy for Soil Protection; IPPC Directive 96/61/EC – Integrated Biodiversity, Flora 10 restore soil resources Pollution Prevention and Control; EU Soil Framework Directive; PPG14; PPS23; and Fauna The UK Government Sustainable Development Strategy: Securing the Future; Landscape, Strategy for Sustainable Construction; Farming and Food Strategy, Facing the Material Assets, Future; The First Soil Action Plan for England: 2004 – 2006; Contaminated Land Soil Strategy for the Borough of St Edmundsbury; St Edmundsbury Borough Council Vision 2025: Sustainable Environment Action Plan. 17. Promote sustainable European Landscape Convention; PPS7; PPS1; Government Rural White Paper: Cultural Heritage, 13, 16, 18 use and management of Our Countryside – the future; The Countryside and Rights of Way Act; Rural Landscape, the countryside Strategy; Wildlife and Countryside Act; Suffolk Rights of Way Improvement Plan Material Assets Suffolk Countryside Strategy; State of Nature – Lowlands – Future Landscapes for Wildlife; The European Convention on the Protection of Archaeological Heritage; UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage; PPS6; PPG15; PPG16; Heritage Counts: State of the Historic Environment; Historic Environment: A Force For the Future; English Heritage Strategy 2005 – 2010; East of England Plan: RSS for the East of England. 18. Protect amenity and European Landscape Convention; PPS7; PPS1; Government Rural White Paper: Cultural Heritage, 18 landscape/townscape Our Countryside – the future; The Countryside and Rights of Way Act; Rural Landscape settings Strategy; Wildlife and Countryside Act; State of Nature – Lowlands – Future Landscapes for Wildlife; The European Convention on the Protection of Archaeological Heritage; UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage; PPS6; PPG15; PPG16; Heritage Counts: State of the Historic Environment; Historic Environment: A Force For the Future; English Heritage Strategy 2005 – 2010; East of England Plan: RSS for the East of England; Suffolk Rights of Way Improvement Plan Suffolk Countryside Strategy; St Edmundsbury Borough Council Vision 2025: Sustainable

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

No Sustainability Theme SEA Topic Relationship to SA Objectives Environment Action Plan.

19. Protect, enhance and The Johannesburg Declaration on Sustainable Development; The UN Millennium Biodiversity, Fauna 16 improve biodiversity and Declaration; Ramsar Convention; Bern Convention; Bonn Convention; EU Sixth and Flora, Climatic important wildlife Environmental Action Plan; European Biodiversity Strategy; Espoo Convention; Factors, Soil, habitats EU Biodiversity Strategy; OSPAR Biological Diversity and Ecosystems Strategy; Water UN Convention on Biological Diversity; Environmental Impact Assessment; PPG2; PPS6; PPS9; The Countryside and Rights of Way Act; The UK Government Sustainable Development Strategy: Securing the Future; Regional Environment Strategy for the East of England; St Edmundsbury Borough Council Vision 2025: Sustainable Environment Action Plan; Working with the Grain of Nature: A Biodiversity Strategy for England; Butterfly Conservation – Regional Action Plan for Anglia; Suffolk Biodiversity Action Plan; State of Nature – Lowlands – Future Landscapes for Wildlife; Wildlife and Countryside Act; The Conservation (Natural Habitats, &c.) Regulations; Regional Biodiversity Action Plan; Woodlands for Life: The Regional Woodland Strategy for the East of England; Keepers of Time – A Statement of Policy for England’s Ancient and Native Woodlands: Action Plan 2005; The Birds Directive; The Habitats Directive. 20. To promote economic The Johannesburg Declaration on Sustainable Development ; The UN Material assets, 19, 21, 22 development Population Millennium Declaration and Millennium Development Goals; A New Partnership for Cohesion – Third Report on Economic and Social Cohesion; Draft New Regulations for Renewed Structural Funds; Renewed EU Sustainable Development Strategy; PPS1; PPG4; PPS7; PPG21; Rural Strategy; Government Rural White Paper: Our Countryside; The UK Government Sustainable Development Strategy: Securing the Future; A Shared Vision – The Regional Economic Strategy for the East of England; Prioritisation in the East of England; International Business Strategy; Expanding Suffolk’s Horizons: 2004-7 – A New Economic Strategy for Suffolk; Sustainable Tourism Strategy for the East of England; St Edmundsbury Borough Council Rural Services Review Final Report and Rural Action Plan; Economic Development Strategy – St Edmundsbury; Regional Tourism Strategy; Tomorrows Tourism Today; Objective 2 Local Area Framework (2004-2005). 21. Improve the vitality of PPS1; PPS6; Our Towns and Cities: The Future – Delivering an Urban Human Health, 19, 20 towns and local centres Renaissance; Towns and Cities Strategy and Action Plan; Urban Renaissance in Landscape,

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

No Sustainability Theme SEA Topic Relationship to SA Objectives and encourage urban the East of England; The UK Government Sustainable Development Strategy: Population renaissance Securing the Future; Framework for Regional Employment and Skills Action; An Integrated Regional Strategy for the East of England; Economic Development Strategy – St Edmundsbury.

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

4. Baseline Introduction 4.1 The SEA Directive says that the Environmental Report should provide information on: ‘relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan” and the “environmental characteristics of the areas likely to be significantly affected’ (Annex I (b) (c)); and ‘any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC’ (Annex I (c)) 4.2 In addition to the requirements of the SEA Directive, the statutory SA process requires the collection of additional information on social and economic characteristics of the plan area. Baseline Data Collection 4.3 Baseline information provides the foundation for predicting and monitoring effects and helps to identify sustainability problems and alternative ways of dealing with them. Sufficient information about the current and likely future state of the plan area is required to allow the plan’s effects to be adequately predicted. 4.4 Baseline data were collected about St Edmundsbury for a range of economic, social and environmental matters, looking at the Borough as it is today and identifying current trends. These data were summarised in the Sustainability Appraisal Scoping Report (October 2006) and its updated version (April 2007). Wherever possible, these data have been updated and relevant additional information added as part of the preparation of this Sustainability Appraisal Report. The baseline data collected to date are summarised below, with more detailed information contained in Appendix A. These data have allowed the identification of key issues for the Borough (see Table 5.1) and have largely determined the indicators listed in Table 6.1, together with the comments of consultees and inputs from other Stage A tasks. These indicators will be employed to measure the effects of implementation of the Core Strategy, thus forming a key part of the overall monitoring programme for the implementation of the LDF. 4.5 Baseline data were principally developed from indicators already used by SSAG in its monitoring work and from the DCLG (formerly ODPM) guidance. There are approximately 140 different indicators on a wide range of different environmental, economic and social issues. The baseline data collected included, wherever possible, trend information, comparable data for the county, East of England or England and any performance targets set for the borough in relation to the SSAG indicators. Baseline Information Population 4.6 The ONS mid year population estimate for 2007 predicted the borough’s resident population to number 102,900 persons. 57% of the borough’s population in 2007 lived in the urban areas of Bury St Edmunds and Haverhill. Between 1991 and 2001, the population of the borough increased by 12%. This is greater than the Suffolk increase of 10% and the second greatest increase of all Suffolk’s districts. It had an estimated population density in 2002 of 150 people per square kilometre, compared to 284 for the East of England and 380 for England as a whole.

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Table 4.1 – 2001 Population and 10 year change between 1991 and 2001

Area 2001 Population 5 Change St Edmundsbury 98,193 12.1% Bury St Edmunds 35,473 13.0% Haverhill 22,010 17.8% Rural St Edmundsbury 40,710 8.4%

Source: 2001 Census

4.7 The gender split in St Edmundsbury is more even than that of the East of England and England with female residents accounting for 50.4% of St Edmundsbury’s population compared with 51.0% in the East of England and 51.3% in England at the 2001 Census. 4.8 Census data (2001) showed that the age profile of St Edmundsbury’s population was similar to Suffolk and the East of England for the younger age groups (0-15, 16-24, 25-44) but that the proportion of the population aged 45-64 was lower than county and regional figures, and the proportion of people aged 65+ was higher than for Suffolk and the East of England. The 2007 mid- year population estimates showed that the age profile of St Edmundsbury broadly reflects that of the East of England. 4.9 Within St Edmundsbury there are marked variations between the two urban centres and the rural area at both ends of the age profile. However, the central age band (25-64 years) is very similar. In the rural areas in 2001 only 27% of the population was aged 0-24 compared to 33% in Haverhill. This situation is reversed for the 65+ population where 24% of the rural population fell into this age group compared to only 17% in Haverhill. Table 4.2 – Population by age (% of total population)

Area 0 15-16 24 - 25 44 - 45 64 - 65 74 - 75+ St Edmundsbury 19.3 9.7 28.9 20.4 13.9 7.8

Bury St Edmunds 18.6 9.9 30.0 19.3 13.4 8.9 Haverhill 22.5 10.8 32.1 18.1 11.5 5.0

Rural St 18.3 9.0 26.2 22.5 15.7 8.4 Edmundsbury Suffolk 20.0 9.6 27.1 25.1 9.4 9.0 East of England 20.0 10.2 28.7 24.5 8.6 7.8

Source: 2001 Census

4.10 In St Edmundsbury the 65+ age group experienced the greatest increase between 1991 and 2001 with a 48% jump, this is more than four times the increase experienced in Suffolk and the region. Between 2002 and 2007, the growth in this age group has reduced to 15% but is still significantly higher than for the East of England. Within the borough, Bury St Edmunds experienced a 23% decrease in 16-24 year olds between 1991 and 2001 compared to a 20% and 25% fall in Haverhill and the rural area respectively. The largest increases occurred in the 65+ age group with Haverhill experiencing a 66% increase compared to 50% and 38% in rural St Edmundsbury and Bury St Edmunds respectively. 4.11 The mid-2004 population estimates from the Office of National Statistics indicate that 12.19% of the total population of St Edmundsbury are migrants. 5.19% of all people moved into the area from elsewhere in the UK compared to 0.72% of people who moved to the area from outside of the UK. The area experiences less out migration as only 4.58% of all people moved out of the area to elsewhere in the UK.

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Table 4.3 – Birth place 2001 (% of total population)

St Edmundsbury East of England England Total Population 98,193 5,388,140 49,138,831 England 90.96% 89.93% 87.44% Scotland 1.83% 1.63% 1.62% Wales 1.09% 1.01% 1.24% Northern Ireland 0.45% 0.4% 0.44% Republic of Ireland 0.62% 0.87% 0.94% Other EU Countries 1.25% 1.4% 1.41% Elsewhere 3.8% 4.75% 6.91% Source: 2001 Census Ethnicity 4.12 The population of St Edmundsbury borough is predominantly White, with 96.1% of the borough falling into this ethnic group in 2007. This is significantly higher than the average for the East of England and England as a whole, but can be seen to have decreased by almost 2% since 2001. The other main ethnic groups found within the borough are indicated in the tables below. Table 4.4 – Ethnic groups 2007 (% of total population)

St Edmundsbury East of England England White 96.1 92.2 88.6 Mixed 1.0 1.5 1.6 Asian or Asian British 1.0 3.3 5.5 Black or Black British 0.9 1.8 2.8 Chinese or Other Ethnic 1.0 1.2 1.4 Group Source: 2001 Census Table 4.5 – Ethnic groups 2001 (% of total population)

St Edmundsbury East of England England White British 94.81 91.45 86.99 White Other 3.22 3.67 3.93 Mixed 0.73 1.08 1.31 Asian or Asian British 0.47 2.26 4.58 Black or Black British 0.35 0.9 2.3 Chinese or Other Ethnic 0.42 0.65 0.89 Group Source: 2001 Census Deprivation 4.13 A National Index of Multiple Deprivation (IMD) has been produced by the Department of Communities and Local Government (DCLG) based on indicators such as education, health,

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

crime and employment used to rank relative deprivation for each local authority in England. St Edmundsbury borough was ranked as 267th in 2004, and 260th in 2007 out of the 354 local authorities, with 1 being the most deprived. Whilst the overall rank of St Edmundsbury is good, both the borough’s score and ranking declined between 2004 and 2007, indicating that the borough became more deprived in comparison with the rest of the nation during this period. The rank scores for multiple deprivation by ward indicate that in 2004 Haverhill South (formally Clements ward) was the most deprived within the borough scoring 1,132 and the least deprived ward was that of Eastgate which scored 7,805 out of the 8414 wards in the UK. Although the rank of wards such as Haverhill South skew that data the overall rank of wards within St Edmundsbury of 5215 is very high reiterating that the borough is an affluent area with few pockets of deprivation. Health 4.14 Life expectancy from birth within the borough during the period 2004-2006 was 78.6 years for males and 82.7 years for females, consistently higher than the national average and higher than St Edmundsbury’s life expectancy for previous years. 4.15 Overall residents within the borough and Suffolk as a whole are amongst the healthiest in the country. At the 2001 Census, the self-assessed health of residents of St Edmundsbury was similar to that of the East of England and better than that of England as a whole, with 70.9% of the borough assessing themselves as having good health. At ward level, no ward in the borough has a Standardised Mortality Rate (SMR) significantly higher than the Suffolk average. However, Kedington, Northgate and Haverhill South all have SMR values 25% above the pre-2003 Suffolk average whereas wards such as Cavendish, Honington and Pakenham have some of the lowest SMRs in the county. Furthermore, at the 2001 Census, the proportion of the Borough’s population with a limiting long term illness (29.9%) was similar to that for the East of England (30.8%) and lower than that for the Country (33.6%). 4.16 St Edmundsbury has a significantly lower rate of teenage conception at 25.5 rate per 1000 girls when compared to the average for Suffolk which was recorded as 31 rate per 1000 girls (2000- 2002 figures). However this overall low rate is not reflected in all wards within St Edmundsbury as St Olaves and Northgate wards both recorded high teenage conception rates of 57.7 and 53.4 respectively. Education and skills 4.17 The average percentage of year 11 students attaining 5 A*-C grades at GCSE for St Edmundsbury was above both the regional and national averages in 2007 at 70.7%. The proportion of students gaining 5 A*-C grades at GCSE in the borough is growing year on year, at approximately the same rate as England. Workforce skills 4.18 Around 36.3% of the working age population in St Edmundsbury had no qualifications in 2007. However, in the same year, 14,900 people of working age have NVQ level 4+ qualifications (degree or higher) accounting for 24.7%. The proportion of the population with NVQ 4+ qualifications increased by over 30% between 2004 and 2005 but decreased slightly between 2005 and 2007. The proportion with low/no qualifications is the highest amongst Suffolk’s districts and is more than double than the regional and national averages. The proportion of the working age population with NVQ level 4+ qualifications in St Edmundsbury is slightly higher than the county average and slightly lower than the regional average. Crime and anti social activity 4.19 The crime rate for St Edmundsbury increased considerably from 69.6 (crimes per 1000 population) in 2003-4 to 81.1 in 2005-06. However, in 2007-08, the crime rate had dropped to 69.2 crimes per 1000 population. Crime rates in St Edmundsbury are consistently slightly lower than those observed regionally and nationally. Fear of crime within St Edmundsbury is fairly constant and similar to national figures, with around 98% of the borough’s residents stating that they feel

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

fairly safe or very safe outside during the day and between 70% and 75% stating that they feel fairly safe or very safe outside after dark in 2006/07. 4.20 The rate of burglaries at 6.9 per 1000 of population in 2004-5 for St Edmundsbury is lower than the regional average of 7.5 and shows a continued decline from 9.1 in 2002-2003 to 8.4 in 2003- 2004. 4.21 The rate of violent crimes in St Edmundsbury for 2004-5 is 14.8, marginally lower than the regional average of 16.6 (per 1000 population.) 4.22 The number of noise complaints made in St Edmundsbury has increased overall between 2002 and 2006. This increase is particularly notable with regards to domestic noise. Access to services and facilities 4.23 Many parishes in the rural areas of St Edmundsbury lack essential services. For example 68% of rural areas in 2004/05 did not have a food shop or general store and 67% did not have a post office. Nonetheless, 59% had a public house and 69% had a village or community centre. However, accessibility in St Edmundsbury is improving, with increases in the percentage of rural households within 13 minutes’ walk of an hourly bus service (36% in 2005/06 compared with 23% in 2001/02) and the proportion of the population with access to hospital or GP or dentist surgery. 4.24 Analysis of access deprivation figures shows that the former Chevington ward is the least accessible in Suffolk and is ranked 43 out of 8414 wards in the country. Indeed, Clare is the only rural ward to achieve a high ranking. Even larger former rural wards such as Stanton and Barrow fell within the 15% most deprived wards in the country in terms of access. 4.25 However, despite many of the parishes lacking essential services this is less of a problem when households with cars/vans are taken into consideration. Within St Edmundsbury the percentage of households in 2001 with no car/van was 16.8 which was lower than the national average (27%) giving St Edmundsbury a rank of 281 out of 376. However this masks variations within the borough as several wards have significantly more households with no car/van such as Eastgate, where 36.4% of households had no car/van in 2001. 4.26 St Edmundsbury also promotes disability equality, and, in particular, strives to ensure that their services are accessible and responsive to different needs. The Bury St Edmunds Shopmobility scheme loans electric scooters and manual wheelchairs to people who may have difficulty walking around the town. The scheme has recently relocated and now offers more extensive services and longer opening hours. As a result, the number of people using the scheme has increased from almost 90 in April 2005 to over 140 in April 2006. All the Council documents are available in a variety of formats on request, including the production of Community Spirit (the quarterly newsletter) on audio tape/CD and a spoken version on the Council’s website. Employment 4.27 The 2001 census shows that in St Edmundsbury 45.3% of economically active people aged 16-74 were in full time employment, higher than the national average of 40.6%. Unemployment within the borough reflected this as only 2.2% of economically active people were unemployed whereas the national average was 3.4%. Within the borough St Olaves ward has the highest level of unemployment, as 4.7% of economically active people were unemployed. 4.28 By 2008, the proportion of economically active people aged 16-74 in St Edmundsbury who were unemployed had increased to 1.6%. However this figure is still lower than regional and national unemployment rates. Housing 4.29 At the time of the 2001 census there were 40,560 households with residents in St Edmundsbury. Bury St Edmunds had 15,591 and Haverhill 9017.

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

4.30 By April 2004, 43,791 dwellings were identified in St Edmundsbury of which 814 (1.9%) were vacant and 1,501 (3.4%) were classed as unfit. This level of “unfitness” was below the national average of 4.8% but slightly higher than that for the East of England (3.1%). 4.31 At present 5,800 (15.5%) dwellings are estimated to have at least one Category 1 Hazard (as identified through the Housing and Safety Rating System). Category 1 Hazards relate to hazards to the health and safety of the occupier which must be dealth with. Category 1 Hazards are associated with pre-1919 dwellings, the privately rented sector, detached houses and bungalows. There is a clear association between Category 1 Hazards and low income households and those with heads of household over 60. The highest proportion of Category 1 Hazards by area was found in the Rural sub-area at 24.8% followed by the Bury St Edmunds sub-area at 13.4%.

Table 4.6 – Housing Tenure

Housing Tenure St Edmundsbury East of England and England Wales Owner occupied :owns outright 29.8 30.7 29.5 Owner occupied: with a mortgage or 40.7 41.5 38.8 loan Rented from: council (Local Authority) 13.8 11.6 13.2

Rented from: Housing 3.4 4.9 6.0 Association/Registered social landlord Rented from: private landlord/letting 7.5 7.6 8.7 agency Rented from: other 4.4 3.2 3.2 Source: 2001 Census 4.32 The results of the 2001 census show that overall housing tenure in St Edmundsbury reflects that of the national average. However marginal differences indicate that there is a higher percentage of owner occupied households in the borough, principally with a mortgage or loan. 4.33 The most significant difference in St Edmundsbury from the national average was in the number of households that were rented from Housing Association/registered social landlord. This accounts for only 3.4% of households in St Edmundsbury compared to 6% nationally. Although this was the most apparent deviance from the national averages it was in line with trends identified throughout the east of England. This was not the case for the number of households rented from the council, where St Edmundsbury shows a higher percentage (13.8%) than that of the national average (13.2%) but more noticeably higher than that found over the East of England in general (11.6%). However, since 2001 the local authority housing stock has been transferred to the Havebury Housing Partnership. Table 4.7 – Household Composition

Household Composition Percentage % Single person 13.3% % pensioners 23.9% Married/co-habiting couple – no children 22.4% Married/co-habiting couple – with children 22.4% Lone parent with children 4.7% Source: 2001 Census 4.34 In St Edmundsbury the number of households on the housing register (the waiting list) as at 1 April 2003 was 2,813, of these, 146 households had been accepted as homeless.

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Housing Provision for Gypsies and Travellers and those with Special Needs 4.35 In 2006, there were two private and no public authorised pitches for Gypsies and Travellers. This level of pitch provision is considered to be insufficient for the borough. 4.36 The proportion of housing completions (number of units built annually) in St Edmundsbury which are appropriate for those with special needs fluctuates greatly but is commonly between 10% and 15% of all housing completions in the borough.

The quality of neighbourhoods and community participation 4.37 St Edmundsbury has a relatively high level of satisfaction for ‘residents who are happy with their neighbourhood as a place to live’. 38% of residents of the borough were very satisfied and 48% fairly satisfied (Suffolk Speaks survey) which is higher than the county average. In terms of community participation, although the turnout to local authority elections has fallen since the 1990s, there are a number of active community and residents groups operating across the borough. Parish communities have only completed nine Parish Plans. The completion or participation level in the production of these plans, which set down the thoughts of the community on local issues, is relatively poor compared with other Suffolk authorities. Landscape and biodiversity 4.38 The landscape of St Edmundsbury is a predominantly rural, with every village having a population of under 3,000 and two major towns of Haverhill and Bury St Edmunds. The borough is an area of unspoiled natural beauty with a keen sense of its rural heritage. Many villages have an important historic character, with thatched and timber framed cottages common; Clare and Cavendish are perhaps the two best known. 4.39 The borough includes one Special Protection Area (SPA) (Breckland), two Special Areas of Conservation (SAC) (Breckland and Waveney & Little Ouse Valley Fens), 23 Sites of Special Scientific Interest (SSSI), 144 County Wildlife Sites, two Local Nature Reserves (LNR) and three Country Parks. 4.40 The majority of the SSSIs in the borough are partly in an unfavourable or mixed condition. However, 20 of the 23 SSSIs are meeting their Public Service Agreement (PSA) targets (i.e. are in favourable or unfavourable but recovering condition) in over half of their areas. The SSSIs located in St Edmundsbury are listed below: • Barnham Heath • Black Ditches, Cavenham • Blo' Norton And Thelnetham Fen • Bradfield Woods • Breckland Farmland • Breckland Forest • Bugg's Hole Fen, Thelnetham • Cavendish Woods • Fakenham Wood And Sapiston Great Grove • Hay Wood, Whepstead • Hopton Fen • Horringer Court Caves • Knettishall Heath • Lackford Lakes

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

• Little Heath, Barnham • Pakenham Meadows • Shaker's Lane, Bury St. Edmunds • Stanton Woods • The Glen Chalk Caves, Bury St. Edmund's • Thetford Heaths • Trundley And Wadgell's Wood, Great Thurlow • West Stow Heath • Weston Fen 4.41 A Landscape Characterisation Study undertaken by Suffolk County Council indentified 14 landscape types within St Edmundsbury, the characters of which are distinct and individually important to the character of the Borough. These landscape types are: • Ancient plateau claylands • Estate sandlands • Plateau estate farmlands • Rolling estate farmlands • Rolling estate sandlands • Rolling valley farmlands • Rolling valley farmlands & furze • Undulating ancient farmlands • Undulating estate farmlands • Urban • Valley meadowlands • Valley meadows & fens • Wooded chalk slopes • Wooded valley meadowlands & fens 4.42 The majority of farmland in the borough is either Grade 2 or 3 which are generally considered to be the best and most versatile types of agricultural land. This agricultural land is therefore a valuable resource within St Edmundsbury. 4.43 Figure 4.1 shows the main environmental designations in the borough. .

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Figure 4.1 – Environmental Designations in St Edmundsbury

Source Multi-Agency Geographic Information for the Countryside (www.magic.gov.uk)

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Historic and archaeological environment 4.44 Bury St Edmunds is a medieval town which grew up around the gates of the Benedictine monastery founded in 1020AD. It retains a Norman town plan, in which the main streets led to the Abbey precinct. During the 14th century Bury St Edmunds developed into a prosperous market town. The Abbey was raided and torn down in the 16th century, its remnants are all around the town, standing as ruins or built into the homes of opportunistic townspeople. The Abbey gardens surround many of the ruins and are the town’s most popular attraction. Many secular mediaeval buildings such as the Guildhall still stand, but most are hidden behind elegant 17th and 18th century facades. 4.45 Haverhill is the second largest town in the borough and has the distinction of having been a market town for 950 years. Between 1851 and 1901 the town almost doubled in size producing a complete Victorian town with new houses, schools, churches and public buildings. More recently the town experienced another major growth period as a consequence of The Town Development Scheme of the 1960’s. 4.46 Within the borough there are more than 3000 listed buildings of which over 1000 are in Bury St Edmunds itself. The proportion of the listed buildings in St Edmundsbury which are at risk has decreased from 1% in 2003 to 0.5% in 2008. The borough also contained 25 Conservation Areas and 1015 properties under Article 4 Directions in 2008. Bury St Edmunds is recognised as a town of considerable archaeological importance and the remains form an essential and valuable part of Suffolk’s identity. Water and air quality 4.47 The quality of water within the borough’s rivers is generally fair to good in terms of chemical and biological quality. Despite recent improvements, the chemical quality of St Edmundsbury’s rivers is worse than the average quality of rivers in the East of England and England. 4.48 Air quality is also generally good within St Edmundsbury with no Air Quality Management Areas (AQMAs) having been designated within the borough. Flood Risk 4.49 Whilst a very low proportion of property in St Edmundsbury is at risk of flooding, Bury St Edmunds, Haverhill and many of the borough’s villages are located in river valleys. Historic evidence has demonstrated that extreme weather conditions have the potential to cause damage through flooding. However, in recent years, very few planning applications for development in flood risk areas in St Edmundsbury have been approved against Environment Agency advice. Soil resources 4.50 One method of protecting soil resources is to reduce the amount of new housing development taking place on greenfield land and focus development on previously developed land. The borough percentage of development on previously developed land is low in relation to the Government target of 60%. However the target of 40% set in the Replacement St Edmundsbury Local Plan has been exceeded in recent years, with 54.4% of dwellings completed in St Edmundsbury in 2007/8 being located on PDL. The Draft East of England Plan states that the borough has to provide 10,000 houses over the period to 2021 – it is unlikely that this can be achieved without the need to develop greenfield sites. Waste 4.51 The amount of household waste collected per head in St Edmundsbury has reduced since 2004/05 but is higher than the national mean. 4.52 In 2005/06 St Edmundsbury was the top performing council in terms of recycling and composting in the country. St Edmundsbury’s recycling rate in the first and second quarter of 2008/09 was at 54%. In 2006/07 St Edmundsbury’s recycling rate was 50.4% compared with an average of 31% across the rest of the country.

59 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

4.53 St Edmundsbury was awarded Beacon Council status in 2001 and 2006 by the Government. This award recognised that St Edmundsbury was a national leader in the field of waste management and recycling. Since then the council has been involved in helping other councils across the country to improve their recycling rates. 4.54 St Edmundsbury is also part of the Suffolk Recycling Consortium, a partnership of six Suffolk district and borough councils and Viridor Waste Management. Through the work of the consortium the total amount of waste material recycled is 36,000 tonnes per year – representing a recycling rate across the Consortium of approximately 30%. By working together with all Suffolk councils St Edmundsbury has helped achieve significant improvements in recycling rates across the county. Traffic 4.55 Traffic volumes increased year on year between 1996 and 2004 with a small decrease in 2005. It is considered that the majority of traffic is caused by an increase in car use, particularly for the journey to work. 4.56 The 2001 Census revealed that of all people in the borough aged 16 – 74 in employment 62.45% usually travel to work by driving a van or car. This is higher than the levels for both Suffolk as a whole (60.57%) and the East of England (58.87%). Commuting patterns 4.57 The 2001 Census provides the only comprehensive assessment of commuting across the whole of the country. The data shows that a large majority of people who live in St Edmundsbury also work in the borough (71%), furthermore 76% of the borough’s residents work within Suffolk and 92% work within the East of England. The district of Forest Heath has the greatest number of commuters from St Edmundsbury with over 2,200 people or 4.5% of the borough’s working age population. Outside of Suffolk the district with the greatest number of commuters from St Edmundsbury is Cambridge with 2130 commuters or 4.2% of the resident working age population, furthermore the South East Cambridgeshire area as a whole accounts for over 9% (over 4,600 people) of commuters from St Edmundsbury. Only 751 people (1.5%) commute to London from the borough and 644 (1.3%) commute outside the region. Table 4.8 – Commuting destinations from St Edmundsbury 2001

Commuting Destinations People Babergh 881 Forest Heath 2,223 Ipswich 621 St Edmundsbury 35,515 Suffolk Coastal 162 Waveney 21 Suffolk 38,012 Bedfordshire 56 Cambridgeshire 4,630 Essex 1,612 Hertfordshire 338 Norfolk 1,279 East of England 45,927

London 751

60 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Other Regions 337 Outside UK 128 Source: 2001 Census Energy consumption and climate change 4.58 St Edmundsbury’s consumption of electricity is high for domestic use. Figures indicate that average domestic energy consumption in the borough is above both that for the East of England and Great Britain with an average annual domestic energy consumption in St Edmundsbury in 2006 of 4954 kWh compared with an average of 4873 kWh for East of England and 4628 kWh for Great Britain over the same period. However, domestic energy consumption in the Borough decreased year on year between 2003 and 2006. 4.59 Average energy consumption by industry in St Edmundsbury in 2004 was slightly below that for the East of England and significantly less than figures for Great Britain. However, by 2006, average energy consumption per consumer for industrial and commercial use had risen from the 2004 figures. Despite similar increases in industrial consumption in the East of England and Great Britain, St Edmundsbury’s average consumption per consumer by 2006 was above the regional and national figures. This is likely to be a result of recent industrial growth in Haverhill. 4.60 Consumption of gas by domestic users within the borough is consistently less than the average for the East of England and Great Britain. However industrial gas consumption is relatively high. Available figures appear to show increasing consumption of gas by domestic uses over recent years. Renewable energy 4.61 There are no commercial renewable energy facilities within the borough. Carbon Dioxide emissions

4.62 Domestic CO2 emissions have decreased in St Edmundsbury but at 2.43 tonnes per capita in 2006 are comparable to regional but higher than national figures (2.48 tonnes and 2.54 tonnes respectively in 2006). Total emissions decreased between 2005 and 2003 but in 2006 rose to

above the 2004 levels. The proportion of the borough’s CO2 emissions which result from industrial and commercial operations is consistently above national figures, reflecting the industrial nature of St Edmundsbury. Business formations 4.63 The table below presents the most recent data on registrations and de-registrations and also calculates the business formation rate i.e. registrations as a % of stock. During the 1990s the rate of formations in St Edmundsbury was consistently below the regional rate. However in recent years this has changed; in 2004 St Edmundsbury’s rates were in line with the regional rate but by 2007 the formation rate in the borough had dropped to below that of the East of England.

61 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Table 4.9 – VAT registrations and De-registrations in 2007

Area Registrations De- Stocks at Net- Business registrations end of change Formation year Rate Babergh 285 235 3,650 55 7.8 Forest Heath 215 185 2,240 30 9.6 Ipswich 290 245 2,990 45 9.7 Mid Suffolk 315 265 4,325 45 7.3 St Edmundsbury 320 265 3,955 55 8.1 Suffolk Coastal 365 305 4,700 60 7.8 Waveney 245 200 3,095 45 7.9 Suffolk 2,030 1,690 24,955 335 8.1 East of England 19,720 14,695 199,630 5,025 9.9 Source: ONS Table 4.10 – VAT registrations and De-registrations in 2004

Area Registrations De- Stocks at Net- Business registrations end of change Formation year Rate Babergh 285 285 3,420 0 8.3 Forest Heath 225 235 2135 -10 10.5 Ipswich 295 270 2800 25 10.5 Mid Suffolk 320 290 3945 30 8.1 St Edmundsbury 345 280 3600 65 9.6 Suffolk Coastal 350 380 4290 -30 8.2

Waveney 230 225 2885 5 8.0 Suffolk 2050 1970 23075 80 8.9 East of England 17,580 17,495 183,675 85 9.6 Source: ONS House Prices 4.64 The average house price in St Edmundsbury in the second quarter of 2008 was £197,503. In both 2006 and 2005, St Edmundsbury was the third most expensive borough in Suffolk. House prices in the borough have increased year on year with a price increase of 2.7% between 2005 and 2006 and by 29% between 2003 and 2006, suggesting a reduction in house price growth in recent times. Table 4.11 – Housing Prices in 2006

Area Flats Terraced Semi- Detached Average detached St Edmundsbury £116,447 £151,414 £167,861 £269,508 £193,424 Suffolk £120,859 £134,232 £151,949 £254,389 £176,076

62 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

East of England £136,746 £159,782 £187,197 £294,411 £199,997 England £181,025 £155,238 £177,091 £299,023 £194,046 Source: Land Registry Table 4.12 – Short and medium term house price changes

Area 2005-06 % Change 2003-06 % Change St Edmundsbury 2.7 28.8 Suffolk 0.9 25.8 East of England 2.5 22.4 England 5.2 33.2 Source: Land Registry Housing Affordability 4.65 Housing affordability has become a key issue in recent years due to dramatic house price inflation since 2001. 4.66 The most widely used method to determine affordable housing, is the Housing Affordability ratio. This determines the affordability of housing by comparing the average house price for each housing category against average incomes. The calculation assumes a 5% deposit therefore the ratio is that of average house price multiplied by 95% to average income. The housing affordability ratio for St Edmundsbury has increased dramatically from 6.53 in 2003 to 8.86 in 2006/07 and is higher than that for the East of England. It is evident from table below that housing affordability in St Edmundsbury is poor. Table 4.13 – Housing Affordability for 1st Quarter 2006

Area Detached Semi Terraced Flats/ *Average Ratio Detached Ratio Maisonettes Ratio Ratio Ratio Babergh 11.65 7.18 6.63 4.5 8.53 Forest Heath 10.99 6.24 5.13 4.26 7.2 Ipswich 9.63 5.61 5.14 5.59 5.99 Mid Suffolk 11.69 6.78 5.79 4.29 8.35 St Edmundsbury 10.97 6.83 6.16 4.74 7.87 Suffolk Coastal 10.13 6.02 5.52 4.44 7.32 Waveney 9.5 6.69 5.52 4.64 7.07 Suffolk 10.49 6.27 5.54 4.98 7.26 East of England 10.51 6.68 5.7 4.88 7.14 England 10.53 6.23 5.46 6.37 6.83 *The average column represents housing affordability across all housing groups.

Source: Suffolk Observatory 4.67 However 25% of housing completions in St Edmundsbury in 2007/08 were for affordable housing, compared with the East of England where the proportion of housing completions which are affordable is consistently below 20%.

63 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Economic Activity and Employment Rates 4.68 The economically active population includes those people who are employed, self-employed, unemployed and some students. In St Edmundsbury there is an economic activity rate (EAR) of 83.8% (51,000 people). St Edmundsbury’s EAR is significantly greater than the county and regional average and the fourth highest in the county. 4.69 The employment rate is defined as the proportion of the working age population in employment. As with economic activity, St Edmundsbury has the third highest rate amongst the districts in Suffolk (after Babergh and Forest Heath) at 82.1%. Table 4.14 – Economic Activity and Employment Rates

Area Economic Activity Rate (%) Employment Rate (%)

Babergh 85.9 84.8 Forest Heath 86.7 82.5 Ipswich 79.7 75.1 Mid Suffolk 81.8 79.8 St Edmundsbury 83.8 82.1 Suffolk Coastal 79.7 78.8

Waveney 78.8 76.1 Suffolk 81.8 79.4 East of England 82.0 78.9 Source: Labour Force Survey Employment Structure 4.70 In 2004 there were 51,515 people in employment in St Edmundsbury. Bury St Edmunds accounts for 58% of total employment and Haverhill 17%. The three largest sectors in the borough (public, manufacturing and distribution) account for 73% of total employment. In 2006, these sectors accounted for 72% of total employment, showing that the proportion of people employed in public, manufacturing and distribution sectors is relatively stable. There are major differences in employment between the borough’s principal urban areas of Bury St Edmunds and Haverhill. Haverhill is more industrial in nature with more than three times the proportion of manufacturing employment compared to Bury which is dominated by public sector employment accounting for almost one third of total employment. Table 4.15 – Employment by sector, 2004

St Edmundsbury Bury St Edmunds Haverhill Number % Number % Number % Agriculture 741 1.4 5 0 0 0 Energy - - 266 0.9 0 0 Manufacturing 9369 18.1 3338 11.2 3234 36.2 Construction 2387 4.6 1232 4.1 324 3.6 Distribution 12854 24.8 8088 27 1948 21.8 Transport 1697 3.3 674 2.3 401 4.5 Banking 6937 13.4 3994 13.4 1241 1241

64 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Public Administration 15478 29.9 11076 37 1445 16.2 Other 2052 4 1243 4.2 339 3.8 Total 51515 100 29916 100 8932 100 Source: Annual Business Inquiry 4.71 Total employment in St Edmundsbury (across all sectors) increased by 9.4% between 1998 and 2004. This is higher than both the regional and county averages. Changes in employment by sector vary significantly within St Edmundsbury (see table below). St Edmundsbury experienced major growth in two sectors between 1998 and 2004; banking, finance and insurance (53.5% increase) and public administration, education and health (22.4% increase). However, between 2004 and 2006, the growth in these sectors was negligible, and the greatest growth rate was observed in the construction (8.7%) and transport and communications (6.1%) sectors. Manufacturing has continued to decline although at a slower rate in recent years, registering a 19.8% fall in employment between 1998 and 2004 and a 4.4% fall between 2004 and 2006. Whereas between 2004 and 2006, the agriculture and fishing sector registered the largest reduction (7.1%), the most significant fall between 1998 and 2004 was experienced in energy and water which fell by 38.4%

Table 4.16 – Sector growth within St Edmundsbury 2004-2006

Sector Sector % Change ('04 to ‘06) Agriculture and Fishing -7.1 Energy and Water Data not available Manufacturing -4.4

Construction 8.7 Distribution, hotels and restaurants 0 Transport and communications 6.1

Banking, finance and insurance, etc -0.8 Public Administration, education and health 0.3 Other 7.5 Source: Calculated from historic SEBC Annual Monitoring Reports Table 4.17 - Sector growth within St Edmundsbury 1998-2004

Sector Sector % Change ('98 to '04)

Agriculture and Fishing -0.9

Energy and Water -38.4

Manufacturing -19.8 Construction 14.7

Distribution, hotels and restaurants 4.6

Transport and communications 0.2

Banking, finance and insurance, etc 53.5 Public Administration, education and 22.4 health Other 1.5 Source: Annual Business Inquiry

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Unemployment 4.72 In recent years St Edmundsbury, along with most areas in the UK, has experienced historically low unemployment rates. In July 2008, 1.6% of the population of St Edmundsbury was unemployed. Despite an increase in recent years, unemployment levels for St Edmundsbury remain well below regional and national levels. Haverhill has significantly higher unemployment than the rest of the borough. Table 4.18 – Unemployment rate within St Edmundsbury June 2006

Area Rate (%) St Edmundsbury 1.7 Bury St Edmunds 1.8 Haverhill 2.8 Rural St Edmundsbury 0.9 Babergh 1.3 Forest Heath 1.1 Ipswich 3.5 Mid Suffolk 1.1 Suffolk Coastal 1.1 Waveney 3.3 Suffolk 2.0 East of England 2.0 Source: ONS Earnings 4.73 Gross average earnings in St Edmundsbury in 2005 were £449 per week. The borough’s earnings are significantly lower than the county and regional averages. However earnings increased by 5.9% between 2004 and 2005, above the county average of 3%. This growth was also significantly better than growth at regional and national level at 3% and 3.8% respectively. 4.74 Gross median weekly earnings have also increased from in £318 in 2002 to £421 in 2007 but are also below regional and national median earnings. 4.75 The earnings figures in the table below relate to gross earnings for full-time employees. Table 4.19 – Average Earnings for 2005

Area Gross Weekly Pay (£) Hourly Pay (£)

Babergh 429 10.75

Forest Heath 434 10.67

Ipswich 456 11.57

Mid Suffolk 420 10.05

St Edmundsbury 449 11.14

Suffolk Coastal 488 11.62

Waveney 375 9.28

Suffolk 443 10.93

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East of England 512 12.8

Great Britain 519 13.18 Source: Suffolk Observatory

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5. Key Sustainability Issues Introduction 5.1 The identification of the key sustainability issues most relevant to the Core Strategy has been based on the review of relevant plans and programmes documented in Section 4, the analysis of the baseline data documented in Section 5 and Appendix A, and a consideration of issues likely to be addressed in the Core Strategy. 5.2 Table 5.1 presents the full results of the analysis of key sustainability issues, which are briefly summarised as: • Significant Historic and Future Population Growth; • Relatively Low Education and Qualification Attainment; • Localised Deprivation; • Fluctuating Crime Rate; • Insufficient Amount of Housing, including Affordable Housing and High Levels of Unfit Dwellings; • Lack of Accommodation Provision for Gypsies and Travellers; • Earnings below Regional Figures; • Increase in Noise Complaints; • Pressure on Rich Biodiversity; • Presence of Sites Designated for their Geological/ Geomorphological Value; • Pressure on Landscape; • Rich Archaeology and Cultural Heritage; • Need to Improve Water Quality; • Pressure on Water Resources; • Comparatively High Levels of Waste Arisings; • Potential for Flood Risk; • Need to Adapt to Changing Climate; • High Energy Consumption;

• High CO2 Emissions per Capita; • Need to Preserve Valuable Land and Soil; • Presence of Contaminated Land; • Low Completions on Previously Developed Land; • High traffic volume and reliance on private car; • Changing Employment Sectors; and • Fluctuating Business Formation Rates. .

St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Table 5.1 – Key Sustainability Issues

No Key Issues Implications and Opportunities for Core Strategy SEA Topic SA Objective SOCIAL ISSUES

1. Significant Historic and Future Population Growth Population 4, 5, 6, 7 The population of St Edmundsbury has grown Opportunity for the Core Strategy to ensure that likely significantly over the past two decades (by 16.9%). future population growth is supported by the provision This growth is expected to continue, particularly with of sufficient additional housing, employment the identification of Bury St Edmunds as a key opportunities and services to ensure that the borough centre for development and change in the East of grows in a sustainable manner. England Plan (Policy BSE1).

Opportunity for the Core Strategy to ensure that new Historic growth in the number of older people in the developments are appropriate for all sectors of the Borough (+14.7% over 2002-07) has been population, particularly older people. significantly higher than that experienced in the East of England as a whole (+8.8% over 2002-07). However, the age profile of St Edmundsbury broadly reflects that of the East of England. Opportunity for the Core Strategy to ensure that 43% of the borough’s population live in rural areas. development in rural areas is sustainable through This is an unusually high proportion (23% of ensuring sufficient provision of new housing, England’s population live in rural areas), and reflects employment and services to meet the needs of local the largely rural nature of the borough. people while at the same time protecting the open countryside. New development should also aim to promote sustainable transport modes.

2. Relatively Low Education and Qualification Attainment Population 2 The percentage of St Edmundsbury’s population Opportunity for the Core Strategy to ensure that with no qualifications is more than double the figures sufficient high quality educational facilities are included for the East of England and England. within proposed developments and that accessibility to educational facilities is enhanced. 3. Localised Deprivation

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Deprivation in St Edmundsbury is increasing, with Opportunity for the Core Strategy to reduce deprivation Population, 1, 2, 4, 5, 20 the borough’s IMD rank having decreased from 267 through the provision of appropriate housing and job Human Health in 2004 to 260 in 2007. However, deprivation is not opportunities which suit the skills of the local workforce. evenly located throughout the borough. The IMD The Core Strategy should also ensure that sufficient rankings show that LSOAs in Haverhill are more education and health facilities are included within consistently deprived; suggesting that deprivation in proposed developments, particularly those located in Haverhill is more widespread rather than just rural areas where service provision is less extensive. concentrated in small pockets. Furthermore, levels of deprivation in the rural areas of St Edmundsbury have increased both relative to elsewhere in England and in terms of actual scores.

4. Fluctuating Crime Rate Trend data shows a fluctuating crime rate in the Opportunity for the Core Strategy to ensure that the Population, 3 borough. Although a significant reduction in crime recent drop in crime rates continues through the Human Health was observed between 2005/06 and 2007/08, prior designing out of crime. This could be achieved by to this the borough had experienced an increasing measures such as the mixing of house types and sizes, crime rate trend. the appropriate location of public and private open space and the network of routeways, particularly for non-motorised users, incorporating natural surveillance considerations.

5. Insufficient Amount of Housing, including Affordable Housing and High Level of Unfit Population, 4, 7 Dwellings Opportunity for the Core Strategy to ensure that Material Assets Although the number of housing completions in St sufficient provision is made for the additional housing Edmundsbury in 2006/07 was above the H1 policy required to meet the targets set by policy H1 of the target included in the East of England Plan, in East of England Plan. previous years the number of completions has not reached the target level.

The uptake of housing benefits has steadily Opportunity for the Core Strategy to encourage the increased since 2003, suggesting that there is provision of affordable housing through the inclusion of insufficient affordable housing available within St a policy detailing a required proportion of new Edmundsbury. Furthermore, the housing developments to be affordable. There is a need for the affordability ratio of the borough has increased Core Strategy to ensure that housing supply matches steadily since 2003, indicating major housing projected demand both in terms of numbers and type.

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affordability problems, particularly as a result of year-on-year increases in house prices.

6. Lack of Accommodation Provision for Gypsies and Travellers Population, 7 St Edmundsbury had 2 gypsy and traveller pitches Opportunity for the Core Strategy to include a policy Human Health, in 2006. As such, the borough is not on track to setting out the Council’s requirement for gypsy and Material Assets reach its East of England Policy H4 target which traveller pitch provision. requires 17 pitches in St Edmundsbury by 2011.

7. Earnings below Regional Figures 4, 6 Whilst average earnings within St Edmundsbury Opportunity for the Core Strategy to promote the Population, have increased over recent years, they are still creation of an environment appropriate for attracting Human Health, below figures for the East of England and England. investors into the borough. Opportunity for the Core Material Assets Furthermore, median wage figures indicate that Strategy to encourage higher paid employment there are an above average number of low paid jobs opportunities whilst ensuring that the created jobs are in the borough. appropriate for the skills of the resident population. 8. Increase in Noise Complaints 1, 3 The number of noise complaints made by residents Opportunity for the Core Strategy to ensure that noisy Population, of and visitors to the borough has increased overall land uses are located away from residential areas. Human Health between 2002 and 2006. This increase is Opportunity for the Core Strategy to promote the use of particularly notable with regards to domestic noise. landscaping and attenuation bunds to reduce the impact of noise-creating activities. ENVIRONMENTAL ISSUES

9. Pressure on rich Biodiversity St Edmundsbury contains a number of sites Opportunity for the Core Strategy to ensure that the Biodiversity, 8, 16 designated for their internationally important habitats and species of the large number of designated Flora, Fauna ecology. These are: sites within the borough are protected from destruction • Breckland SPA; and loss and, where possible, are enhanced. The settings of the sites should be safeguarded and nearby • Breckland SAC; and developments should be screened to reduce the visual impact. • Waveney & Little Ouse Valley Fens SAC.

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The borough also contains a number of SSSIs, National Nature Reserves, County Wildlife Sites, Opportunity for the Core Strategy to promote the Local Nature Reserves and Country Parks. Although designated sites for their amenity and recreational these sites are considered to be of significant value through the encouragement of appropriate ecological value, their integrity, and the habitats and interpretation or visitor provision. species that they support are under pressure from the high level of development required in order to meet growth targets set within the East of England Plan.

The majority of the ecological SSSIs in the borough are partly in an unfavourable or mixed condition with 2 of the Borough’s 23 SSSIs wholly in an unfavourable and deteriorating condition.

There are a large number of designated BAP habitats and species in Suffolk, many of which will be present in St Edmundsbury. It is necessary that any permitted development does not detrimentally affect these habitats and species.

10. Presence of Sites Designated for their Geological/ Geomorphological Value St Edmundsbury Borough contains two geological Opportunity for the Core Strategy to ensure that the Soil, Landscape 8, 16 SSSIs (Thetford Heaths and Breckland Forest) and geology of the designated sites within the borough is one Regionally Important Geological Site near protected from destruction and loss and, where Thelnetham. Whilst available data suggests that the possible, is enhanced. The settings of the sites should condition of these sites is favourable at present, also be safeguarded. pressures from development may put the condition of the sites at risk. Opportunity for the Core Strategy to promote the designated sites for their amenity and recreational vale through the encouragement of provision of visitors’ centres and educational facilities at the sites.

11. Pressure on Landscape The borough contains 14 landscape types, the Opportunity for the Core Strategy to encourage the

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characters of which are distinct and individually preservation of the borough’s distinct landscape types Landscape 18 important to the character of the Borough. in order to ensure that the integrity and high landscape Development pressures (e.g. suburbanisation, value of St Edmundsbury is not lost. transport and industrial developments, agricultural rationalisation and tourism related development) as a result of past and projected future development The quality of the wider settings of the landscape types within the borough have placed, and are likely to should be preserved and enhanced with sympathetic continue to place significant pressure on the development adjacent to designated sites which blends landscape of St Edmundsbury. These landscape with the environment. types are: • Ancient plateau claylands • Estate sandlands • Plateau estate farmlands • Rolling estate farmlands • Rolling estate sandlands • Rolling valley farmlands • Rolling valley farmlands & furze • Undulating ancient farmlands • Undulating estate farmlands • Urban • Valley meadowlands • Valley meadows & fens • Wooded chalk slopes • Wooded valley meadowlands & fens

12. Rich Archaeology and Cultural Heritage St Edmundsbury contains over 3,000 listed buildings Opportunity for the Core Strategy to require continued Cultural 17 and a large number of historic parks and gardens, protection of sites designated for their archaeological, Heritage

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scheduled monuments, conservation areas and historical and cultural value, particularly against Article 4 Directions. It is vital that these valuable pressures from development. The settings of these assets continue to be protected. sites should also be safeguarded. The Core Strategy should consider opportunities to conserve and rejuvenate historic features and places. Careful consideration should also be given to non-designated historic features. 13. Need to Improve Water Quality The proportion of St Edmundsbury’s rivers that were Opportunity for the Core Strategy to promote the Water 9 assessed as having good chemical water quality in inclusion of Sustainable Urban Drainage Systems 2005 was higher than in 2004 and 2003. However, (SUDS) on new developments, thereby helping to the chemical quality of St Edmundsbury’s rivers is improve local water quality and reduce flood risk. worse than the average quality of rivers in the East of England and England. The biological water quality of the rivers in St Edmundsbury is higher, however, with none of the boroughs rivers being assessed as having poor or bad biological quality in 2004 and 2005.

14. Pressure on Water Resources The level of development required by the East of Opportunity for the Core Strategy to promote, as an Water, 11, 15 England Plan, and the population growth that this is integral part of new developments, the inclusion of Population likely to cause, will dramatically increase the measures which reduce the demand for water. Such pressure on existing water resources. These schemes include water conservation measures, such resources are already strained given that the as grey water recycling and water storage amount of rainfall received in the East of England is mechanisms, and should be considered where there is significantly less than for other parts of the UK, and unlikely to be any material conflict with residential is likely to decrease as a result of projected climate amenity, human health or the wider protection of the change. environment. The Core Strategy should promote achieving Code for Sustainable Homes level 3 at minimum for residential dwelling or BREEAM (‘Very Good’/’Excellent’ standard) for non-residential development. This will help ensure that water efficiency measures form part of the development design.

15. Comparatively High Levels of Waste Arisings

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The amount of household waste collected per head Opportunity for the Core Strategy to promote the use of Material Assets 12 in St Edmundsbury has reduced since 2004/05 but sustainable construction techniques, using recycled is higher than the national mean. The volume of materials where possible. This will reduce the waste municipal waste produced has reduced by a generated by redevelopment which contribute both to significant amount since 2002/03 the cost of the build and also to the degradation of the local environment.

16. Potential for Flood Risk Whilst a very low proportion of property in St Opportunity for the Core Strategy to reduce the Climatic 15 Edmundsbury is at risk of flooding, Bury St susceptibility of developments within the borough to Factors, Water Edmunds, Haverhill and many of the borough’s flooding through the location of proposed new villages are located in river valleys. Historic development on land outside of Flood Zones 2 and 3. evidence has demonstrated that extreme weather Where development is likely to result in increased conditions have the potential to cause damage surface water run-off and flooding, the Core Strategy through flooding. should require that suitable flood mitigation or alleviation measures, including SUDS, be implemented in order to overcome the flood risk. 17. Need to Adapt to a Changing Climate The main expected climate changes in the Opportunity for the Core Strategy to ensure that Climatic Factors 15 East of England are likely to include: communities, developments and infrastructure (e.g. the road and rail networks) within the borough are adapted • Increases in temperatures (hotter summers, to cope with forecasted changes in climate. milder winters); • Increases in seasonality (e.g. dryer summers, wetter winters); • Increases in the intensity and frequency of storm events (e.g. extreme rainfall event leading to fluvial/groundwater flooding).

18. High Energy Consumption Average annual electricity consumption figures for Opportunity for the Core Strategy to encourage the Material Assets 9, 14 St Edmundsbury show a decrease in domestic location of renewable energy facilities within the electricity consumption and an increase in industrial borough, particularly through the inclusion of micro- energy consumption since 2003. Figures also renewable energy generation on site as an integral part

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indicate that average domestic and industrial energy of large developments. consumption in the borough is above both that for The Core Strategy should promote achieving Code for the East of England and GB. Sustainable Homes level 3 at minimum for residential dwelling or BREEAM (‘Very Good’/’Excellent’ standard) Domestic gas consumption is below figures for East for non-residential development. This will help ensure of England and GB. However, industrial gas that energy efficiency measures form part of the consumption is relatively high. development design.

There are no commercial renewable energy facilities within the borough.

19. High CO2 Emissions per Capita

Per capita domestic CO2 emissions in St Opportunity for the Core Strategy to promote cleaner Climatic Factors 14 Edmundsbury (2.43 tonnes) are slightly lower than manufacturing industries and other employment regional (2.48 tonnes) and national figures (2.54 sectors as an alternative to existing industry within the tonnes). However, total CO2 emissions per capita in borough. 2006 (13.44 tonnes) increased from 2005 level Opportunity to promote renewable, low carbon energy (12.10 tonnes) and are higher than regional and technologies and energy efficiency measures within the national figures, as a result of the industrial nature of borough. Promotion of achieving Code for Sustainable the borough. Recent increases in total emissions in Homes level 3 at minimum for residential dwelling or St Edmundsbury are likely to be as a result of BREEAM (‘Very Good’/’Excellent’ standard) for non- industrial growth in Haverhill. residential development will help minimise CO2 emissions from new development. Further opportunity for the Core Strategy to assist with the reduction in CO2 emissions through the provision of low carbon sustainable transport networks as an alternative to the private car. Specifically the Core Strategy should promote an increase in public transport infrastructure and services as an integral part of new large-scale development to ensure that there is a realistic alternative to the private car. The location of new development with respect to existing and proposed sustainable transport networks can assist with the reduction of CO2 emissions. 20. Need to Preserve Valuable Land and Soil

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The majority of farmland in the borough is either Opportunity for the Core Strategy to reduce the loss of Soil, Landscape 10 Grade 2 or 3 which are generally considered to be valuable agricultural land through the promotion of the best and most versatile types of agricultural brownfield sites and those located on poor quality land land. The high level of growth in St Edmundsbury as preferable sites to those located on Grade 2 and 3a required by the East of England Plan is likely to agricultural land and through the promotion of higher result in the loss of some of this valuable land. density developments.

21. Presence of Contaminated Land Despite recent remediation, there exist a large Opportunity for the Core Strategy to reduce the area of Landscape, Soil, 10 number of potentially contaminated sites within St potentially contaminated land within the borough Material Assets Edmundsbury. Contamination of land is an through the promotion of brownfield sites for important issue in the use of previously developed development. If contaminated, these sites will require land. Removing contamination through the remediation prior to development, thereby reducing development process helps reduce the take-up of threats posed by contamination to health and the greenfield sites and also diminishes the threats environment. posed by contamination to health, safety and the environment.

22. Low Completions on Previously Developed Land Whilst St Edmundsbury regularly meets its target of Opportunity for the Core Strategy to maintain the Landscape, Soil, 18 40% of completions on PDL, this target is proportion of completions located on PDL through the Material Assets significantly lower than that for the East of England promotion of brownfield sites for development. as a whole. The proportion of completions on PDL is However, it is understood that the level of development likely to decrease in the future if St Edmundsbury is that is required for the borough means that a significant to achieve the high level of growth required by the proportion of the development will need to be located East of England Plan. on greenfield land. 23. High traffic volume and reliance on private car Traffic volumes within St Edmundsbury are high, Opportunity for the Core Strategy to reduce existing Air, Human 9, 21 with the proportion of journeys to work in the high traffic volumes and reliance on private car through Health borough being undertaken by car being significantly the creation of a sustainable integrated transport higher in 2001 than that for the East of England and network which services Bury St Edmunds, Haverhill England. The proportion of journeys to work and the smaller market towns within the borough. undertaken by public transport in the borough is significantly lower than that for the East of England and England. Further opportunity for the Core Strategy to reduce the number of miles travelled in the personal car through the location of new development in close proximity to

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Available data suggests that the distance that existing services, amenities and facilities. Any transport residents of St Edmundsbury commute to work is networks or services required by the new significantly higher than the national mean. developments should be fully integrated with the existing transport network. Opportunity for the Core Strategy to enhance the attractiveness of the borough for investment and new business and employment opportunities in order to reduce the need for residents to commute to outside the borough for work.

ECONOMIC ISSUES 24. Changing Employment Sectors The proportion of St Edmundsbury’s population Opportunity for the Core Strategy to ensure that the Material Assets 19, 22 employed in agriculture and manufacturing is borough is attractive for businesses which require declining. There are major differences in prominent workers who have similar skills to those required in employment sectors within the borough. Haverhill is agriculture and manufacturing and that the problems industrial in nature with more than three times the associated with the decline in agriculture and proportion of manufacturing employment compared manufacturing are minimised, particularly in Haverhill. to Bury which is dominated by public sector As part of this, the Core Strategy should enlarge the employment, accounting for almost one third of total employment base of the borough, in order to safeguard employment. its economy and the financial security of its residents from fluctuations in the job market. 25. Fluctuating Business Formation Rates The business formation rate in St Edmundsbury Opportunity for the Core Strategy to ensure that the Material Assets 19 fluctuates but is broadly similar to that of East of borough is attractive for investment and new England. The business formation rate in 2006 and businesses through the provision of high quality 2007 was lower than that observed between 2001 business developments of appropriate size and type to and 2004. suit the employment needs of the borough.

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6. Sustainability Appraisal Framework Introduction 6.1 The SA Framework is a key component in completing the SA through synthesising the baseline information and sustainability issues into a systematic and easily understood tool that allows the assessment of effects arising from the implementation of the Core Strategy in key areas. Although the SEA Directive does not specifically require the use of objectives or indicators in the SEA process, they are a recognised and useful way in which social, environmental and economic effects can be evaluated and compared at key stages of the Strategy’s development. 6.2 The SA Framework comprises a list of objectives. Progress toward achieving these objectives will be measured using the corresponding indicators. The purpose of the SA Framework is to provide a set of criteria against which the performance of the Core Strategy can be predicted and evaluated. St Edmundsbury Core Strategy SA Framework 6.3 An SA Framework has been developed using an iterative process, based on the review of relevant plans and programmes, the evolving baseline, analysis of key sustainability issues and consideration of which of these issues can potentially be addressed by the Core Strategy. It also has been based on the SEA Framework prepared by the Suffolk Sustainability Appraisal Group for all Suffolk authorities to use and adapt in their SA work. The SA Framework is presented in Table 6.1. 6.4 It is considered that the 22 objectives listed in Table 6.1 adequately address the matters required to be considered in the SA. Amendments have been made to the overall framework since the publication of the Core Strategy Preferred Options and Strategic Sites Issues and Options SAR in November 2008. These reflect the comments received from consultees and have been finalised following internal Council discussion relating to the key priorities for St Edmundsbury. 6.5 The SA Framework developed for the St Edmundsbury Core Strategy includes a series of carefully selected indicators which provide a clarification of the intended interpretation of each objective.

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Table 6.1 – SA Framework

No Objective Detailed decision making Indicator criteria Social Objectives

1. To improve the Will it improve access to high Proportion of population with access to hospital or GP or dentist surgery health of the quality, health facilities? population overall and reduce health Will it reduce health inequalities % of people who describe their health as not good inequalities and death rates? % of people who describe their health as good Overall death rate by all causes per 100,000 population

Cancer (Malignant neoplasm’s) deaths under 75 per 100,000 population Heart disease deaths under 75 per 100,000 population Respiratory disease deaths (all ages) per 100,000 population Deaths from self harm and injury undetermined per 100,000 population

Number of people killed and seriously injured (KSI) in road traffic accidents (RTA) per 100,000 population Life expectancy (years) Will it encourage healthy Proportion of journeys to work on foot or by cycle lifestyles? How do children travel to school? Obesity in the population Change in existing provision of outdoor playing space (youth and adult space) Change in existing provision of children's play space Change in provision of open space % of footpaths and other rights of way which are easy to use by members of the public

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Change in amount of accessible natural green space (Districts) Participation in sport and active recreation (National Indicator 8)

2. To maintain and Will it improve qualifications and % of year 11 pupils gaining 5+ A*-C grades at GCSE improve levels of skills of young people? education and skills Average point score per student at A and AS level in the population Will it improve qualifications and Proportion of the population with no qualifications overall skills of adults? Working age population with NVQ level 4 or higher

3. To reduce crime and Will it reduce actual levels of Crime rate per 1000 population anti-social activity crime? Burglary Rate per 1000 population Violent Crime Rate per 1000 population Will it reduce the fear of crime? Fear of Crime Will it reduce noise and odour Number of domestic and commercial noise complaints concerns? Number of odour complaints

4. To reduce poverty Will it reduce poverty and social Proportion of the population who live in wards that rank within the most deprived and social exclusion exclusion in those areas most 10% and 25% of wards in the country affected? Number of housing benefit recipients in St Edmundsbury borough

5. To improve access to Will it improve accessibility to Percentage of rural population living in parishes which have a food shop or general key services for all key local services? store, post office, pub, primary school and meeting place sectors of the population Percentage of rural households within 15 minutes’ walk of an hourly bus service Proportion of population with access to key local services e.g. GP, post office

Will it improve accessibility to New Retail Floor Space in Town Centres shopping facilities? Proportion of population with access to a food shop Will it improve access to Number of child care places per thousand children under 5

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childcare?

6. To offer everybody Will it reduce unemployment Unemployment rate – (%) unemployed persons the opportunity for overall? rewarding and satisfying Will it reduce long-term Long-term unemployment employment unemployment? Will it provide job opportunities Proportion of lone parents and long term-ill who are economically active for those most in need of employment? Will it help to improve earnings? Average Earnings

7. To meet the housing Will it reduce homelessness? Homelessness Numbers requirements of the whole community Will it provide enough housing? Housing Stock Housing Land Availability

Will it increase the range and Affordable Housing completions affordability of housing for all social groups? Special Needs Housing Number of homes managed by Registered Social Landlords Dwellings per hectare of Net Developable Area Average property price and Housing Affordability Percentage of vulnerable persons living in non-decent homes

8. To improve the Will it improve the satisfaction of % of residents who are happy with their neighbourhood as a place to live quality of where people with their neighbourhood people live and to as a place to live? encourage community Will it increase access to natural Area of land managed in whole or part for its ecological interest and with public participation green space? access over and above public rights of way Areas of deficiency in terms of natural green space Change in amount of accessible natural green space

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Will it encourage engagement in Electoral turnout in local authority elections decision making? Number of Parish Plans completed

Will it increase the number of Number of people involved in volunteer activities people involved in volunteer activities? Will it improve ethnic relations? Number / rate of racist incidents

Will it improve access to cultural Number of visits to/uses of Council funded or part-funded museums per 1,000 facilities? population

Number of visits to Council funded or part-funded museums that were in person per 1,000 population The number of pupils visiting museums and galleries in organised school trips Percentage of adults who have either attended an arts event or participated in an arts activity at least three times in the past 12 months (NI 11 Engagement in the arts)

No Objective Detailed decision making Indicator (source) criteria

Environmental Objectives 9. To improve water Will it improve the quality of Water quality in rivers and air quality inland waters? Groundwater quality Will it improve air quality? Have annual mean concentrations of any key air pollutants been exceeded? Number of Air Quality Management Areas and dwellings affected

10. To conserve soil Will it minimise the loss of Number and percentage of new dwellings completed on greenfield land resources and quality greenfield land to development? Dwellings per hectare of net developable area

Will it minimise loss of the best Allocations on best and most versatile agricultural land (grades 1, 2, and 3a) and most versatile agricultural

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land to development? Will it maintain and enhance Number of potential and declared contaminated sites returned to beneficial use soil quality? Number / area of organic farms (ha)

11. To use water and Will it promote sustainable use Recycled aggregate production mineral resources of minerals? efficiently, and re-use and recycle where Will it promote sustainable use Daily domestic water use (per capita consumption, litres) for St Edmundsbury possible of water? Will it maintain water Water availability for water dependent habitats availability for water dependant habitats?

12. To reduce waste Will it reduce household Household and municipal waste produced waste?

Will it increase waste recovery Tonnage / proportion of household (and municipal) waste recycled, composted and and recycling? landfilled

13. To reduce the effects Will if effect traffic volumes? Traffic volumes in key locations of traffic on the environment Will it reduce the need for local Percentage of all new residential development taking place in major towns, other travel? towns, and elsewhere Percentage of rural population living in parishes which have a food shop or general store, post office, pub, primary school and meeting place Distance to key services

Will it increase the proportion Percentage of journeys to work undertaken by sustainable modes of journeys made using modes other than the private car? Percentage of schoolchildren travelling to school by sustainable modes Car parking standards (the number of spaces per development)

14. To reduce Will it reduce emissions of Consumption of electricity - Domestic use per consumer and total commercial and contributions to green house gases by industrial use climate change reducing energy consumption? Consumption of gas - Domestic use per consumer and total commercial /industrial use

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Energy efficiency Local Authority Housing stock

GHG emissions by sector and per capita emissions - proportion and absolute quantity in tonnes per year (Defra Statistics on CO2 emissions for local authority areas) Percentage of buildings achieving desired rating against national building standards such as Code for Sustainable Homes (all new dwellings meeting Code level 3 by 2010, Code level 4 by 2013 and Code level 6 by 2016) or BREEAM (‘Very Good’/’Excellent’ standard).

Percentage of new development which sources a percentage of energy from low carbon or renewable sources: i. Onsite; ii. Offsite. Number of properties receiving grants to increase energy efficiency in their homes (e.g. from Carbon Emissions Reductions Target Scheme or the Warm Front Scheme) Will it increase the proportion Renewable energy generation: installed generating capacity. of energy needs being met by renewable sources?

15. To reduce Will it minimise the risk of Flood Risk – Planning applications approved against Environment Agency advice vulnerability to flooding to people and property climatic events from rivers and watercourses? Properties at risk of flooding from rivers Incidence of fluvial flooding (properties affected)

Will it reduce the risk of Incidence of flood watches and warnings damage to people and property from storm events? 16. To conserve and Will it maintain and enhance Change in number and area of designated ecological sites enhance biodiversity sites designated for their and geodiversity nature conservation interest Condition of CWS (new National Indicator 197) statutory: SSSIs, SPA, SAC, LNRs and non-statutory: County Wildlife Sites (CWS)?

Will it avoid disturbance or Reported condition of ecological SSSIs

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damage to protected species Development proposals affecting protected species outside protected areas and their habitats? Will it help deliver targets and Achievement of Habitat Action Plan targets action for habitats and species within the Suffolk Biodiversity Achievement of Species Action Plan targets Action Plan (BAP)? Development proposals affecting BAP habitats outside protected areas

Will it help to reverse the Bird survey results national decline in farmland birds?

Will it protect and enhance Change in number and area of designated geological SSSIs and Regionally Important sites, features and areas of Geological/Geomorphological Sites (RIGSs) geological value in both urban and rural areas? Reported condition of geological SSSIs and RIGSs 17. To conserve and Will it protect and enhance Number of listed buildings and buildings at risk where appropriate sites, features and areas of enhance areas of historical and cultural value in Area of historic parks and gardens historical and both urban and rural areas? Number and area of Conservation Areas (CAs) and Article 4 directions archaeological importance Number of Conservation Area Appraisals (CAAs) completed and enhancement schemes (in conservation areas) implemented Will it protect and enhance Number of Scheduled Ancient Monuments (SAMs) damaged as a result of sites, features and areas of development archaeological value in both urban and rural areas? Number of applications affecting known or unknown archaeological site but judged of high potential and approved with conditions requiring prior excavation or recording during development

18. To conserve and Will it reduce the amount of Number and percentage of new dwellings completed on previously developed land

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enhance the quality derelict, degraded and Number and percentage of existing housing commitments on previously developed and local underused land? land distinctiveness of landscapes and Number of vacant dwellings townscapes Will it improve the landscape Landscape condition specified in landscape character assessments and/or townscape? Number / area of town / village greens and commons Area of Designated Landscape, Historic Parks and Gardens Number of Countryside Stewardship / Environmental Stewardship schemes

Light pollution Number of planning applications refused for reasons due to poor design

No Objective Detailed decision making Indicator (source) criteria Economic Objectives

19. To achieve Will it improve business Take-up of URBAN employment floorspace (completions) sustainable levels of development and enhance prosperity and competitiveness? Take-up of RURAL employment floorspace (completions) economic growth Employment permissions and allocations (URBAN) throughout the plan area Employment permissions and allocations (RURAL) Net change in the total number of VAT registered businesses in the area Business formation rate (or new VAT registrations as % of total VAT registered stock)

Will it improve the resilience of Business start ups and closures business and the economy? Employment by industry % Number and percentage of businesses by main industry type Number and percentage of businesses by size (number of employees)

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Will it promote growth in key Number and percentage of businesses by industry type in key sectors sectors?

Will it improve economic Comparative industrial and office rental costs within the plan area (to complete based performance in advantaged on identified advantaged and disadvantaged areas in own area) and disadvantaged areas?

Will it encourage rural Employment permissions and allocations in rural areas (RURAL) diversification?

20. To revitalise town Will it increase the range of Percentage of town centre units with A1 uses centres employment opportunities, shops and services available in town centres?

Will it decrease the number of % Vacant units in town centres vacant units in town centres?

21. To encourage Will it reduce commuting? Distances travelled to work for the resident population efficient patterns of movement in support Import/export of workers to district and/or major towns of economic growth Employment permissions and allocations in urban areas (URBAN) Number / percentage of people working from home as main place of work

Will it improve accessibility to Number of developments where a travel plan is submitted or is a condition of work by public transport, development walking and cycling? Percentage of journeys to work undertaken by sustainable modes

Will it increase the proportion Proportion of port freight carried by rail of freight transported by rail or other sustainable modes?

Will it increase the Number of farmers markets and farm shops consumption of locally produced food and goods? Number of locally sourced products stocked by major supermarket chains 22. To encourage and Will it encourage indigenous Number of enquiries to business advice services from within area accommodate both business?

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indigenous and Will it encourage inward Number of enquiries to business advice services from outside of area inward investment investment?

Will it make land available for Employment land availability (URBAN) business development? Employment land availability (RURAL)

Employment permissions and allocations (URBAN) Employment permissions and allocations (RURAL)

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SA Baseline Data and Trends 6.6 The SA Framework is the key tool used in the assessment of effects. The prediction of effects, in terms of their magnitude, frequency, duration, and spatial extent, is conducted via detailed analysis of the baseline data. It is thus important to ensure that critical aspects of the baseline can be directly related to the objectives and indicators of the SA framework. Determining the significance of predicted effects is perhaps the most critical task in the SA. The picture that the baseline presents in terms of the SA framework is the starting point for this. 6.7 Table 6.2 presents a summary of the current trends observed in the baseline data (improving, stable or declining) against the updated SA objectives. Future Baseline 6.8 The SEA Directive requires the consideration of the likely evolution of the state of the environment without the implementation of the plan being assessed. Within the next 20 years it is predicted that there will be a number of external influences that will affect the state of St Edmundsbury’s social, natural, built and economic environment, without the implementation of the St Edmundsbury Core Strategy. 6.9 Such influences and future trends are also set out in Table 6.2. These baseline trends without the implementation of the Core Strategy have been used in the assessment of the Core Strategy policies and strategic sites set out in Sections 10 and 11 below.

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Table 6.2 – SA Current and Predicted Future Baseline Data Trends

Current Future SA Objectives Comments Condition Trends

Social

To improve the health of the Good Stable Accessibility to GP and Hospitals in St Edmundsbury improved between 2004 and population overall and reduce health 2005. Current good levels of self-assessed health averages, similar to that of the East England and better than that of England as a whole, are likely to remain stable 1 inequalities in the future with or without the implementation of the plan, as the Replacement Local Plan will safeguard potential sites for health and emergency facilities.

Good Improving The average percentage of year 11 students attaining 5 A*-C grades at GCSE for St To maintain and improve levels of Edmundsbury was above both the regional and national averages in 2007 at 70.7%. 2 education and skills in the population The proportion of students gaining 5 A*-C grades at GCSE in the borough is overall growing year on year, at approximately the same rate as England.

Good Stable There has been a significant reduction in crime figures between 2005 and 2008 and crime rates in St. Edmundsbury are lower than those for East of England and To reduce crime and anti-social 3 England. The situation is likely to remain stable in the future with or without activity implementation of the plan.

Good Declining The overall rank of 2007 Indices of Multiple Deprivation of St Edmundsbury is good. However, the borough’s score and ranking declined between 2004 and 2007, To reduce poverty and social 4 indicating that the borough became more deprived in comparison with the rest of the exclusion nation during this period.

Moderate Improving Many parishes in the rural areas of St Edmundsbury lack essential services. Nonetheless, 59% had a public house and 69% had a village or community centre. However, accessibility in St Edmundsbury is improving, with increases in the percentage of rural households within 13 minutes’ walk of an hourly bus service To improve access to key services for 5 (36% in 2005/06 compared with 23% in 2001/02) and the proportion of the all sectors of the population population with access to hospital or GP or dentist surgery. Accessibility to key services and facilities is likely to further improve in line with the current trends, as the Local Plan Strategy is committed to reduce the need to travel, by improving the balance between homes and key services.

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Current Future SA Objectives Comments Condition Trends

Moderate Stable In 2008, St Edmundsbury was the local authority with the highest employment rate in Great Britain outside London. There is an upward trend for pay in the borough. To offer everybody the opportunity for However, rates are still below that for the East of England and England with a high 6 rewarding and satisfying employment rate of low paid jobs in the borough. The likely trend without implementation of the Core Strategy will be for current employment characteristics to remain stable.

Moderate Improving The current level of housing completion is below the East of England Plan target. However, there was an increase in the number of housing completions in recent To meet the housing requirements of years. Proportion of affordable completions has increased significantly between 7 the whole community 2004/05 and 2007/08.The proportion of net completions which were affordable in St Edmundsbury is higher than for the East of England.

To improve the quality of where people Moderate Stable St Edmundsbury has a relatively high level of satisfaction for ‘residents who are live and to encourage community happy with their neighbourhood as a place to live’ with the percentage of satisfied participation residents higher than the county average. In terms of community participation, 8 although the turnout to local authority elections has fallen since the 1990s, there are a number of active community and residents groups operating across the borough. The completion or participation level in the production of Parish Plans is relatively poor compared with other Suffolk authorities. Environmental To improve water and air quality Good Improving The quality of water within the borough’s rivers is generally fair to good in terms of chemical and biological quality. Air quality is also generally good within St Edmundsbury with no Air Quality Management Areas (AQMAs) having been designated within the borough. The likely trends in water and air quality without 9 implementation of the Core Strategy is likely to be improving as the Replacement Local Plan identifies measures to be undertaken and the need to protect water resources and local air quality.

To conserve soil resources and quality Moderate Improving The target of 40% of development to be provided on previously developed land set in the Replacement St Edmundsbury Local Plan has been exceeded in recent years, with 54.4% of dwellings completed in St Edmundsbury in 2007/8 being 10 located on PDL. However, this is below the Government target of 60%. Contamination of land is an important issue in the use of previously developed land. Removing contamination through the development process helps reduce the take- up of greenfield sites and also diminishes the threats posed by contamination to

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Current Future SA Objectives Comments Condition Trends

health, safety and the environment. The number of potentially contaminated sites has been reduced. This trend is likely to continue, as the Local Plan includes a policy (NE4) to ensure improvement in the study area’s contaminated sites.

To use water and mineral resources Good Declining The East of England is already the driest region in the UK, therefore water efficiently, and re-use and recycle conservation and efficiency are becoming an increasing priority. Domestic water where possible consumption in St Edmundsbury is marginally below national levels. The proportion of household waste recycled in the borough is significantly higher than that for the 11 East of England and England, and is increasing year on year. However, the level of population growth expected in St Edmundsbury is likely to dramatically increase pressure on both water and mineral resources in the future.

To reduce waste Moderate Declining The volume of household waste produced has been roughly stable over the period of 1999-2006, whereas the volume of municipal waste produced has reduced by a significant amount since 2002/03. The amount of household waste collected per 12 head in St Edmundsbury has reduced since 2004/05 but is higher than the national mean. Likely population growth within St Edmundsbury is likely to increase the volume of waste produced by the borough.

To reduce the effects of traffic on the Poor Stable Traffic volumes within the study area are high with the proportion of journeys to work environment by car significantly higher than that for the East of England and England (2001). 13 The reliance on the private car is likely to remain high in the absence of a realistic alternative.

To reduce contributions to climate Poor Declining Total emissions per capita in 2006 increased from 2005 level and are higher than change regional and national figures, as a result of the more industrial nature of the borough. Per capita domestic CO2 emissions have decreased in St Edmundsbury and are comparable to national but higher than regional figures. Due to the probable 14 continuation of the operation of industry in St Edmundsbury, and the increase in CO2 emissions which is expected to accompany the future increase in St Edmundsbury’s population, the likely future trend will be declining.

To reduce vulnerability to climatic Good Stable A very low proportion of properties in the borough are at risk of flooding and the 15 events average flow of the watercourses is low. The likely future trend will remain stable if no planning applications are approved against EA advice.

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Current Future SA Objectives Comments Condition Trends

To conserve and enhance biodiversity Moderate Improving Large areas of the Borough have ecological designations at national, regional and and geodiversity local levels and there are a large number of designated BAP habitats and species. The majority of the ecological SSSIs in the borough are in partly an unfavourable or mixed condition, with 13 of the 23 SSSIs meeting PSA targets, a further 7 meeting 16 PSA targets in over half of their areas, 1 meeting PSA targets in under half of its area, with a further 2 SSSIs not meeting their PSA target at all. However, all geological SSSIs meet PSA targets. The future trend is likely to improve, as the Local Plan aims to protect and enhance biodiversity and ecological conservation.

To conserve and where appropriate Good Improving The number of Listed Buildings, Designated Parks and Gardens and Conservation enhance areas of historical and Areas has gradually increased in the Borough. The number of buildings at risk has archaeological importance fallen since 2003 and the borough has met the Suffolk target of 0.7% and no SMs 17 have been damaged as a result of new development. These features are well protected within the Borough and the Local Plan is committed to protect the local historic environment. Therefore, the future trend is likely to improve.

To conserve and enhance the quality Moderate Declining St Edmundsbury has 16687 ha of Special landscape area (25.5% of Borough) and and local distinctiveness of landscapes 14 landscape types. Development pressures (e.g. suburbanisation, transport and and townscapes industrial developments, agricultural rationalisation and tourism related 18 development) as a result of past and projected future development within the borough have placed, and are likely to continue to place significant pressure on the landscape of St Edmundsbury.

Economic To achieve sustainable levels of Moderate Improving The business formation rate in St Edmundsbury fluctuates but is broadly similar to prosperity and economic growth that of East of England. The business formation rate in 2006 and 2007 was lower throughout the plan area than that observed between 2001 and 2004. Between 1998 and 2004, the Banking and Finance industry, and the Public Admin, education and health sectors have 19 seen significant levels of growth, with a large decline in the energy and water and manufacturing sectors. The Replacement Local Plan envisages balancing economic growth with protecting the built and natural environment.

To revitalise town centres Good Improving The town centre at Bury St Edmunds and increasingly the town centre at Haverhill 20 act as sub-regional centres providing a focus for shopping, leisure, business and cultural activities for the towns themselves and the surrounding smaller settlements,

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Current Future SA Objectives Comments Condition Trends

as well as the needs of residents outside the borough. Policy BSE7 (town centre development area – Bury St Edmunds) and Policy HAV5 (Haverhill town centre Masterplan) in the Replacement Local Plan aim to regenerate and revitalise the town centres. Therefore, the future trend is likely to improve.

To encourage efficient patterns of Moderate Declining A large majority of people who live in St Edmundsbury also work in the borough movement in support of economic (71%). However, the distance that residents of St Edmundsbury commute to work is growth significantly higher than the national mean. A high proportion of journeys to work in 21 the borough are undertaken by car. The reliance on the private car is likely to persist due to a predominantly rural nature of the area and the lack of public transport provision.

To encourage and accommodate both Good Improving St Edmundsbury was designated as a Growth Area in 2007. This enabled indigenous and inward investment preparation of an area development programme and obtaining funding. It is 22 considered that targeted public investment will stimulate private sector investment in the area. Therefore the future trend is likely to improve.

Key: Current Conditions - good/moderate/poor Future Trends – improving/stable/declining Good Impr Mod Stable Poor Decl

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7. Compatibility between Core Strategy Objectives and SA Objectives Introduction 7.1 In order to ascertain the overall sustainability of the approach proposed for the Core Strategy, the draft Core Strategy Objectives, initially identified in the Draft Core Strategy Issues and Options Report, were tested against the SA Objectives to gauge their compatibility. Overview 7.2 Table 7.1 shows the results of the broad compatibility assessment of the initial set of the Core Strategy objectives with the SA Objectives. It indicates that in the majority of cases, where there is relevance between the two sets of objectives, they are either broadly compatible, or offer the potential to be compatible dependent upon the implementation measures proposed through the development of the Core Strategy policies. 7.3 This is particularly true of the predicted compatibility against the social and economic dimensions of sustainability. In contrast, there is a considerable amount of uncertainty against the environmental objectives resulting in potential conflicts, which requires clarification through the translation of the Core Strategy objectives into policy in order to maximise their potential contribution in sustainability terms. Objectives with Potential Conflicts 7.4 Core Strategy Objectives A (Housing requirements), B (Economic vitality and wealth) and I (Provision of services and communities) conflict with SA Objectives 12 (Waste), 13 (Traffic effects), 16 (Biodiversity and geodiversity) and 17 (Historical and archaeological assets). Provision of adequate levels of housing, facilities and employment opportunities is likely to require an additional take of Greenfield land, leading to potential conflict with the preservation of biodiversity and historic and areas of historical and archaeological importance. New development will also lead to higher levels of waste generation and to a net increase in the usage of the private car. It is for these reasons that the three objectives have been highlighted as potentially in conflict with the listed SA objectives. Compatibility Dependent upon Implementation Measures 7.5 The compatibility assessment has identified a considerable number of incidences where the compatibility or otherwise of Core Strategy and SA Objectives is assessed as being ‘dependent upon implementation measures’. This essentially represents instances where careful attention will need to be paid to the content of the policies developed to implement the Core Strategy Objectives. Key point to note in this respect is as follows: • The majority of assessments falling into this category are related to the inherent correlation between the construction of new built development and the potential for environmental consequences in terms of increased emissions, including GHG emissions, increased trip generation, potential for pollution, requirements for increased water and resource usage, potential for the permanent loss of land of biodiversity value to development, and potential for an increased risk of flooding. - Recommendation: in order to ensure that implementation measures result in a positive correlation between the Core Strategy Objectives and the SA Objectives, the wording of policies must reflect the latest thinking on the sustainable siting, design and construction of buildings, including climate change mitigation and adaptation considerations; and

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strongly support the provision of public transport and other sustainable modes and waste recycling infrastructure. 7.6 The discussion of the results of the compatibility assessment for each draft Core Strategy objective is presented in Table 7.2. Final Core strategy Objectives 7.7 As a result of the recommendations of the compatibility assessment and consultation comments received on the Draft Core Strategy Issues and Options Report, a number of the Core Strategy objectives were refined and one new objective has been added to the Core Strategy objectives. The final set of the Submission Draft Core Strategy is listed below: • Strategic Objective A - To deliver housing in a sustainable way, including specialist and affordable housing to meet the needs of the whole community, by providing an adequate and continuous supply of land for housing whilst seeking to maximise the amount of Previously Developed Land used. • Strategic Objective B - To secure economic vitality and growth by delivering an adequate and continuous supply of land for employment to meet the needs and demands of different sectors of the economy and reduce the need for out-commuting. • Strategic Objective C - To sustain and enhance rural communities by providing, where infrastructure and environmental capacity exists, new housing to grow settlements and safeguard existing rural services while, maintaining and, where possible, improving the rural environment. • Strategic Objective D - To maintain and develop leisure, cultural, educational and community facilities, including access to green space, commensurate to the level of housing and employment growth to meet the needs of residents and visitors. • Strategic Objective E - To provide opportunities for people to shop for all their needs by sustainable means in thriving and economically viable town, local and district centres. • Strategic Objective F - To enable people and goods to move around efficiently and safely to the benefit of the economy and community, with minimum harm to the environment by seeking to reduce car dependency and encouraging more sustainable forms of transport • Strategic Objective G - To maintain and protect built and natural environment and ensure that new development protects and enhances assets of local design, cultural, historic and conservation importance, and character of the landscape. • Strategic Objective H - To maintain, protect and enhance the biodiversity, geodiversity and natural environment and seek opportunities to increase the provision of green open space and access to the countryside. • Strategic Objective I - To ensure that new development only occurs where there is adequate capacity in existing services, facilities and infrastructure or where this capacity can reasonably be provided. • Strategic Objective J - To ensure new development addresses and tackles environmental and sustainability issues including climate change adaptation, carbon emissions reduction, renewable energy provision, recycling, waste reduction and water efficiency.

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Table 7.1 – Compatibility Matrix between draft Core Strategy objectives and SA Objectives SA Objective Draft Core Strategy Objectives A BCDEFGH I 1. To improve the health of the population overall and 9 9 9 9 9 9 9 9 9 reduce health inequalities 2. To maintain and improve levels of education and 9 9 skills in the population overall 3. To reduce crime and anti-social activity 9 9 9 9 9 9

4. To reduce poverty and social exclusion 9 9 9 9 9 9 9

5. To improve access to key services for all sectors of 9 9 9 9 9 the population 6. To offer everybody the opportunity for rewarding and 9 9 satisfying employment 7. To meet the housing requirements of the whole 9 9 community 8. To improve the quality of where people live and to 9 9 9 9 9 9 9 encourage community participation 9. To improve water and air quality 9 9 9 ?

10. To conserve soil resources and quality 9 9

11. To use water and mineral resources efficiently, and 9 9 9 ? re-use and recycle where possible 12. To reduce waste X 9 X

13. To reduce the effects of traffic on the environment X X ? 9 9 9 9

14. To reduce contributions to climate change ? ? 9 9 9 9 9

15. To reduce vulnerability to climatic events ? ? 9

16. To conserve and enhance biodiversity and X 9 9 9 9 X geodiversity 17. To conserve and where appropriate enhance areas ? 9 X of historical and archaeological importance 18. To conserve and enhance the quality and local ? 9 9 9 ? distinctiveness of landscapes and townscapes 19. To achieve sustainable levels of prosperity and 9 9 9 9 economic growth throughout the plan area 20. To revitalise town centres 9 ? 9 9 9

21. To encourage efficient patterns of movement in 9 9 9 9 9 support of economic growth 22. To encourage and accommodate both indigenous 9 9 9 9 and inward investment

Key: Potentially Compatible 9

Not Compatible X

Not relevant

Dependent on Nature of Implementation ? Measures

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Table 7.2 – Discussion of Results of Assessment of draft Core strategy Objectives with the SA objectives

Draft Core Strategy Objective Commentary

A To meet the requirements for housing in such a New housing should meet the requirements of the whole community and improve the quality way that is sustainable and will best serve the of life in the borough. New housing should make a positive contribution to reducing crime and whole community anti-social behaviour and make steps to overcome poverty and social-exclusion. New housing will contribute to renewable energy provision and should be in locations which reduce the need to travel. New residential development could place a strain on the existing infrastructure which could intensify traffic congestion and have a negative impact on health and education provision. This could be mitigated by ensuring that new residential development is accompanied by improvements in infrastructure. New residential development will generate waste; this could be mitigated through the provision of recycling facilities. The provision of adequate levels of housing is compatible with aims to improve population health but has the potential to conflict with the preservation of biodiversity through the loss of greenfield land and archaeology through potential loss of or damage to sites of value. B To secure economic vitality and wealth creation Economic vitality and wealth will provide employment opportunities, revitalise town centres, in all communities without causing unacceptable encourage investment and support sustainable patterns of growth. New development may harm to the environment place a strain on infrastructure, but this could be mitigated through the delivery of new infrastructure. New development may also increase traffic congestion, this could be mitigated through travel plans for new development and enhanced public transport infrastructure. This objective ensures that measures are taken to reduce impact of development on the natural environment including the use of brownfield sites and ecological assessments. Securing economic viability will promote population health and contribute to reducing crime and anti- social activity, reducing poverty.

C To sustain and enhance rural communities while This should help to improve access to services in rural areas and enhance the provision of maintaining and where possible improving the housing and employment opportunities, thereby contributing to reducing poverty and social rural environment exclusion. Focusing any new development in existing villages will help develop and support sustainable transport and therefore reduce contributions to climate change. New development within villages could impact upon their character and the character of the surrounding countryside, however Objective C seeks to reduce the negative effect on the rural environment and any effects could be mitigated through good design.

D To maintain and develop leisure, culture, Improving the health and education of the population will reduce crime and help to reduce educational and community facilities to meet the poverty and social exclusion in the borough. Access to services will contribute to the overall needs of residents and visitors quality of life, revitalise town centres and encourage investment in the borough. This objective is also likely to conserve and enhance historical and archaeological assets. New development may also increase traffic congestion, this could be mitigated through travel

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Draft Core Strategy Objective Commentary plans for new development and enhanced public transport infrastructure. Measures should be taken to reduce impact of development on the natural environment including the use of brownfield sites and ecological assessments. E To provide opportunities for people to shop for all The improvement of access to shops by sustainable transport means will reduce the effects their needs by sustainable means in town, local of traffic on the environment therefore reducing contributions to climate change and reducing and district centres, which are thriving and viable negative effects on population health. Increasing use of public transport will also help to locations alleviate traffic congestion. The overall quality of life will be improved with increased access helping to overcome social exclusion and encouraging a sense of community. The revitalisation of town centres and growth of rural centres will attract further investment into the borough and support sustainable economic growth. New development within villages could impact upon their character and the character of the surrounding countryside, but this could be mitigated through good design.

F To enable people and goods to move around Improving transport links across the borough will reduce the effects of traffic on the efficiently and safely to the benefit of the environment and on contributing to climate change and air quality issues, reduce traffic economy and community, with minimum harm to congestion and improve access to services. This in turn will reduce levels of crime and social the environment by seeking to reduce car exclusion and contribute to improving population health. Improved transport and accessibility dependency and encouraging more sustainable will also help to promote sustainable economic growth. forms of transport where appropriate and providing greater accessibility to services for all. G To maintain and improve the quality of the built Improvements to the quality of the built environment will contribute to the overall quality of life environment and promote the revitalisation of town centres. Good design may help to reduce crime and anti-social activity and promote population health. New development should also seek to improve existing environmental conditions and conserve and enhance areas of historical and archaeological importance. Improved quality of the built environment may also include the regeneration of brownfield sites whilst conserving and enhancing the quality and local distinctiveness of landscapes and townscapes. H To achieve a balanced natural environment This will enhance quality of life, reduce contributions to climate change and promote where the use of resources and energy is sustainable travel modes. It should also contribute to improving water, soil and air quality minimised, materials and waste recycled and within the borough and promote good population health. Consideration should be given to development undertaken with minimum adverse protection and enhancement of local landscape and townscape, retaining local impact, giving close regard to the principles of distinctiveness and enhancing biodiversity and geodiversity of the borough. sustainability

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Draft Core Strategy Objective Commentary I To ensure that existing and new development is This will contribute to improving the quality of life in the borough and promote a sense of adequately served by community facilities and community therefore reducing crime and social exclusion. Provision of services will help to public services which are accessible by integrate new development with surrounding areas. Provision of community facilities and sustainable forms of transport public services may encourage investment into the borough. Improved accessibility including for non-car users will reduce traffic congestion and reduce contributions to climate change. New development will increase waste production and is likely to conflict with the preservation of biodiversity through the loss of greenfield land and archaeology through potential loss of or damage to sites of value.

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8. Plan Issues and Options Introduction 8.1 Stage B of the SA/SEA process seeks to develop and refine options for the Core Strategy. These options included Spatial Strategic Options and Strategic Sites for the Core Strategy DPD. 8.2 The SEA Directive requires that the Environmental Report should consider ‘reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme’ and give ‘an outline of the reasons for selecting the alternatives dealt with’ (Article 5.1 and Annex Ih). Development of Spatial Strategic Options 8.3 Five main strategic options for the spatial strategy for the borough were set out in Part 5 of the Core Strategy Issues and Options document published in March 2008. These were: • Option 1: Business as usual – this maintains the hierarchy in the Replacement St Edmundsbury Borough Local Plan 2016 (adopted in 2006), to determine the scale of new development appropriate for each location. • Option 2: Urban Growth – under this option new development would be directed towards Bury St Edmunds and Haverhill and a slowing down in the recent rates of development in the rural settlements. • Option 3: Regeneration of Haverhill – the majority of new development would be split equally between Bury St Edmunds and Haverhill, and development in the rural areas would be much lower than recently experienced. • Option 4: Rural Development - under this option significantly more development would take place in the settlements outside Bury St Edmunds and Haverhill than at present. Development rates in Haverhill would reduce compared with what has actually happened in the last ten years, but growth rates in Bury St Edmunds would continue at the rate achieved over the same period in order to reflect the strategy of the Draft East of England Plan. • Option 5: New Settlement – this option proposes a new settlement of at least 3,000 homes plus a commensurate level of jobs, services and community facilities to be constructed in the latter years of the LDF period. Some growth in the existing towns and villages would be required in the interim period to ensure that housing and the economy remain buoyant, but there would be a lower rate of development in those settlements in parallel with the construction of a new settlement. 8.4 Each option was assessed against the twenty-two Sustainability Appraisal objectives in terms of its effects, and these assessments formed part of the 26 Draft Core Strategy issues and Options Report - Initial Sustainability Appraisal (March 2008). 8.5 This section represents a revised assessment of the strategic spatial options. The revision was undertaken to align the assessment scale with SA best practice to allow for better comparison between all the options. Potential sustainability effects for each of the options were assessed in terms of progress towards achieving the relevant SA objective using the scoring system presented in Table 8.1

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Table 8.1 – Scoring of Options Assessment 3 +++ Major positive - likely to result in substantial progress towards the objective 2 ++ Moderate positive - likely to result in some progress towards the objective 1 + Minor positive - likely to result in very limited progress towards the objective 0 0 Neutral outcome -0.5 +/- Range of possible positive and negative outcomes 0 ? Uncertain outcome -1 - Minor negative - likely to be to the very limited detriment of achieving the objective -2 -- Moderate negative - likely to be to the limited detriment of achieving the objective -3 --- Major negative - likely to be substantially detrimental to achieving the objective

Results of Assessment 8.6 Table 8.2 presents a summary in numerical form of the results of the assessment of strategic options, while the sections below present a brief analysis of the results. The full assessment tables are presented in Appendix B. 8.7 The assessment results show that Options 2 and 3 perform well in the sustainability terms with no significant differences between them, as both options direct further growth to Bury St Edmunds and Haverhill and slow down and restrict development in the rural areas. Option 3 is expected to deliver a higher level of benefits against SA Objective 4 (Social exclusion), as it places a higher emphasis on the regeneration of Haverhill, and therefore, overall it performs slightly higher than Option 2. The main benefits that these two options are expected to deliver include better opportunities for development on previously developed land, the provision of good cycle and pedestrian links to employment, services and facilities, the provision of education and skills training, the efficient use of energy, etc. 8.8 Option 1 is a business as usual scenario, which supports a more disperse growth by directing development to Bury St Edmunds and also allowing development in the rural service centres. This option is also expected to deliver positive effects against the SA objectives overall, although of lower level than Options 2 and 3. 8.9 Option 5 supporting the development of new settlement was also identified as being likely to deliver beneficial effects overall. The main advantages associated with this option include similar effects to Options 2 and 3 in terms of the use of more sustainable modes of transport, accessibility to key services and ability to provide homes for all, and also by providing opportunities to adopt sustainable development measures throughout the development and from the outset. However, disadvantages of this option are loss of significant amount of greenfield land and potentially diverting from opportunities in the existing settlements. 8.10 Option 4, promoting growth in the countryside scores the lowest against the SA objectives due to such effects as restricting access to the key services and facilities with little or no scope for employment, exacerbating the reliance on the private car, loss of green space and natural habitats and inability accommodate the required level of growth and meet the housing needs of the whole community. Positive effects of helping avoid the demise of rural facilities are likely to be outweighed by the listed negative effects. 8.11 The results of this assessment suggest that the most appropriate way forward would be to amalgamate elements of Options 2 and 3, concentrating on Bury St Edmunds and Haverhill, and also include elements of Option 1, which indicates that certain level of development is required in the rural service centres to maintain the livelihood of the rural areas, in carrying the option through to the preferred option.

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Table 8.2 – Summary of Assessment of Strategic Options for Spatial Strategy Option 1 Option 2 Option 3 Option 4 Option 5 SA Objective 1 To improve the health of the population overall and reduce health 122-0.52 inequalities 2 To maintain and improve levels of education and skills in the population 12213 overall 3 To reduce crime and anti-social activity 00000 4 To reduce poverty and social exclusion 00200 5 To improve access to key services for all sectors of the population 122-0.52 6 To offer everybody the opportunity for rewarding and satisfying 122-1-0.5 employment 7 To meet the housing requirements of the whole community 122-23 8 To improve the quality of where people live and to encourage community 122-0.5-0.5 participation 9 To improve water and air quality -1 -2 -2 -2 -1 10 To conserve soil resources and quality 122-1-2 11 To use water and mineral resources efficiently, and re-use and recycle 133-22 where possible 12 To reduce waste 122-22 13 To reduce the effects of traffic on the environment 122-22 14 To reduce contributions to climate change -2 -1 -1 -3 -1 15 To reduce vulnerability to climatic events -1 -2 -2 -1 -2 16 To conserve and enhance biodiversity and geodiversity 122-1-2 17 To conserve and where appropriate enhance areas of historical and -0.5 2 2 -1 -2 archaeological importance 18 To conserve and enhance the quality and local distinctiveness of 122-0.5-0.5 landscapes and townscapes 19 To achieve sustainable levels of prosperity and economic growth 322-0.52 throughout the plan area 20 To revitalise town centres -1 2 2 -2 -2 21 To encourage efficient patterns of movement in support of economic -1 2 2 -2 2 growth 22 122-1-0.50.48 1.50 1.60 -1.23 0.30 To encourage and accommodate both indigenous and inward investment Average

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Development of Strategic Sites Introduction 8.12 Strategic sites identified in the Core Strategy Preferred Options and Strategic Sites Issues and Options Document have been subject to an assessment in order to determine their performance in sustainability terms, with reference to social, environmental and economic factors. These sites are located around Bury St Edmunds and Haverhill. The rationale used for the sites assessment, its results and a discussion of the relative merits and disadvantages of the strategic sites options are set out below. 8.13 Existing SA guidance recognises that the most familiar form of SA prediction and evaluation is generally broad-brush and qualitative. It is recognised that quantitative predictions are not always practicable and broad-based and qualitative predictions can be equally valid and appropriate. Examples of the prediction and evaluation techniques for assessing significance of effects are expert judgement, dialogue with stakeholders and public participation, geographical information systems, reference to legislation and regulations and environmental capacity. Many of these techniques have been employed in this assessment. Assessment Methodology 8.14 For the assessment of the sites there was a need to devise location specific SA criteria to cover, for example, accessibility to schools, healthcare facilities and other community services, accessibility to public transport, identify specific environmental constraints and facilities and establish the proposed site uses. Table 8.3 below presents the SA Framework adopted for the assessment of the strategic sites. Three SA objectives have been excluded from the strategic sites sustainability appraisal framework, as the indicators developed to measure the progress in achieving them, were deemed to be beyond the sphere of influence of the strategic site allocation process. These objectives are as follows: • Objective 3: To reduce crime and anti-social activity; • Objective 11: To use water and mineral resources efficiently, and re-use and recycle where possible; and • Objective 12: To reduce waste.

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Table 8.3 – Strategic Sites Sustainability Appraisal Framework

SA Objective Decision Making Criteria Indicator Social 1 To improve health of the population Is there adequate access to health facilities? Is it within 30 mins of a GP, dentist and hospital by overall and reduce health inequalities public transport? Will it encourage healthy lifestyles? Will it lead to a direct loss of public open space or open access land? Will it improve accessibility by Public Rights of Way?

2 To maintain and improve levels of Will it improve qualifications and skills of young Is it within 30 mins of a school by public transport? Is it education and skills in the population people? within walkable/cyclable distances (800m and 2-5km)? overall Is it within walkable/cyclable distances (800m and 2- 5km)? 4 To reduce poverty and social exclusion Will it reduce poverty and social exclusion in those Will the site be located near or within LSOAs in the most areas most affected? deprived 20% to 40% in the country? 5 To improve access to key services for Will it improve accessibility to key local services? Is it within 30 mins of the town centre by public all sectors of the population transport? Is it within walkable/cyclable distances (800m and 2- 5km) to key services? Will it improve accessibility to shopping facilities? Is it within 30 mins of a supermarket/ shopping centre by public transport? Is it within walkable/cyclable distances (800m and 2- 5km) to supermarkets/shopping centre? Will it improve accessibility and decrease the need Is the site proposed for mixed-use development with of travel? good accessibility to local facilities? 6 To offer everybody the opportunity for Will it reduce the unemployment overall? Is the site proposed for employment or mixed use with rewarding and satisfying employment employment included?

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7 To meet the housing requirements of Will it increase the range and affordability of Is the site proposal over the relevant thresholds for the the whole community housing for all social groups? application of affordable housing policy? CS Policy 6 defines that, for Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable.

8 To improve the quality of where people Will it increase access to natural green space? Is the site proposed in a location with accessible natural live and encourage community green space? participation Environmental 9 To improve water and air quality Will it avoid development in areas protected for Is the site proposed within a groundwater source water quality reasons? protection zone? Is the site proposed within a water abstraction management area? Will it improve air quality? Is the site proposed within an Air Quality Management Area (AQMA)? 10 To conserve soil resources and quality Will it minimise the loss of Greenfield land to Is the site proposed on Greenfield land? development? Will it minimise the loss of the best and most Would it lead to the loss of best and most versatile versatile agricultural land to development? agricultural land (Grade 1, 2 and 3a)?

Will it maintain and enhance soil quality? Will it lead to remediation of contaminated land?

13 To reduce the effects of traffic on the Will it decrease the need for local travel? Does the site have good accessibility to local facilities environment (as assessed above)?

14 To reduce contributions to climate Will it increase the proportion of energy needs Will the site proposal promote the incorporation of change being met by renewable sources? small-scale renewable in developments? Note: Adherence to Policy ENG1 of the Regional Plan which requires that new development of more than 10 dwellings or 1,000m2 of non residential floor space

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should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, was coded green. Will it reduce emissions of greenhouse gases by Is there a clear commitment to meet Code Level 3 or reducing energy consumption? above of the Government’s Code for Sustainable Homes? Note: Adherence to Policy CS2 was coded green, as meeting Code Level 3 or achieving high BREEAM rating under this Policy will help minimise CO2 emissions. 15 To reduce vulnerability to climatic Will it minimise the risk of flooding to people and Does the site lie within the flood risk zones (2, 3a, 3b) events property from rivers and watercourses? identified in the SFRA and have a proposed 'non- compatible' use or is located within 9m of a river?

16 To conserve and enhance biodiversity Will it maintain and enhance sites designated for Is the site in proximity to a Special Protection Area and geodiversity their nature conservation interest? (SPA), Special Area of Conservation (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SPA, SAC or SSSI.

Is the site in proximity to a County Wildlife Site, Local Nature Reserve or Ancient Woodland? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 500m of a site.

Will it avoid disturbance or damage to protected Are BAP habitats and species known to be on the site? species and their habitats? Will it protect and enhance sites, features and Would it lead to a loss of or damage to a designated areas of geological value? geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site within 1km of a SSSI will be coded red and within 500m will be coded amber. The site adjacent to RIGS will be coded red and within 500m - amber.

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17 To conserve and where appropriate Will it protect and enhance sites, features and Are there any listed buildings on or adjacent to the site? enhance areas of historical and areas of historical and cultural value? archaeological importance Is the site in or adjacent to a Conservation Area? Note: The sites located in a Conservation Area were coded red, those within 40 metres of a town Conservation Area or within 800m of a village Conservation Area (PPG2 criteria) were coded orange and sites not located in proximity to any Conservation Areas were coded green.

Is the site in or adjacent to a Historic Park and Garden? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of a Historic Park and Garden.

Is the site in or adjacent to a Scheduled Ancient Monument (SAM)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of a SAM. Will it protect and enhance sites, features and Is the site in or adjacent to an Area of Archaeological areas of archaeological value? Importance or a potential archaeological site? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of an Area of Archaeological Importance or a potential archaeological site.

18 To conserve and enhance the quality Will it improve the landscape or townscape? Is the site in or adjacent to a Green Corridor? Note: For and local distinctiveness of landscapes the purposes of this assessment, proximity will be taken and townscapes to mean that the site is within 40m of a Green Corridor.

Will the site development lead to coalescence of urban extensions with nearby villages?

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Economic 19 To achieve sustainable levels of Will it improve business development and Is the site proposed for mixed-use development or prosperity and economic growth enhance competitiveness? employment? throughout the plan area 20 To revitalise town centres Will it increase the range of employment Is the site proposed for mixed-use development or opportunities, shops and services available in employment in town centres? town centres? 21 To encourage efficient patterns of Will it improve accessibility to work by public Is the site proposed in a proximity to a public transport movement in support of economic transport, walking and cycling? route or in a walkable/cyclable distance? growth 22 To encourage and accommodate both Will it make land available for business Will it increase employment land availability? indigenous and inward investment development?

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8.15 The assessment of the sites was undertaken using the following qualitative assessment scale: Table 8.4 - Key to Strategic Sites Assessment In conformity with the criterion Not relevant to criterion / Neutral effects ? Insufficient information is available Partially meets the criterion / possibly in conflict with the criterion/ some constraints identified In conflict with the criterion

Assessment Results 8.16 Overall, the strategic sites are assessed as having significantly positive effects on most of the SA social objectives through the following: • provision of affordable housing, the proportion of which is determined by the thresholds outlined in the Core Strategy, • good accessibility to healthcare facilities and opportunities for healthier life style; and • good accessibility to natural green spaces for informal recreation. 8.17 Although some of the sites are not located within walkable distance to schools or other local facilities, as the sites represent urban extensions, they are still considered to offer a good level of accessibility to key local services by cycling or public transport. 8.18 In terms of environmental SA objectives, Table 8.5 demonstrates that a range of positive (sustainable) and negative (unsustainable) factors affect each strategic site proposal. The most commonly observed positive factors for all sites are as follows:

• development on all the sites is expected to achieve CO2 reductions as a result of adherence to the Core Strategy Policy 2 (Sustainable Development) • the development of the sites will not lead to a loss of or damage to designated geological sites, as there are no geological SSSI or RIGS close to any of the strategic sites, nor to any Historic Park and Garden, Area of Archaeological Importance or Green Corridor. 8.19 The most frequently observed unsustainable factors of these strategic sites are their location on greenfield land, which is also often of high agricultural value, and being within water abstraction management areas. Some of the sites also perform poorly as they are completely or partially located within groundwater source protection zones and flood risk zones, and are located in close proximity to SSSI and Local Nature Reserves. 8.20 More specifically, Haverhill Site 3 contains a SAM and Bury Site 1 is located adjacent to a village Conservation Area, potentially affecting its settings. Haverhill Site 1 and Haverhill Site 2 are both located adjacent to BAP habitats (wet woodland) and to village Conservation Areas, Bury Site 3 North of Westley Road contains 3 Listed Buildings and Bury Site 4 is located adjacent to a Conservation Area and to a SAM. Bury Site 1 is located in close proximity to Fornham All Saints and Bury Site 3 North of Westley Road is located in close proximity to Westley. Therefore, the development of these sites should include consideration as to how to avoid the coalescence of these urban extensions with Fornham All Saints and Westley. 8.21 On the whole, the development of the strategic sites is likely to deliver significantly positive effects against most of the SA economic objectives. Development of the sites is likely to contribute to sustainable levels of prosperity and economic growth, encourage efficient patters of movement as well as encourage and accommodate both indigenous and inward investment. 8.22 Although all strategic sites have a combination of sustainable and unsustainable factors affecting them, the most sustainable strategic sites are considered to be: • Bury Site 2, proposed for residential and mixed use development, is predicted to have positive effects against most of the sustainability objectives. The site forms an urban extension to Bury St Edmunds of 48.63ha. Its development would increase the area of Bury St Edmunds and result in the loss of a comparatively large area of greenfield agricultural

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land. However, the site would benefit from the services offered within Bury St Edmunds and it has the advantage of being located close to a public transport route - the nearest bus stop is located approximately 1km from the site with good accessibility to local facilities. The proposed site is not within or in close proximity to any statutory or locally designated sites and it is not located within an area of flood risk. The site will also lead to prosperity and economic growth and will encourage and be able to accommodate both indigenous and inward investment. • Bury Site 3 North of Westley Road, abuts Bury St Edmunds settlement boundary and it is a large-scale development (50+ha) that would significantly increase the area of Bury St Edmunds and result in the loss of a large area of greenfield agricultural land. The development of the site may lead to coalescence of the urban extension with Westley and may affect the quality of groundwater, as it is located within a water abstraction management area and a groundwater source protection zone 2. On the positive side, the site would benefit from the services offered within Bury St. Edmunds and it has the advantage of being located close to a public transport route - the nearest bus stop is located approximately 50m from the site and to a Public Right of Way. The site is proposed for mixed use with employment included and has good accessibility to local facilities. The proposed site is not within or in close proximity to any statutory or locally designated sites and is not located within a flood zone. The site will also lead to prosperity and economic growth, will encourage efficient patterns of movement to support that economic growth and will encourage and be able to accommodate both indigenous and inward investment. • Bury Site 5, with 54.49ha proposed for residential and commercial development with additional ancillary uses (with employment), the site abuts Bury St Edmunds settlement boundary and has good accessibility to local facilities. Its development would lead to a comparatively substantial increase in the area of Bury St Edmunds and result in the loss of a large area of greenfield agricultural land. It may also affect the quality of groundwater, as it is located within a water abstraction management area and a groundwater source protection zone 2. However, the site is not located within a flood risk area. The proposed site is located in proximity to the Glen Chalk Caves SSSI. Similarly to the other proposed sites, this site would benefit from the services offered within Bury St. Edmunds and it would have the advantage of being located close to a public transport route - the nearest bus stop is located approximately 100m from the site and to Public Rights of Way. The site will also lead to prosperity and economic growth, will encourage efficient patterns of movement to support that economic growth and will encourage and be able to accommodate both indigenous and inward investment.

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Table 8.5 – Summary of the strategic sites assessment SA Objective Indicator Haverhill Haverhill Haverhill Bury - Bury - Bury - Site Bury - Site Bury - Bury - Bury - Bury - - Site 1 - Site 2 - Site 3 Site 1 Site 2 3 North of 3 South of Site 4 Site 4a Site 5 Site 6 Westley Rd Westley Rd Social 1 To improve health of Is it within 30 mins of a GP, dentist the population and hospital by public transport? overall and reduce Will it lead to a direct loss of public health inequalities open space or open access land? Will it improve accessibility by Public Rights of Way? 2 To maintain and Is it within 30 mins of a school by improve levels of public transport? education and skills Is it within walkable/cyclable in the population distances (800m and 2-5km)? overall 4 To reduce poverty Will the site be located near or and social exclusion within LSOAs in the most deprived 20% to 40% in the country? 5 To improve access Is it within 30 mins of the town to key services for centre by public transport? all sectors of the Is it within walkable/cyclable population distances (800m and 2-5km) to key services? Is it within 30 mins of a supermarket/ shopping centre by public transport? Is it within walkable/cyclable distances (800m and 2-5km) to supermarkets/shopping centre? Is the site proposed for mixed-use development with good accessibility to local facilities? 6 To offer everybody Is the site proposed for employment the opportunity for or mixed use with employment rewarding and included? satisfying employment

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SA Objective Indicator Haverhill Haverhill Haverhill Bury - Bury - Bury - Site Bury - Site Bury - Bury - Bury - Bury - - Site 1 - Site 2 - Site 3 Site 1 Site 2 3 North of 3 South of Site 4 Site 4a Site 5 Site 6 Westley Rd Westley Rd 7 To meet the housing Is the site proposal over the requirements of the relevant thresholds for the whole community application of affordable housing policy? 8 To improve the Is the site proposed in a location quality of where with accessible natural green people live and space? encourage community participation Environmental 9 To improve water Is the site proposed within a and air quality groundwater source protection zone? Is the site proposed within a water abstraction management area? Is the site proposed within an Air Quality Management Area (AQMA)? 10 To conserve soil Is the site proposed on Greenfield resources and land? quality Would it lead to the loss of best and most versatile agricultural land (Grade 1, 2 and 3a)? Will it lead to remediation of ? ? ? ? contaminated land? 13 To reduce the Does the site have good effects of traffic on accessibility to local facilities (as the environment assessed above)? 14 To reduce Will the site proposal promote the contributions to incorporation of small-scale climate change renewable in developments? Is there a clear commitment to meet Code Level 3 or above of the Government’s Code for Sustainable

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SA Objective Indicator Haverhill Haverhill Haverhill Bury - Bury - Bury - Site Bury - Site Bury - Bury - Bury - Bury - - Site 1 - Site 2 - Site 3 Site 1 Site 2 3 North of 3 South of Site 4 Site 4a Site 5 Site 6 Westley Rd Westley Rd Homes? 15 To reduce Does the site lie within the flood risk vulnerability to zones (2, 3a, 3b) identified in the climatic events SFRA and have a proposed 'non- compatible' use or is located within 9m of a river? 16 To conserve and Is the site in proximity to a Special enhance biodiversity Protection Area (SPA), Special and geodiversity Area of Conservation (SAC) or Site of Special Scientific Interest (SSSI)? Is the site in proximity to a County Wildlife Site, Local Nature Reserve or Ancient Woodland? Are BAP habitats and species known to be on the site? Would it lead to a loss of or damage to a designated geological site - SSSI or RIGS (Regionally

Important Geological/Geomorphological Sites). 17 To conserve and Are there any listed buildings on or where appropriate adjacent to the site? enhance areas of Is the site in or adjacent to a historical and Conservation Area? archaeological Is the site in or adjacent to a importance Historic Park and Garden? Is the site in or adjacent to a Scheduled Ancient Monument (SAM)? Is the site in or adjacent to an Area of Archaeological Importance or a potential archaeological site? 18 To conserve and Is the site in or adjacent to a Green

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SA Objective Indicator Haverhill Haverhill Haverhill Bury - Bury - Bury - Site Bury - Site Bury - Bury - Bury - Bury - - Site 1 - Site 2 - Site 3 Site 1 Site 2 3 North of 3 South of Site 4 Site 4a Site 5 Site 6 Westley Rd Westley Rd enhance the quality Corridor? and local distinctiveness of Will the site development lead to landscapes and coalescence of urban extensions townscapes with nearby villages? Economic 19 To achieve Is the site proposed for mixed-use sustainable levels of development or employment? prosperity and economic growth throughout the plan area 20 To revitalise town Is the site proposed for mixed-use centres development or employment in town centres? 21 To encourage Is the site proposed in a proximity to efficient patterns of a public transport route or in a movement in walkable/cyclable distance? support of economic growth 22 To encourage and Will it increase employment land accommodate both availability? indigenous and inward investment

Key:

In conformity with the criterion Not relevant to criterion / Neutral effects ? Insufficient information is available Partially meets the criterion / possibly in conflict with the criterion/ some constraints identified In conflict with the criterion

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9. Assessment of Core Strategy Policies

9.1 This assessment was undertaken of the Core Strategy Draft Document dated 1st June 2009. Subsequent to this assessment a number of changes have been made by the Council to the policies. The final set of policies is presented in section 12. Core Strategy Policies 9.2 The St Edmundsbury Core Strategy Draft Document dated 1st June 2009 sets out 16 policies. The majority of the Core Strategy policies have been assessed separately against the SA framework. However, the two policies, Policy CS1 St Edmundsbury Spatial Strategy and Policy CS5 Settlement Hierarchy and Identity that relate to a similar theme have been grouped and assessed together to facilitate the effectiveness of appraisal and reduce the potential for repetition or contradiction. Table 9.1 details the Core Strategy policies. Results of the Assessment 9.3 Appendix D presents the results of the detailed appraisal of the potential effects of the Core Strategy policies predicted to arise from implementation of the policies. The section below presents an analysis of the detailed appraisal in terms of the significance of direct effects and potential cumulative effects and recommendations for improving the sustainability of the policies. Suggestions for mitigation of adverse effects or enhancement of positive ones are also set out. 9.4 The assessment is based on certain important assumptions with regard to the SA objectives which are detailed in Table 9.2. 9.5 Table 9.3 presents a summary of the significance of direct effects from the detailed appraisal. The significance of effects is denoted using the following system of symbols:

+++ Strongly positive ++ Moderately positive + Slightly positive 0 No effect - Slightly negative -- Moderately negative --- Strongly negative +/- Combination of positive and negative effects / neutral effect

9.6 For the purposes of analysing the results of the assessment, significant effects are those that result in strongly or moderately negative or positive effects. 9.7 It should be emphasised that the information quality, and attendant uncertainties and assumptions required to address them, vary across the evidence base for the SA objectives. This has been systematically recorded and taken into account in the detailed appraisal sheets (see Appendix D). Thus, where a major effect has been predicted for a particular SA objective, but the evidence base for this contains uncertainties or its interpretation requires a number of assumptions, the measure of information quality recorded in the appraisal has been reduced, and this is reflected in the calculation of the effect significance (see Section 2 for further details of the appraisal methodology).

117 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report Table 9.1 - Core Strategy Policies

No Policy Name Policy Description

1. Policy CS1 St. Policy CS1 Edmundsbury Spatial To date (1 April 2008) development (including land with a valid planning consent but not yet built) provided Strategy and for 6,380 new homes and has been distributed across the borough as follows: Policy CS5: Settlement • Bury St Edmunds 42% Hierarchy and Identity • Haverhill 40% • Rural Area 17% During the remainder of the LDF period, to 2031, new homes will be distributed as follows: Bury St Edmunds 5,950: • Previously developed land 650+ • Greenfield 1,800 • Strategic Urban Extensions 3,500 Haverhill 3,900: • Previously developed land 250 • Greenfield 1,150 • Strategic Urban Extensions 2,500 Rural Area: • Previously developed land 105 • Greenfield Area Action Plans for Bury St Edmunds and Haverhill and a Site Allocations Development Plan Document for the rural area will identify the location and precise boundaries of future development land. Policy CS5 All proposals for new development will be expected to have regard to the position of the site within the settlement hierarchy. 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 and functional vitality of the settlement as a whole. The coalescence of towns with surrounding settlements through new development will not be allowed to happen. 2. Policy CS2 Sustainable A high quality, sustainable environment will be achieved by designing and incorporating measures Development appropriate to the nature and scale of development, including: The protection and enhancement of natural resources:

118 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report a) making the most efficient use of land and infrastructure; b) protecting and enhancing biodiversity, wildlife and geodiversity, and avoiding impact on areas of nature conservation interest; c) safeguarding and enhancing wildlife corridors and ecological networks; d) conserving and, wherever possible, enhancing the character and quality of local landscapes and the wider countryside and public access to them, in a way that recognises and protects the fragility of these resources; e) conserving other natural resources including, air quality and soil and, wherever possible, enhancing them; f) protecting the quality and potential yield of water resources; g) maximising the efficient use of water including recycling of dirty water; and sustainable design of the built environment: h) providing the infrastructure and services necessary to serve the development; i) minimising the use of resources and energy, and exploring the feasibility and viability of decentralised energy (low carbon and/or renewable) in all new developments; j) incorporating the principles of sustainable construction including provision for recycling; and the minimisation of energy and resource efficiency at construction and occupancy phases. Developments should comply with the appropriate national standards such as the Code for Sustainable Homes and BREEAM; k) wherever possible, creating carbon neutral development; l) orientating buildings to maximise the benefit from sunlight and passive solar heating unless to do so would conflict with the grain of the surrounding area’s townscape, landscape or topography; m) aiming to meet, as a minimum, Code Level 3 of the Government’s Code for Sustainable Homes for new-build dwellings; n) maximising the use of recycled materials; o) taking account of flood risk; p) considering the natural drainage of surface water, including, where appropriate, the use of Sustainable Urban Drainage Systems (SUDS); q) making a positive contribution towards the vitality of the area through an appropriate mix of uses. In areas of strategic growth this will include employment, community, social, health and recreation facilities (including the protection and provision of informal and formal recreation, parks, open spaces and allotments); r) creating a safe environment which enhances the quality of the public realm; s) making a positive contribution to local distinctiveness, character, townscape and the setting of settlements;

119 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report t) wherever possible, conserving or enhancing the historic environment including archaeological resources.

3. Policy CS3: The Natural and The diversity, character and quality of the natural and built environment will be protected, conserved, Built Environment managed, and where possible enhanced. A network of designated sites, protected habitats and species (BAPS), wildlife or green corridors, and other green spaces will be identified and protected and habitat creation supported through policies in the Development Management DPD and other DPDs in the Local Development Framework 4. Policy CS4: Design and Proposals for new development must create and contribute to a high quality, sustainable environment. Local Distinctiveness Proposals will be expected to address, as appropriate, the following components: • detailed heritage and conservation design appraisals and information; • consideration of protection of the landscape and historic views; • an understanding of the local context and an indication of how the proposal will enhance the area; • protection of the natural environment; • in housing proposals the density and mix of housing; • provision or enhancement of open space, play, leisure and cultural facilities; • access and transport considerations. Concept Statements and Masterplans will be required for sites which by virtue of size, location or proposed mix of uses are determined by the local planning authority to require a masterplanning approach. A landscape/townscape character appraisal will be an essential prerequisite for concept statements, design briefs and master plans. Area Action Plans and Site Allocations DPDs will define those sites where this approach is required. The promotion of secure attractive, safe and people-friendly streets, to encourage more walking, cycling, recreation and local shopping, will be a priority for the council. Where appropriate the street environment will be improved/developed with a combination of the following (not exclusive): • Quality pavements and well-coordinated street furniture • Improvements to footpaths and cycle routes • Street trees and well-maintained landscaping • Clear and minimal signage • Traffic management schemes • Shared spaces and home zones • Cycle paths • Crime deterrence and safety measures, including lighting and CCTV • Public art

120 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report New developments will be required to contribute towards public realm improvements. They should also provide active street frontages to create attractive and safe street environments. 5. Policy CS6: Affordable Developers will be expected to allocate land within sites where housing is proposed to ensure that Housing affordable housing is provided

In Bury St Edmunds and Haverhill: i. Where sites are 0.5 hectares and above or 15 dwellings or more are proposed, 40% shall be affordable. ii. Where sites are between 0.3 hectares and 0.5 hectares or between 10 and 14 dwellings, 30% shall be affordable. iii. Where sites are between 0.17 hectares and 0.3 hectares or between 5 and 9 dwellings, 20% shall be affordable.

In other settlements, on sites of 0.17 hectares and above or 5 dwellings or more, 40% shall be affordable. These criteria shall also apply where a site is part of a wider but contiguous site. Conditions or legal obligations will be used to ensure that affordable housing is secured and retained for those in housing need. The Local Planning Authority will consider issues of development viability and mix, including additional costs associated with the development of brownfield sites and the provision of significant community benefits, and may be willing to negotiate a lower percentage of affordable housing. Note: This policy applies to both new build and conversion housing schemes.

6. Policy CS7: Gypsy and In the countryside, proposals for gypsy sites and travelling show people will be permitted where: Travellers Accommodation a) the site has been identified in the DPD, or in the interim, where satisfactory evidence supporting a need for the accommodation is provided; b) the use of the site would not have an adverse impact upon the amenities of nearby occupiers; c) the proposal would not detract from the undeveloped open and rural character and appearance of the countryside; and d) adequate landscaping measures are included.

A condition or legal agreement to control the future use of sites for gypsies and travelling show people may be imposed, as appropriate.

Where the proven need is short term the development will be limited by a temporary permission.

7. Policy CS8: Sustainable The council will develop and promote a high quality and sustainable transport system across the borough Transport and reduce the need for travel through spatial planning and design

All proposals for development will be required to provide for travel by a range of means of transport other than the private car in accordance with the following hierarchy:

121 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report • Walking • Cycling • Public Transport (including taxis) • Commercial vehicles • Cars

All development proposals will be required to be accessible to people of all abilities including those with mobility impairments

New commercial development, including leisure uses and visitor attractions, which generate significant demands for travel, should be located in areas well served by a variety of transport modes. Where appropriate, development proposals that will have significant transport implications will be required to have a transport assessment and travel plan showing how car based travel to the site can be minimised. 8. Policy CS9: Strategic The council will continue to work with relevant partners, including Suffolk County Council and the Transport Improvements Highways Agency, and developers, to secure the necessary transport infrastructure to achieve improvements to:

• Junctions 42 and 44 of the A14 adjacent to Bury St Edmunds • Transport safety on the A1307 between Haverhill and the A11 • Relieve the adverse impacts of traffic in Bury St Edmunds, Haverhill and those villages which have identified transport issues • Rail infrastructure in the borough • The public transport network in the towns and rural areas • Rights of way in the borough to achieve the objectives of the Suffolk Rights of Way Improvement Plan. 9. Policy CS10: Employment Employment land will be allocated in sustainable locations in the towns of Bury St Edmunds and Haverhill. and the Local Economy Existing General Employment Areas in or near Key Service Centres or Local Service Centres will continue to be protected and promoted for employment uses.

Policies in Local Development Documents will ensure that Bury St Edmunds can fulfil its role as a Key Centre for Development and Change by providing for quality employment development at the Suffolk Business Park, and that Haverhill can continue to meet the local employment needs in the Greater Cambridge area, particularly those of research and development and bio-technology industries.

Existing employment areas will continue to meet local and sub-regional needs at Clare, Great Wratting, Chedburgh, Barnham, Saxham and Stanton/Hepworth (Shepherd’s Grove). Proposals for growth in Key Service Centres and Local Service Centres will be expected to include provision for employment land and premises to meet local needs and encourage sustainable communities.

Policies in Local Development Documents will set criteria for the continued encouragement of sustainable

122 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report employment development and tourism development opportunities (including conversion of suitable buildings) in villages and rural areas. 10. Policy CS11: Retail, Leisure The town centres of Bury St Edmunds and Haverhill will continue to be the focus for new retail, leisure and and Office Development office development, taking into account;

• the need to maintain their vitality and viability • the requirement to assess the need for future growth • the sequential approach to development • the impact of any development on existing centres • the need to ensure locations are accessible by a variety of modes of transport

Retail and leisure activity elsewhere will be focused on those Key Service and Service Centres identified in Core Strategy Policy CS5 and in the new local centres located in the areas for growth identified in Policies CS12 and CS13. The development of services and facilities in these locations will be expected to be of an appropriate scale and character to reflect the role and function of the local centres and in accordance with the sequential approach.

11. Policy CS12:Bury See Core Strategy and assessment of strategic sites: St.Edmunds Strategic Limited growth to the north -west (strategic sites 1 and 2) Growth Limited growth to the west (strategic site 3) Further growth at Moreton Hall (strategic site 5) Long term strategic growth - north east Bury St.Edmunds (strategic site 6) Long term strategic growth - south east Bury St.Edmunds (strategic sites 4 and 4a).

12. Policy CS13:Haverhill Strategic Growth Land on the north-eastern edge of Haverhill will accommodate the future long term strategic growth for the town and will provide; • At least 2,200 homes • Improved connections to the existing built up area with a network of foot and cycle links to the town centre and employment areas • Protection so that the ridge and the visual boundary with Kedington is not breached • Protection for the Scheduled Ancient Monument at Wilsey Farm • New strategic public open space and recreation facilities • Education, social and recreational facilities • Local employment facilities • Opportunities for renewable energy generation and efficient use of resources • An opportunity to explore the potential for a North-eastern relief road.

13. Policy CS14: Phasing In accordance with the spatial strategy, the Council will promote the re-use of previously developed land

123 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report within housing settlement boundaries ahead of releasing greenfield sites for new neighbourhoods. The need to release land for new neighbourhoods will be assessed against the release of potential release of sites within the existing urban areas of the towns concerned. Matters to be considered in making such an assessment will include:

§ The potential to deliver national and regional targets for the development of previously developed land; § The projected delivery of the annual target for constructing new homes in the borough; § The delivery of required infrastructure; and § Achieving the objectives of the spatial strategy.

14. Policy CS15: Infrastructure All new proposals for development will be required to demonstrate that the necessary on and off-site infrastructure capacity required to support the development and to mitigate the impact of it on existing community facilities exists or will exist prior to that development being occupied.

In circumstances where the provision or improvement of infrastructure or other works or facilities is necessary, both within and beyond the borough boundary, to address community or environmental needs associated with new development or to mitigate the impact of development on the environment or existing communities, standard charges and/or standard formulae will be imposed for the payment of financial contributions towards such infrastructure, works or facilities to ensure that all such development makes an appropriate and reasonable contribution to the costs of provision.

The provision of infrastructure will be linked directly to phasing of development on land throughout the borough to ensure that there is no detrimental impact on existing infrastructure, the environment or residential amenity. It will be coordinated and delivered in partnership with other authorities and agencies such as the local highways authority, local education authority, the environment agency, primary car trusts, utility companies and other private and public sector partners.

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Table 9.2 – Assessment Rationale for Policies Assessment SA Objective Assessment Rationale Social 1. To improve health of the population overall and Consideration of: reduce health inequalities • Whether policies improve access to health facilities, and indirectly improve health for all. • Secondary consideration of reducing air pollution, ensuring homes are of a decent standard, and other indirect or longer-term effects upon health. • Secondary effects considered of improving walking and cycling infrastructure, recreational opportunities and the positive effect on improving levels of health. • Policies that promoted enhancing existing or developing new green spaces were considered as this could lead to increasing recreational opportunities. The relationship between adequate provision of green space and other aspects of health were also assessed – such as green spaces/parks providing relaxation areas and relationship to stress levels. 2. To maintain and improve levels of education and Consideration of: skills in the population overall • Whether policies would directly provide educational, training and learning facilities for the local population. • Whether policies would indirectly provide opportunities for learning (e.g. nature trails), employment based training and development. • Whether policies would improve accessibility to educational opportunities or learning facilities. • Secondary considerations of adequate housing provision, as having indirect positive effects on retaining local skills. 3. To reduce crime and anti-social activity Consideration of: • The degree to which policies would reduce crime and the fear of crime through indirect measures such as incorporating design features in new development (such as additional lighting, CCTV) and enhancing natural surveillance. 4. To reduce poverty and social exclusion Consideration of: • The extent to which policies sought to improve access to essential facilities such as employment and housing to all sectors of the borough. This included the effects of locational policies on access, as well as the provision of transportation infrastructure in connecting such locations. • Provision of an adequate proportion of affordable housing to ensure social inclusion and diversity within communities. 5. To improve access to key services for all sectors of Consideration of: the population • Whether policies would improve directly or indirectly accessibility to services and facilities through siting, improved transport measures, pedestrian and cycle links, specific community facilities, and open space.

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SA Objective Assessment Rationale 6. To offer everybody the opportunity of rewarding and Consideration of: satisfying employment • The extent to which the different policies would attract workers with key skills that are locally in demand (link with the economic objectives in supporting economic activity). • The effect of the policy in terms of offering opportunities for employment based training and development. • Whether policies would improve accessibility to employment opportunities through siting and type of development as well as transportation infrastructure. 7. To meet the housing requirements of the whole Consideration of: community • The extent to which policies would result in meeting the identified housing targets in the short, medium and long term and identified needs such as quality of housing appropriate to local needs and affordability. 8. To improve the quality of where people live and to Consideration of whether policies promote high quality design in housing, public realm, preserve and encourage community participation enhance residential amenity and encourage people to take pride in their local community. Environmental 9. To improve water and air quality Consideration of: • Whether policies would result in reductions or increases in traffic derived pollutant concentrations. • Effect of the use of more sustainable modes of transport, reductions in vehicle use leading to improvements in air quality. • Positive effects on water quality as a result of reductions in volume of traffic and reduced concentrations of pollution in run-off. • Whether policies would lead to a loss of Greenfield land and result in increased hard surfaces giving rise to polluted run off and impacting the water cycle. 10. To conserve soil resources and quality Consideration of: • How policies will reduce or increase soil contamination and safeguard soil quality and quantity, including high quality agricultural land. This includes considerations of greenfield land take. • Development types (e.g. approach to infilling) and densities. 11. To use water and mineral resources efficiently, and Consideration of: re-use and recycle where possible • Whether policies would promote efficiency in use of water and other natural resources. • Whether policies would directly reduce energy demand and incorporate renewable energy. 12. To reduce waste Consideration of: • Whether policies directly reduce the generation of waste and recycling of waste against standard levels expected for development, e.g. by providing recycling facilities within and near to homes. • Construction waste reduction, re-use and recycling.

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SA Objective Assessment Rationale 13. To reduce the effects of traffic on the environment Consideration of the extent to which policies would provide sustainable modes of transport, or promote the use of such modes and restrict the use of cars, by their location, quality of the pedestrian and cyclist environment, design, or information provision. 14. To reduce contributions to climate change Consideration of whether policies would result in reductions or increases of greenhouse gas (GHG) emissions such as from transport and new development and to what extent. 15. To reduce vulnerability to climatic events Consideration of: • Whether policies would have positive or negative effects on flood risk. • Direct or indirect effects on mitigation against and adaptation to the risk of flooding and other climate change effects, e.g. by using sustainable drainage systems and buildings adaptation (the use of green roofs, the utilisation of natural and artificial ventilation corridors, etc). 16. To conserve and enhance biodiversity and Consideration of: geodiversity • Whether policies may have a positive or negative effect on internationally and nationally designated sites and locally important habitats and species (either through fragmentation or proximity effects). • Whether the policies would result in the conservation, enhancement or creation of habitats (positive effects). Effects of urban development on wildlife networks and corridors were also considered in terms of whether such corridors would be protected or severed. 17. To conserve and where appropriate enhance areas Consideration of: of historical and archaeological importance • Policies that would have a direct effect on designated Conservation Areas, Scheduled Ancient Monuments, listed buildings, locally listed buildings and their settings. • Extent to which there is a sympathetic integration of development on local character would be assessed. • Secondary effects would be considered through policies that would reduce the traffic levels in the borough as well as other traffic management measures resulting in positive effects. 18. To conserve and enhance the quality and local Consideration of: distinctiveness of landscapes and townscapes • Whether policies would seek directly or indirectly, to maintain and enhance the quality of the landscape, countryside and open space. • Whether policies would seek to prevent coalescence of settlements. Economic 19. To achieve sustainable levels of prosperity and Consideration of: economic growth throughout the plan area • Whether policies would support maintaining and extending the range of wealth generating activities, including retail, leisure, recreation and tourism in addition to services, facilities and educational activities. • The extent to which policies would require development to be focused in existing urban centres and the expected impact of the policies on the overall quality and attractiveness of the area

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SA Objective Assessment Rationale would be primary considerations.

20. To revitalise town centres Consideration of: • Whether policies would aim to reduce the number of vacant units and/or add to the diversity and vitality of the town centres. 21. To encourage efficient patterns of movement in Consideration of sustainable development, accompanied by strategies for public transport, community support of economic growth infrastructure and a mix of uses. 22. To encourage and accommodate both indigenous Consideration of whether policies would support inward investment. and inward investment

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Table 9.3 – Summary of Significance of Direct Effects of the Preferred Policies

SA Objective 12346789101112131415 1 To improve the health of the population overall and ++ ++ + + 0 0 + 0 0 0 + + 0 + reduce health inequalities 2 To maintain and improve levels of education and skills in the population overall ++000000000++++0+ 3 To reduce crime and anti-social activity 0+0++0+00000000 4 To reduce poverty and social exclusion 0+00+++0+00++00 5 To improve access to key services for all sectors of ++ +++ + + ++ + ++ ++ ++ ++ ++ + ++ + the population 6 To offer everybody the opportunity for rewarding and satisfying employment 00000000+++++++00 7 To meet the housing requirements of the whole community ++ 0 0 + ++ + 0 0 0 0 ++ ++ ++ 0 8 To improve the quality of where people live and to + 0 0 ++ 0 ++ 0 0 0 0 ++ ++ 0 0 encourage community participation 9 To improve water and air quality --+++0000+/-00- ---+/- 10 To conserve soil resources and quality -+++0 0--0+/-00 - - - 0 11 To use water and mineral resources efficiently, and re-use and recycle where possible --++00000000- ---0 12 To reduce waste --++00000000- ---0 13 To reduce the effects of traffic on the environment -+/-0000+/-+/-++-+/--+ 14 To reduce contributions to climate change --++0000+/---++-----0 15 To reduce vulnerability to climatic events -++00000--00+/-+/--0 16 To conserve and enhance biodiversity and - ++ +++ 0 0 -- 0 +/- 0 0 - - - 0 geodiversity 17 To conserve and where appropriate enhance areas of historical and archaeological importance - +++++0 - 0+/-00 --+ - 0

18 To conserve and enhance the quality and local - +++++0 - 0+/-00 - + - 0 distinctiveness of landscapes and townscapes 19 To achieve sustainable levels of prosperity and economic growth throughout the plan area + 0 0 0 0 0 0+++++++++++ 20 To revitalise town centres ++ + 0 0 ++ 0 + 0 ++ ++ ++ + ++ ++ 21 To encourage efficient patterns of movement in support of economic growth + 0 0 ++ 0 0 0 ++ 0 0 ++ 0 + 0 22 To encourage and accommodate both indigenous and inward investment 0000000++++0+++00

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Policy CS1: St Edmundsbury Spatial Strategy and Policy CS5: Settlement Hierarchy and Identity 9.8 These policies were appraised together given their similar aim, which is to set out the spatial location and distribution of residential development in St Edmundsbury to meet the identified housing targets set out in the East of England Plan for the period 2001-2021. 9.9 The policies perform well against the social objectives as by providing housing during the plan period, this will ensure that housing needs for the Borough are met. However, the provision of approximately 10,000 homes in St Edmundsbury will inevitably have negative effects on the environment. From this assessment negative effects of varying scale and significance were identified against SA Objectives 9 (water and air quality), 10 (soils resources and quality), 11 (water and mineral resources), 12 (waste), 13 (effects of traffic on the environment), 14 (climate change), 15 (vulnerability to climatic events, 16 (biodiversity), 17 (heritage) and 18 (local landscape and townscape) as the Core Strategy identifies the need for Greenfield development to meet longer term and higher housing targets. This includes the strategic expansion of Bury St Edmunds and Haverhill as well as in rural areas. 9.10 The policy states ‘the protection of the natural and historic environment, the distinctive character of settlements and the ability to deliver infrastructure will take priority when determining the locations of future development’. Whilst this provides a generic aim to protect the natural and built environment, this policy could be strengthened by cross referring to Policy CS2: Sustainable Development somewhere in the policy wording which sets out clear, criteria based policy to achieving a high quality sustainable environment. 9.11 Positive effects have been identified for the economic objectives as by focusing development in the towns of Bury St Edmunds and Haverhill this sequential approach should ensure positive significant permanent effects in revitalising existing centres and supporting economic growth in the borough. Policy CS2: Sustainable Development 9.12 This policy is the Council’s overarching policy for ensuring environmental considerations both for the built and natural environment such as water, climate change, air quality, noise, biodiversity, heritage and design are taken into account in any new development. Policy CS2 provides a strong criterion based approach, which if effectively implemented, would have overall positive effects on all environmental SA objectives. The policy is also expected to benefit a number of the SA social objectives (1 – Health; 3 – Crime; 4 – Social exclusion; 5 – Access to key services) and economic objective (20 – Town centres), as it aims to provide infrastructure and services, contribute to the vitality of the area and create a safe environment. 9.13 It is recommended that the policy supporting text clearly establishes the link between the measures set out in Policy CS2 and the need to respond to climate change. This would help demonstrate how the Core Strategy provides the framework for reducing the area’s carbon footprint and making it resilient to the climate change consequences in accordance with Supplement to Planning Policy Statement 1 (Planning and Climate Change). Policy CS3: Natural and Built Environment 9.14 The appraisal of this policy results in similar positive effects on the environmental SA objectives as CS2. It is suggested that this policy is combined with Policy CS2 as the aims of both policies are comparable. However, if this policy remains as a separate policy in the Core Strategy, the following recommendations should be made: • Suggest including reference to the protection and enhancement of the built environment in the policy wording itself and its supporting text to strengthen the policy and to achieve more significant positive effects for this objective. • Suggest including reference to the protection and enhancement of landscapes in the policy wording itself to strengthen the policy and to achieve more significant positive effects for this objective.

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Policy CS4: Design and Local Distinctiveness 9.15 The remit for this policy is that proposals for new development must create and contribute to a high quality, sustainable environment. This is similar to the aims of Policies CS1 and CS2 and this policy seems to combine a number of CS policies CS2, CS3, CS8. In addition, it is considered that this policy and the measures outlined to promote secure attractive, safe and people-friendly streets are too detailed for inclusion in the Core Strategy and would sit better in the Development Management DPD. 9.16 From this assessment positive effects of varying scale and significance were identified against all the SA environmental objectives. Positive effects are also expected against a number of the SA social objectives (1 - Health of population; 3 - Crime; 5 – Access to services; 7 – Housing requirements; 8 – Quality of life) and SA economic objective 21 (Efficient patterns of movement), as it stipulates the provision of open space, leisure, cultural facilities and mix of housing and promotes the use of sustainable transport modes through infrastructure improvements and traffic management schemes. Policy CS6: Affordable Housing 9.17 This policy has been identified as having positive significant effects against three of the SA social objectives. The significantly positive effects related to affordable housing provision helping to tackle poverty and social exclusion (SA Objective 4), providing affordable housing in accessible locations (SA Objective 5) and providing sufficient housing that is affordable (SA Objective 7). The policy allows the LPA to ensure that affordable housing provision is directed to locations that offer the greatest accessibility to education, employment, recreation, countryside health, community services and cultural facilities for a wider proportion of the population, particularly those without access to a car as greatest proportion of affordable housing will be provided in Bury St Edmunds and Haverhill. The policy is also expected to benefit SA economic objective 20 (Revitalise town centres) by supporting the viability of the population through enabling local people to afford to buy houses in the area. Policy CS7: Gypsies and Travellers Accommodation 9.18 This policy is assessed as having overall positive effects against the social SA objectives. By accommodating the gypsy and traveller population as opposed to excluding them should have positive effects on reducing social exclusion (SA Objective 4). St Edmundsbury is required to provide up to 20 pitches for gypsies and travellers by 2012 (there were only two authorised pitches in 2006). Therefore, this provision should meet the requirements of the gypsy and traveller community, having significant positive effects on SA Objective 6 (Quality of life). 9.19 The provision of additional 18 pitches for gypsies and travellers will be permitted in the countryside through this policy which is predicted to have negative effects of varying scale on the majority of the environmental objectives. The current policy wording for protecting the environment is limited to: ‘the use of the site would not have an adverse impact upon the amenities of nearby occupiers’, ‘the proposal would not detract from the undeveloped open and rural character and appearance of the countryside’ and ‘adequate landscaping measures are included’. The inclusion of these criteria in the policy wording minimises negative effects for the landscape SA objective however; there are no equivalent criteria seeking the protection of other environmental resources such as water, solids, air, biodiversity and heritage. 9.20 To minimise potential negative effects it is recommended that the policy is cross-referenced to Policy CS2 as follows: ‘In the countryside, proposals for gypsy and traveller show people will be permitted in accordance with the criteria outlined in Policy CS2…….:’ 9.21 It is also suggested that a criteria-based policy for selecting suitable sites based on criteria outlined in CS2 should be developed and included in the relevant policy in the Development Management DPD to ensure sites are considered against biodiversity, landscape and heritage designations, soil quality, flood risk etc. Suggested additional criteria include:

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• a sequential site selection process with an emphasis on land which has been previously developed; • safe and convenient access to the primary road network with proximity to the major road network and without blocking any existing rights of way ; • safe and acceptable environmental conditions within the site including the need to avoid air and noise pollution and significantly contaminated land; • an ability to receive essential services including water, sewerage, drainage and water disposal; • location within reasonable proximity to key local services; • the potential risk of flooding or the ability to mitigate this risk; and • ensuring that any other adverse effects on the built and natural environment are avoided and / or mitigated including compliance with the key environmental policies set out in the Core Strategy (including Policies CS2 and CS4). 9.22 Policy CS7 can then also refer to the policy on Gypsy and Travellers Accommodation in the Development Management DPD that sets out more detailed sites selection criteria. Policy CS8: Sustainable Transport 9.23 This policy sets out a hierarchy for sustainable transport with non-motorised user provision as a priority. This policy requires that all development proposals will be accessible to people of all abilities, including those mobility impaired, which should result in permanent positive and significant effects on SA Objective 5 (Access to key services for all). This policy was also assessed as having positive but not significant effects on SA Objective 20 (Vitality of town centres). The promotion of alternatives to the car is likely to have indirect positive effects on the viability and vitality of town centres by making town centres more accessible to a wider cross- section of the population. 9.24 This policy is assessed as having a mix of positive and negative effects for SA Objective 13 (Traffic effects). Whilst this policy, through promoting non-motorised users and travel plans, contributes to reducing car emissions and effects of traffic on the environment resulting in positive effects, new development will inevitably increase traffic volumes, as the number of households increases, given the prevailing cultural and societal norms. Therefore, a mixture of positive and negative effects on the environment is likely when assessed together. Policy CS9: Strategic Transport Improvements 9.25 By virtue of the nature and content of the strategic transport improvements outlined in this policy which vary from improvements to rail and public transport, to road infrastructure proposals such as the improvements of Junctions 42 and 44 of the A14 adjacent to Bury St Edmunds, the assessment of this policy has resulted in a contradictory mixture of positive and negative effects of varying degrees of significance on the environmental SA objectives. 9.26 Overall, positive effects are predicted for SA Objective 5 (Access to services), as improvements to all transport network modes should have significant long term positive effects on improving accessibility to key services, particularly in the towns of Bury St. Edmunds and Haverhill. Overall positive effects are predicted for the SA economic objectives 19, 20, 21 and 22 (Sustainable levels of prosperity; Revitalise town centres; Efficient patterns of movement; Indigenous and inward investment), as improvements to all transport network modes should have significant long term positive effects on strengthening the economy. CS10: Employment and the Local Economy 9.27 Positive significant effects are predicted for the SA social objectives 4 and 5 (Poverty and social exclusion; Access to services). By concentrating employment in the towns of Bury St. Edmunds and Haverhill and in existing general employment areas in or near key service centres or local service centres will improve accessibility as well as ensuring readily available opportunities for

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employment. This policy is assessed as having significant positive effects on the economic objectives. 9.28 The current policy wording offers no protection of the environment, in particular in relation to new employment sites and is currently reactive rather than proactive in its protection of the environment. Whilst any development proposal would be assessed against the criteria outlined in Policy CS2: Sustainable Development, it is recommended that this policy cross refers to Policy CS2. This policy is assessed as having a range of not significant positive and negative effects on a number of environmental objectives due to the potential negative effects of new employment development on the environment. Policy CS11 Retail, Leisure and Office Development 9.29 If the aim of the policy is to encourage cultural facilities alongside retail and leisure opportunities, it is recommended that the title of the policy be changed to encompass a broader spectrum i.e. Retail, Leisure and Cultural Provision’. It is also recommended to remove ‘office development’ from the policy title as the principal aim of the policy seems to relate to retail and leisure and the vitality and viability of town centres. 9.30 Significant positive effects are predicted for SA Objective 5 (Access to services), as concentrating retail in the towns of Bury St Edmunds and Haverhill should result in significant positive effects in improving access to retail and leisure facilities. It will ensure that shopping facilities are accessible by a range of modes particularly with the effective implementation of the sustainable transport hierarchy. Positive but not significant effects are predicted for SA objective 14 (Contributions to climate change ) through the reduction in car use and the need to travel due to promotion of retail and leisure facilities in accessible locations, resulting in the reduction of greenhouse gas emissions in the long term. 9.31 Significant positive effects are predicted for SA economic objective 20 (Revitalise town centres), as this is the key aim of the policy. Policy CS12: Bury St Edmunds Strategic Growth 9.32 The strategy for Bury St Edmunds stems from CS Policy 1: Spatial Strategy for St Edmundsbury which identifies this historic market town as a key focus for sustainable growth. This policy identifies five broad areas for development around the town, which correspond with five of the six strategic sites proposed. This assessment has appraised the strategic growth of Bury St Edmunds and should be read in conjunction with the detailed appraisals for the six strategic sites. 9.33 Overall positive significant effects are predicted for the social SA Objectives 2 (Education and skills), 5 (Improving accessibility), 6 (Employment) and 7 (Housing) and minor positive effects are expected for SA objective 4 (Social exclusion). Positive significant long term effects are also predicted for SA economic objectives 19, 20, 21 and 22 (Sustainable levels of prosperity; Revitalise town centres; Efficient patterns of movement; Indigenous and inward investment), as the strategic economic growth of Bury St Edmunds is the overarching aim of this policy. With regard to the SA environmental objectives, a mix of positive and negative effects of varying degrees of significance is predicted which is inevitable given that this policy promotes new development. Potential effects identified in the detailed assessment of the strategic sites need to be carefully addressed through appropriate mitigation measures. 9.34 Strategic sites in and around Bury St Edmunds have been subject to more detailed appraisal (see Section 9). Policy CS13: Haverhill Strategic Growth 9.35 This policy relates to the expansion of Haverhill on land on the north-eastern edge of the town to accommodate future long term strategic growth for the town. All predicted effects therefore would occur in the longer term. 9.36 Positive significant effects are predicted against SA Objective 2 (Education and skills) as this policy stipulates the provision of education facilities which is likely to have positive effects. The effects will be local as any educational facility would serve the local population. Positive

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significant effects are also predicted for social objectives SA Objective 5 (Improving accessibility) due to the potential for a North-eastern relief road, providing additional facilities in an already accessible areas and improved local connections to the existing built up areas and rights of way network. Positive significant effects are also predicted for SA Objective 7 (Housing requirements) through the provision of 2,200 homes, which will contribute to meeting the housing requirements of the borough. As a proportion of this housing will be affordable, minor positive effects are also expected for SA Objective 4 (Social exclusion). 9.37 Positive significant long term effects are predicted for SA economic objectives 19, 20, 21 and 22 (Sustainable levels of prosperity; Revitalise town centres; Efficient patterns of movement; Indigenous and inward investment), as the strategic economic growth of Haverhill is the overarching aim of this policy. 9.38 With regard to the environmental objectives, a mix of positive and negative effects of varying degrees of significance is predicted which is inevitable given that this policy promotes new development. Significant negative effects are predicted in the long term for SA Objective 10 (Soil resources) and SA Objective 16 (Biodiversity) due to greenfield expansion. Significant negative effects are also predicted for SA Objectives 9 (Water and air quality), 12 (Waste), 13 (Effects of traffic), 14 (Contributions to climate change) and 15 (Vulnerability to climatic events) due to the inevitable increases in population and traffic as a result of new development. Positive effects are predicted against SA Objectives 17 (Heritage) and 18 (Landscape), as the policy includes the following two criteria: ‘protection so that the ridge and the visual boundary with Kedington is not breached’ and ‘protection for the Scheduled Ancient Monument at Wilsey Farm’. 9.39 It is recommended that additional criterion is added to this policy to ensure the protection of the wider natural environment to include biodiversity. Although effective implementation of Policy CS2: Sustainable Development, should help in minimising negative effects, it is recommended to that this policy is cross-referenced to Policy CS2 or an additional criterion should be added as follows: ‘ensure that any adverse effects on the built and natural environment are avoided, mitigated and/or compensated’

‘Land on the north-eastern edge of Haverhill will accommodate the future long term strategic growth for the town, subject to other relevant policies in particular CS2, and will provide….’

9.40 The strategic expansion of Haverhill will, if CS4 is implemented effectively, be subject to a master plan, planning application and detailed environmental impact assessment, which should ensure that proposals respect the natural and built environment, where possible and that negative effects are mitigated. 9.41 Strategic sites in and around Haverhill have been subject to more detailed appraisal (see Section 9). Policy CS14: Phasing 9.42 It is recommended that the title of this policy is re-worded to read 'Sequential approach to sites development', as the policy text refers to sequential approach in re-using previously developed land with housing settlement boundaries ahead of releasing greenfield sites for new neighbourhoods. The identification and prediction of effects are similar to those for Policies CS1 and CS5, establishing a spatial location and distribution of housing, in terms of effects of new development. 9.43 At present the wording of the policy offers no protection on the environment. Whilst any development proposal would be assessed against the criteria outlined in Policy CS2: Sustainable Development, it is recommended that this policy cross refers to Policy CS2. Policy CS15: Infrastructure 9.44 This policy is assessed primarily as having effects against the majority of the social objectives. Positive effects are achieved against SA Objectives 1, 2 and 5 (Health of the population;

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Education and skills; Access to key services). However, this policy does not stipulate the type of community facilities which will be supported through this policy (only in the supporting text). The positive effects may be greater if the specific community facilities are referred to in the policy wording. The assessment against the environmental SA objectives has resulted in a mix of effects. 9.45 The provision of infrastructure through developer contributions may generate sufficient funding to enhance sustainable transport options in combination with Policy CS8 resulting in positive effects on SA Objective 13 (Effects of traffic). 9.46 The scale and effects of this policy is likely to be monitored through the development control process. The uncertainty of all effects predicted is high as they will depend on the nature of obligations sought for development proposals. 9.47 It is suggested that this policy is titled as 'community infrastructure capacity and tariffs' as the principal aim of this policy appears to relate to community infrastructure provision to be achieved through developer contributions. Cumulative, Synergistic and Indirect Effects 9.48 The detailed assessment, the results of which are presented in Appendix D, was focused primarily on direct effects. As required by the SEA Regulations, cumulative, synergistic and indirect effects have also been recorded and analysed during the appraisal. Table 9.4 lists the results of this analysis. Table 9.4 – Summary of Cumulative, Synergistic and Indirect Effects Policies Effects Causes Significance CS1, CS2, Cumulative and Taken together, these policies all seek to Significant positive CS3, CS4, synergistic effects address aspects that contribute to improving effects increasingly CS5, CS8, on improving the health, encompassing high quality housing; apparent over the CS12, health of St improvement in walking and cycling provision medium to longer term. CS13, Edmundsbury’s as well as an improvement in sports and CS15 resident population recreational facilities and access to them; and improvement of the natural environment and transport that may improve air quality and a sense of wellbeing. CS1, CS5, Indirect effects on The spatial hierarchy and policies for strategic Indirect positive effects CS12, improving levels of growth in Haverhill and Bury St Edmunds likely over the longer CS13 education and should help to improving overall education terms as development skills and skill level for the local population. proposals and infrastructure is completed. CS2, CS6, Indirect effect on A number of the policies may, when taken Indirect positive effects CS7, CS8 tackling poverty together, help to reduce poverty and social likely over the longer and social exclusion in St Edmundsbury. These factors term as development exclusion include: improving the quality of housing and proposals and development as well as affordability, infrastructure completed, improving skills levels and access to providing this is done in community facilities, education and an equitable way across employment, and improving health levels. the plan area. All CS Cumulative effects The cumulative effect of policies concerned Significant positive Policies on improving with the locational approach, focusing the effects developing over accessibility to greatest concentrations of development within the medium and longer services and central and accessible locations, should result term as more facilities in an overall reduction in the need for development residents and workers to travel to access opportunities are essential services and facilities. realised. CS1, CS5, Cumulative effects These policies cumulatively will meet the Significant positive CS6, CS7, of meeting the housing requirement for Bury St Edmunds. effects developing over CS12, housing the medium and longer CS13 requirements of St term as more Edmundsbury development

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Policies Effects Causes Significance opportunities are realised. All Cumulative effects An increase in development and road Significant negative on air quality infrastructure may lead to a net increase in effects developing over overall traffic volume, despite efforts to create the medium to longer a modal shift, and thus lead to the term as more deterioration of air quality. development occurs. CS1, CS9, Cumulative effects GHG emissions arise from a wide variety of Significant and CS12, on contributing to sources including transport, construction, permanent negative CS13 climate change and waste transfer and the general operation of effects, becoming vulnerability of buildings (heating and lighting systems). As increasingly apparent climatic events such, the cumulative effects of realising the over the medium and scale of development set out in these policies longer term. is likely to result in an overall increase in GHG emissions across the plan area, irrespective of the potential effects of other policy provisions. The focus of growth around the airport will likely exacerbate these effects. CS1, CS2, Cumulative and The cumulative and synergistic effects of Significant positive CS8, CS9, synergistic effects policies concerned with the locational effects developing over CS10, on reducing the approach of focusing the greatest the medium to longer CS11, effects of traffic on concentrations of development with main term as more CS12, the environment population centres; and the promotion of a development CS13 combination of physical and incentive based opportunities and measures aimed at encouraging the use of infrastructure proposals public transport on encouraging modal shift to are completed. non-car modes, particularly for short distance and commuting trips. CS1, Indirect effects of The spatial hierarchy and policies for strategic Indirect positive effects CS2CS9, strengthening the growth in Haverhill and Bury St Edmunds likely over the longer CS10, local economy in St should help to strength the economy. term. CS11, Edmundsbury CS12, CS13, CS14, CS15

9.49 The assessment therefore highlights the need for those elements that are expected to result in adverse effects to be addressed more overtly as part of the DPD process, supported by mitigation as appropriate, as well as enhancement of beneficial effects where possible.

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10. Mitigation

10.1 The term mitigation encompasses any approach that is aimed at preventing, reducing or offsetting significant adverse environmental effects that have been identified. In practice, a range of measures applying one or more of these approaches is likely to be considered in mitigating any significant adverse effects predicted as a result of implementing the Core Strategy. In addition, it is also important to consider measures aimed at enhancing positive effects. All such measures are generally referred to as mitigation measures. 10.2 However, the emphasis should be in the first instance on proactive avoidance of adverse effects. Only once alternative options or approaches to avoiding an effect have been examined should mitigation then examine ways of reducing the scale/importance of the effect. 10.3 Mitigation can take a wide range of forms, including: • Suggested re-wording of some policies in order to improve the likelihood of positive effects and to minimise adverse effects; • Technical measures (such as setting guidelines) to be applied during the implementation stage; • The effective implementation of other relevant Core Policies within the Core Strategy; • Identifying issues to be addressed in project environmental impact assessments for certain projects or types of projects; • Contingency arrangements for dealing with possible adverse effects. 10.4 Mitigation measures for each Policy have been considered and the Policies Assessment Tables (Appendices D) include cross-references to mitigation measures where appropriate. 10.5 Recommendations on how to strengthen identified positive effects or minimise negative effects have been identified for a number of policies in section 9.

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11. Monitoring

11.1 The SEA Directive states that ‘member states shall monitor the significant environmental effects of the implementation of plans and programmes...in order, inter alia, to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action’ (Article 10.1). 11.2 In addition, the Environmental Report should provide information on a ‘description of the measures envisaged concerning monitoring’ (Annex I (i)) (Stage E). 11.3 SA monitoring will cover significant social and economic effects as well as significant environmental effects; and it involves measuring indicators which will enable the establishment of a causal link between the implementation of the plan and the likely significant sustainability effects (both beneficial or adverse) being monitored. This will allow the identification of any unforeseen adverse effects and enable appropriate remedial action to be taken. 11.4 The SA guidance recommends SA monitoring is incorporated into each Council’s existing monitoring arrangements. Under Section 35 of the Planning and Compulsory Purchase Act 2004 and Regulation 48 of the Town and Country Planning Regulations 2004 the Councils are required to prepare Annual Monitoring Reports (AMRs) to assess the implementation of their LDFs. For monitoring efforts to be optimally effective, it will be important that the Councils seek to integrate the monitoring of the significant sustainability effects of the JMDPD with the AMR process. 11.5 Potential indicators for monitoring these effects have been identified as part of this appraisal and are listed under the relevant objective in the SA framework set out in Table 6.1 above. 11.6 In order to reach a final framework of indicators for their AMRs the Councils will need to consider the indicators proposed in the SAs to identify those which can be most effectively used to monitor the sustainability effects of each LDF as a whole. This will need to be undertaken in dialogue with statutory consultees and other bodies, as in many cases the monitoring information may need to be provided by outside bodies. 11.7 The following significant effects against all the SA objectives (including direct and cumulative, synergistic and indirect effects) have been identified by the assessment and form the basis of the monitoring programme: SA Objectives with identified significant effects 1 - To improve the health of the population overall and reduce health inequalities (positive effects) 2 - To maintain and improve levels of education and skills in the population overall (positive effects) 3 - To reduce crime and anti-social activity (positive effects) 4 - To reduce poverty and social exclusion (positive effects) 5 - To improve access to key services for all sectors of the population (positive effects) 6 - To offer everybody the opportunity for rewarding and satisfying employment (positive effects) 7 - To meet the housing requirements of the whole community (positive effects) 8 - To improve the quality of where people live and to encourage community participation (positive effects) 9 - To improve water and air quality (both positive and negative effects) 10 - To conserve soil resources and quality (both positive and negative effects) 11 - To use water and mineral resources efficiently, and re-use and recycle where possible (both positive and negative effects)

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12 - To reduce waste (both positive and negative effects) 13 – To reduce the effects of traffic on the environment (positive effects) 14 - To reduce contributions to climate change (both positive and negative effects) 15 - To reduce vulnerability to climatic events (both positive and negative effects) 16 - To conserve and enhance biodiversity and geodiversity (both positive and negative effects) 17 - To conserve and where appropriate enhance areas of historical and archaeological importance (both positive and negative effects) 18 -To conserve and enhance the quality and local distinctiveness of landscapes and townscapes (positive effects) 19 - To achieve sustainable levels of prosperity and economic growth throughout the plan area (positive effects) 20 - To revitalise town centres (positive effects) 21 - To encourage efficient patterns of movement in support of economic growth (positive effects) 22 - To encourage and accommodate both indigenous and inward investment (positive effects) 11.8 The monitoring programme outlined in Table 12.1 below is preliminary and will be confirmed at the time of the adoption of the Core Strategy DPD. Monitoring of the direct and cumulative, synergistic and indirect effects was combined where these overlap and where the suggested set of indicators can be used to monitor two or more effects. The programme may still evolve based on the results of public consultation, dialogue with environmental and other consultees and the identification of additional data sources, as in many cases information will be provided by outside bodies. It should be noted, however, that there will be a need for careful consideration of the practicalities of monitoring to be taken into account in shaping the final monitoring strategy, especially in the context of limited resources at the Borough level. The emphasis must be on creating a balanced, effective, yet achievable set of monitoring criteria.

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Table 11.1 - Proposed Monitoring Programme

No Effects to be monitored Indicator(s) to be used Target Suggested frequency Responsibility for of review/analysis of undertaking monitoring monitoring data/mitigation 1 Effects on improving the health Proportion of population with % Increase Periodically SEBC (DfT of the population overall and access to hospital or GP or dentist accessibility indicators) reducing health inequalities surgery Proportion of journeys to work on % Increase Annual SEBC foot or by cycle How do children travel to school? Non identified Annual SEBC

Obesity in the population Annual SEBC (Department of Health indicator 7.01)

Participation in sport and active 70% of population Annual SEBC (National recreation participants in 30 mins Indicator 8) activity, 5 times a week by 2020 Source: The Framework for Sport in England: A Vision for 2020 2 Effects on maintaining and Average point score per student at % Increase Annual SEBC improving levels of education A and AS level and skills in the population overall Proportion of the population with % Increase Annual SEBC no qualifications

3 Effects on reducing crime and Crime rate per 1000 population Decrease Annual SEBC (Suffolk Speaks, anti-social activity British Crime Survey) Fear of Crime Decrease Annual SEBC (Suffolk Speaks, British Crime Survey)

4 Effects on reducing poverty Proportion of the population who % Reduce Annual SEBC and social exclusion live in wards that rank within the

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No Effects to be monitored Indicator(s) to be used Target Suggested frequency Responsibility for of review/analysis of undertaking monitoring monitoring data/mitigation most deprived 10% and 25% of wards in the country

5 Effects on improving access to Percentage of rural households % Increase Annual SEBC key services for all sectors of within 15 minutes’ walk of an the population hourly bus service Proportion of population with % Increase Annual SEBC access to key local services e.g. GP, post office

6 Effects on offering everybody Unemployment rate – (%) % Reduce Annual SEBC the opportunity for rewarding unemployed persons and satisfying employment

7 Effects on meeting the housing Homelessness Numbers Reduce Annual SEBC requirements of the whole community Annual net dwelling completions Proposed East of Annual SEBC England annual target of housing completions for St Edmundsbury (Policy H1) between 2001 and 2021: 500 Affordable Housing completions Policy H3 - Affordable Annual SEBC Housing of the Replacement St Edmundsbury Borough Local Plan 2016: 40% affordable housing on: i) sites of 0.5+ ha or 15+ dwellings, in settlements of 3,000+

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No Effects to be monitored Indicator(s) to be used Target Suggested frequency Responsibility for of review/analysis of undertaking monitoring monitoring data/mitigation ii) sites of 0.17+ ha or 5+ dwellings, in settlements of less than 3000 Special Needs Housing Not identified Annual SEBC

Provision for gypsy and traveller 17 pitches by 2011 SEBC pitches (The East of England Plan, a target for St Edmundsbury in Policy H4) Average property price and Decrease Annual SEBC Housing Affordability 8 Effects on improving the quality % of residents who are happy with Increase Periodically SEBC (Suffolk Speaks of where people live and their neighbourhood as a place to Survey) encouraging community live participation Change in amount of accessible Increase in the amount of Periodically SEBC (Suffolk Biological natural green space accessible natural green Records Office) space by 5% by 2010

Number of people involved in Increase Periodically SEBC (NI 6 volunteer activities ‘Participation in regular volunteering’) 9 Effects on improving water and Water quality in rivers Improve Annual SEBC (Environment air quality Agency) Groundwater quality Improve Annual SEBC (Environment Agency) Have annual mean concentrations Zero exceedances Annual SEBC of any key air pollutants been

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No Effects to be monitored Indicator(s) to be used Target Suggested frequency Responsibility for of review/analysis of undertaking monitoring monitoring data/mitigation exceeded?

10 Effects on conserving soil Number and percentage of new Decrease Annual SEBC resources and quality dwellings completed on greenfield land

Dwellings per hectare of net Recommended minimum Annual SEBC developable area guideline = 30 dwellings/hectare (PPG3) Number of potential and declared Increase Annual SEBC contaminated sites returned to beneficial use 11 Effects on using water and Recycled aggregate production Increase Annual SEBC mineral resources efficiently, and re-use and recycle Daily domestic water use (per Achieving the equivalent Annual SEBC (Audit capita consumption, litres) for St of 3 stars under the Code Commission) Edmundsbury for Sustainable Homes for water use (105litres/capita/day) is a desirable target for new homes 12 Effects on reducing waste Household and municipal waste Year-on-year reduction Annual SEBC produced

Tonnage / proportion of household Year-on-year increase Annual SEBC (and municipal) waste recycled, and composted 13 Effects on reducing the effects Traffic volumes in key locations Decrease Annual SEBC of traffic on the environment Percentage of all new residential Increase Annual SEBC development taking place in major towns, other towns, and

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No Effects to be monitored Indicator(s) to be used Target Suggested frequency Responsibility for of review/analysis of undertaking monitoring monitoring data/mitigation elsewhere Percentage of journeys to work Increase Annual SEBC undertaken by sustainable modes

Percentage of schoolchildren Increase Annual SEBC travelling to school by sustainable modes Car parking standards (the Decrease Annual SEBC number of spaces per development) 14 Effects on reducing Consumption of electricity - Decrease Annual SEBC (DTI)) contributions to climate change Domestic use per consumer and total commercial and industrial use

Consumption of gas - Domestic Decrease Annual SEBC (DTI) use per consumer and total commercial /industrial use

GHG emissions by sector and per To reduce CO2 Annual SEBC (Defra Statistics capita emissions - proportion and emissions 80% by on CO2 emissions for absolute quantity in tonnes per 2050 from a 1990 local authority areas) year baseline figure (national target) Source: UK Climate Change Act 2008 Percentage of buildings achieving Desirable targets: Annual SEBC desired rating against national all new dwellings building standards such as Code meeting Code level 3 for Sustainable Homes or by 2010, Code level 4 BREEAM (‘Very Good’/’Excellent’ by 2013 and Code

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No Effects to be monitored Indicator(s) to be used Target Suggested frequency Responsibility for of review/analysis of undertaking monitoring monitoring data/mitigation standard) level 6 by 2016

1. Percentage of new East of England Periodically SEBC development which sources a targets percentage of energy from low 10% (2010); 17% (2020) carbon or renewable sources: i. Onsite; ii. Offsite.

Renewable energy generation: Increase Annual SEBC installed generating capacity.

Number of properties receiving Increase Annual SEBC grants to increase energy efficiency in their homes (e.g. from Carbon Emissions Reductions Target Scheme or the Warm Front Scheme)

15 Effects on reducing Flood Risk – Planning applications Compliance with Annual SEBC vulnerability to climatic events approved against Environment Environment Agency Agency advice advice

Properties at risk of flooding from Decrease/Maintain Annual SEBC (Environment rivers stable Agency)

16 Effects on conserving and Change in number and area of No net loss Annual SEBC enhancing biodiversity and designated ecological sites geodiversity Condition of CWS Improve Periodically SEBC (new National Indicator 197) Reported condition of ecological Meet the Public Periodically SEBC (Natural SSSIs Service Agreement England)

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No Effects to be monitored Indicator(s) to be used Target Suggested frequency Responsibility for of review/analysis of undertaking monitoring monitoring data/mitigation targets Achievement of Habitat and Compliance Periodically SEBC Species Action Plan targets

Development proposals affecting Zero Annual SEBC BAP habitats outside protected areas

Reported condition of geological Improve Periodically SEBC SSSIs and RIGSs

17 Effects on conserving and Number of listed buildings and Decrease Annual SEBC (English enhancing areas of historical buildings at risk Heritage) and archaeological importance Area of historic parks and gardens No net loss Annual SEBC (English Heritage)

Number and area of Conservation No net loss Annual SEBC (English Areas (CAs) and Article 4 Heritage) directions Number of Conservation Area Increase Annual SEBC Appraisals (CAAs) completed and enhancement schemes (in conservation areas) implemented Number of Scheduled Ancient Zero Annual SEBC (English Monuments (SAMs) damaged as Heritage) a result of development

Percentage of development Not identified Annual SEBC permissions with conditions requiring archaeological investigations prior to or during

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No Effects to be monitored Indicator(s) to be used Target Suggested frequency Responsibility for of review/analysis of undertaking monitoring monitoring data/mitigation development

18 Effects on conserving and Number and percentage of new Borough target of 40% Annual SEBC enhancing the quality and local dwellings completed on previously from SEBC distinctiveness of landscapes developed land Replacement Local and townscapes Plan PPG3: 60% on brownfield Number of vacant dwellings Decrease Annual SEBC Landscape condition specified in No reduction in quality Periodically SEBC (Suffolk landscape character assessments or character Landscape Character Assessment)

19 Effects on achieving Take-up of URBAN employment To maintain a supply Annual SEBC sustainable levels of prosperity floorspace (completions) of available land where and economic growth appropriate and to throughout the plan area encourage year-on- year employment development

Take-up of RURAL employment To maintain a supply Annual SEBC floorspace (completions) of available land where appropriate

Employment permissions and None identified Annual SEBC allocations (URBAN) Employment permissions and None identified Annual SEBC allocations (RURAL)

20 Effects on revitalising town % Vacant units in town centres Not exceed the Annual SEBC

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No Effects to be monitored Indicator(s) to be used Target Suggested frequency Responsibility for of review/analysis of undertaking monitoring monitoring data/mitigation centres national average

21 Effects on encouraging Number of developments where a Increase Annual SEBC efficient patterns of movement travel plan is submitted or is a in support of economic growth condition of development

Percentage of journeys to work Increase Annual SEBC undertaken by sustainable mode Number of farmers markets and Increase Annual SEBC farm shops

22 Effects on encouraging and Employment land availability To maintain a supply Annual SEBC accommodating both (URBAN) of available land where indigenous and inward appropriate investment Employment land availability To maintain a supply Annual SEBC (RURAL) of available land where appropriate

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12. Conclusions

12.1 The Core Policies within the St Edmundsbury Core Strategy DPD meet to a large extent the range of sustainability objectives identified in the SA framework, on the whole achieving a balance of positive significant effects. 12.2 This report provides recommendations for improving the sustainability performance of the Core Strategy, where appropriate. In some cases, cross-referencing of policies can clarify the application of all Core Policies to specific development proposals. In others, recommendations have been made as to how strengthen the wording of the policies by expanding aspects of the issues they cover and improving the clarity of wording. The remaining negative effects can be minimised to acceptable levels by undertaking Environmental Impact Assessment of projects or schemes arising from the implementation of the Core Strategy. 12.3 The policies’ wording has been further refined (and expanded in some cases) in the finalised version of the Core Strategy Submission Document, as a result of further Council’s internal work and taking into account recommendations arising from both the SA and AA processes and changes proposed by the Planning Inspectorate. In addition, a new policy covering (policy CS13 Rural Areas) has been added setting out how development in rural areas will be controlled. 12.4 Table 12.1 below presents the set of the finalised policies included in the Core Strategy Submission Document. Refinements to the policies, by providing clarification and further detail, have further enhanced the sustainability performance of St Edmundsbury Core Strategy. 12.5 The Core Policies offer potentially significant positive effects on all SA social and economic objectives, therefore addressing suitably the issues associated with health, education, crime and fear of crime, poverty and social exclusion, access to key services, employment, housing requirements, revitalisation of town centres, economic growth and investment. However, a range of both significant positive and negative effects have also been identified with regard to the environmental SA objectives. The predicted negative effects are associated with Policies aiming to accommodate the provision of over 10,000 new homes and required infrastructure in St Edmundsbury, including Greenfield land take, which will have negative effects on the environment. Specifically, the assessment has identified negative effects of varying scale and significance on water and air quality, soils resources and quality, mineral resources, waste, effects of traffic on the environment, climate change, vulnerability to climatic events, biodiversity, heritage and local landscape and townscape. 12.6 The extent of the significance of negative effects associated with new development and the subsequent mitigation will be assessed in greater detail in the assessment of subsequent DPDs and AAPs. Consequently, careful wording of more specific policies could minimise these potential significant effects identified in the assessment of the Core Strategy policies as well as ensuring that there is adequate provision for the protection of the environment.

149 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report Table 12.1 –Core Strategy Policies (as in Core Strategy Submission Document)

Policy Text (new text shown in italics)

Policy CS1 St Edmundsbury Spatial Strategy

The spatial strategy provides a framework for environmentally sustainable economic growth within the overall guidelines of the East of England Plan and the context of the Western Suffolk Sustainable Community Strategy. The Key Diagram illustrates the Council’s vision for the management of growth in the borough for the period to 2031. The protection of the natural and historic environment, the distinctive character of settlements and the ability to deliver infrastructure will take priority when determining the location of future development.

Opportunities to use previously developed land and buildings for new development will be maximised through a sequential approach to the location of development in settlements. The towns of Bury St Edmunds and Haverhill will be the main focus for the location of new development, supported by appropriate levels of development in Key Service Centres, Local Service Centres and Infill Villages. In particular, longer term strategic growth will be provided to the south-east and north-east of Bury St Edmunds and the north-west and north-east of Haverhill. Lesser, mixed use development will take place on the eastern, north-western and western edges of Bury St Edmunds.

All growth around Bury St Edmunds and Haverhill will protect the identity of those villages that surround the towns and strategic landscaped buffers will be identified and where necessary provided to ensure that the settlements do not become part of the larger urban area. Precise boundaries to determine the extent of the built up area of the towns will be defined in preparing the Area Action Plans for Bury St Edmunds and Haverhill.

Provision is made for a commensurate proportion of the 18,000 new jobs allocated in the East of England Plan for the Rest of Suffolk and the same Plan’s requirement for at least 15,400 new homes (net) between 2001 and 2031.

The table below sets out the components of the new housing provision and its proposed distribution across the borough. All new allocations are minimum numbers.

Already Currently Remaining Strategic Other Rural Total % built permitted Local Plan directions potential windfall Town / 2001- (April allocations of growth * settlemen 2008 2008) rolled t category forward Bury St 1600 672 441 4350 750 7813 50 Edmunds Haverhill 930 373 1273 2500 240 5316 34 Rural Key 507 317 240 610 575 2464 16 Area Service Centres Local 35 170 Service Centres Other 10 villages Totals 3037 1362 1989 6850 1780 575 15593

* Figures in this column are rounded and include large sites that have gained planning consent since 1 April 2008; are included in approved development briefs or masterplans; or are identified in the Strategic Housing Land Availability Assessment (SHLAA).

Area Action Plans for Bury St Edmunds and Haverhill and a Site Allocations Development Plan Document for the rural area will identify the location and precise boundaries of future development land.

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Policy CS2 Sustainable Development A high quality, sustainable environment will be achieved by designing and incorporating measures appropriate to the nature and scale of development, including: The protection and enhancement of natural resources: a) making the most resource efficient use of land and infrastructure; b) protecting and enhancing biodiversity, wildlife and geodiversity, and avoiding impact on areas of nature conservation interest in both rural and built up areas; c) safeguarding and enhancing wildlife corridors and ecological networks; d) conserving and, wherever possible, enhancing the character and quality of local landscapes and the wider countryside and public access to them, in a way that recognises and protects the fragility of these resources; e) identifying, protecting and conserving: a network of designated sites; protected habitats and species (BAPS); wildlife or green corridors; and other green spaces will be identified, protected and habitats created as appropriate f) conserving and, wherever possible, enhancing other natural resources including, air quality and the quality and local distinctiveness of soils and, wherever possible, enhancing them; g) protecting the quality and availability potential yield of water resources; h) maximising the efficient use of water including recycling of used water dirty water and rain water harvesting i) maximising the potential of existing and new sources of energy from biomass including timber and other energy crops; and Sustainable design of the built environment: j) providing the infrastructure and services necessary to serve the development; j) minimising the use of resources and energy, and exploring the feasibility and viability of decentralised energy (low carbon and/or renewable) in all new developments; k) incorporating the principles of sustainable design and construction in accordance with recognised appropriate national standards and codes of practice to cover the following themes:- • Energy and CO2 Emissions – creating carbon neutral development and incorporating decentralised energy generation • Water – ensuring water efficiency by managing water demand and using such waste water reuse methods as rainwater harvesting and grey water recycling; • Materials - minimising the use of resources and making use of local materials • Surface Water Run-off – incorporating flood prevention and risk management measures, such as sustainable urban drainage; • Waste – adhering to the waste hierarchy during construction and following development to prevent waste generation and ensure reuse, recovery and recycling • Pollution – remedying existing pollution or contamination and preventing further pollution arising from development proposals • Transport – minimising the need for travel and ensuring a balance between transport infrastructure and pedestrians • Health and Wellbeing – ensuring that the development enhances the quality of life of future occupants and users; • Ecology – valuing and enhancing the ecological features of the development site, where appropriate. l) Ensuring that developments and their occupants are capable of managing the impact of heat stress and other extreme weather events k) incorporating the principles of sustainable construction including provision for recycling; and the minimisation of energy and resource efficiency at construction and occupancy phases. Developments should comply with the appropriate national standards such as the Code for Sustainable Homes and BREEAM; l) wherever possible, creating carbon neutral development; m) orientating buildings to maximise the benefit from sunlight and passive solar heating unless to do so would conflict with the grain of the surrounding area’s townscape, landscape or

151 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report topography; n) aiming to meet, as a minimum, Code Level 3 of the Government’s Code for Sustainable Homes for new-build dwellings; o) maximising the use of recycled materials; p) taking account of flood risk; q) considering the natural drainage of surface water, including, where appropriate, the use of Sustainable Urban Drainage Systems (SUDS); m) making a positive contribution towards the vitality of the area through an appropriate mix of uses. In areas of strategic growth this will include employment, community, social, health and recreation facilities (including the protection and provision of informal and formal recreation, parks, open spaces and allotments); n) creating a safe environment which enhances the quality of the public realm; o) making a positive contribution to local distinctiveness, character, townscape and the setting of settlements; p) wherever possible, conserving or enhancing the historic environment including archaeological resources. Site specific and area targets, along with detail of viability, to meet national standards and codes, will be set out in the Area Action Plans and the Rural Site Allocations document This policy has been incorporated in Policy CS2.

Policy CS3 Design and Local Distinctiveness Proposals for new development must create and contribute to a high quality, sustainable environment. Proposals will be expected to address, as appropriate, the following components: • detailed heritage and conservation design appraisals and information; • consideration of protection of the landscape and historic views; • an understanding of the local context and an indication of how the proposal will enhance the area; • protection of the natural environment; • In proposals for housing, the density and mix of housing; • provision or enhancement of open space, play, leisure and cultural facilities; • access and transport considerations. Concept Statements/Development Briefs and Masterplans will be required for sites which by virtue of size, location or proposed mix of uses are determined by the local planning authority to require a masterplanning approach. A landscape/townscape character appraisal will be an essential prerequisite for concept statements, Development Briefs and Master Plans. Area Action Plans and Rural Site Allocations DPDs will define those sites where this approach is required. In Bury St Edmunds and Haverhill improvements to the environment of streets and spaces to secure attractive, safe and people-friendly town centres will be a priority. Proposals for new development in the towns will be required to contribute to improving the public realm. The Area Action Plans and the Development Management DPDs will include specific schemes and policies to support this. The promotion of secure attractive, safe and people-friendly streets, to encourage more walking, cycling, recreation and local shopping, will be a priority for the council. Where appropriate the street environment will be improved/developed with a combination of the following (not exclusive): Quality pavements and well-coordinated street furniture Improvements to footpaths and cycle routes Street trees and well-maintained landscaping Clear and minimal signage Traffic management schemes Shared spaces and home zones Cycle paths Crime deterrence and safety measures, including lighting and CCTV Public art

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New developments will be required to contribute towards public realm improvements. They should also provide active street frontages to create attractive and safe street environments.

Policy CS4 Settlement Hierarchy and Identity All proposals for new development will be expected to have regard to the position of the site within the settlement hierarchy. 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 and functional vitality of the settlement as a whole. The coalescence of towns with surrounding settlements through new development will not be allowed to happen.

Policy CS5 Affordable Housing Developers will be expected to integrate land for affordable homes within sites where housing is proposed, to ensure that affordable housing is provided and comes forward in parallel with market homes, with targets as follows;

1. Where sites are between 0.17 hectares and 0.3 hectares or between 5 and 9 dwellings, 20% shall be affordable.

2. Where sites are 0.3 hectares and above or 10 dwellings or more are proposed, at least 30% shall be affordable

3. On those broad locations for development, identified in policies CS11 and CS12, a target of 40% of affordable dwellings is set. This is subject to master planning and a viability review, the details for which will be set out in the Area Action Plans for Bury St Edmunds and Haverhill

These criteria shall also apply where a site is part of a wider but contiguous site.

Conditions or legal obligations will be used to ensure that affordable housing is secured and retained for those in housing need.

The mix, size, type and tenure of affordable homes should meet the local identified housing need and be appropriately weighted to ensure that the provision makes at least a proportionate contribution to the categories of greatest need. Where it is demonstrated / proven that such an approach is necessary, Exceptionally, the Local Planning Authority will consider issues of development viability and mix, including additional costs associated with the development of brownfield sites and the provision of significant community benefits, and may be willing to negotiate a lower percentage or tenure mix of affordable housing.

Note: This policy applies to both new build and conversion housing schemes Policy CS6 Gypsy and Traveller Accommodation In the countryside, proposals for gypsy sites and travelling show people will be permitted in accordance with the criteria outlined in Policy CS2 where: a) the site has been identified in the DPD, or in the interim, where satisfactory evidence supporting a need for the accommodation is provided; b) the use of the site would not have an adverse impact upon the amenities of nearby occupiers; c) the proposal would not detract from the undeveloped open and rural character and appearance of the countryside; and d) adequate landscaping measures are included. A condition or legal agreement to control the future use of sites for gypsies and travelling show people may be imposed, as appropriate. Where the proven need is short term the development will be limited by a temporary permission. A criteria based policy for selecting suitable sites will be set out in the Development Management DPD.

153 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Policy CS7 Sustainable Transport The council will develop and promote a high quality and sustainable transport system across the borough and reduce the need for travel through spatial planning and design

All proposals for development will be required to provide for travel by a range of means of transport other than the private car in accordance with the following hierarchy:

• Walking • Cycling • Public Transport (including taxis) • Commercial vehicles • Cars

All development proposals will be required to be accessible to people of all abilities including those with mobility impairments

Policy CS8 Strategic Transport Improvements The council will continue to work with relevant partners, including Suffolk County Council and the Highways Agency, and developers, to secure the necessary transport infrastructure to achieve improvements to:

Policy CS9 Employment and the Local Economy

Employment land at the Suffolk Business Park east of Bury St Edmunds (68.28 hectares) and Hanchett End at Haverhill (12 hectares) will be is allocated to enable the delivery of additional jobs in sustainable locations in the towns of Bury St Edmunds and Haverhill. Employment growth will also be achieved by the allocation of land for employment uses in mixed use developments in Bury St Edmunds, Haverhill, and the Key and Local Service Centres, and through policies supporting growth in the rural economy, retail, leisure and tourism. Existing General Employment Areas in or near Key Service Centres or Local Service Centres will continue to be protected and promoted for employment uses.

Policies in Local Development Documents will ensure that employment growth within a diverse local economy that will deliver a substantial proportion of the jobs target for “the Rest of Suffolk” identified in the East of England Plan. Growth will focus on Bury St Edmunds in the north of the borough to ensure that the town can fulfil its role as a Key Centre for Development and Change by providing for quality employment development at the Suffolk Business Park, and in the south of the borough growth will be concentrated in that Haverhill so that it can continue to meet the local employment needs in the Greater Cambridge area, particularly those of research and development and bio-technology industries. Policies in Development Plan Documents will ensure that Bury St Edmunds can fulfil its role as a Key Centre for Development and Change by providing for quality employment development at the Suffolk Business Park, and that Haverhill can continue to meet the local employment needs in the Greater Cambridge area, particularly those of research and development and bio- technology industries.

154 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report

Existing employment areas will continue to meet local and sub-regional needs at Clare, Great Wratting, Chedburgh, Barnham, Saxham and Stanton/Hepworth (Shepherd's Grove) Proposals for growth in Key Service Centres and Local Service Centres will be expected to include provision for employment land and premises to meet local needs and encourage sustainable communities including, where viable, integrated within strategic areas of growth. All employment proposals will be expected to meet the criteria set out in Policy CS2 to protect and enhance natural resources and ensure the sustainable design of the built environment.

Policies in Development Plan Documents will set criteria for the continued encouragement of sustainable employment development and tourism development opportunities (including conversion of suitable buildings) in villages and rural areas.

Policy CS10 Retail, Leisure and Cultural Provision The town centres of Bury St Edmunds and Haverhill will continue to be the focus for new retail, leisure, cultural and office development, taking into account; • the need to maintain their vitality and viability • the requirement to assess the need for future growth • the sequential approach to development • the impact of any development on existing centres • the need to ensure locations are accessible by a variety of modes of transport The 2007 Retail Appraisal identified the need for additional retail floorspace in Bury St Edmunds and Haverhill as outlined in the table below;

Location 2011 (sq m net) 2016 (sq m net) 2021 (sq m net) 5 Convenience Comparis Convenience Comparison Convenience Comparison Goods on Goods Goods Goods Goods Goods

Bury St 2,800 2,000 3,350 11,350 3,900 22,100 Edmunds Town Centre

Bury St -150 2,050 400 9,300 950 17,550 Edmunds Non- Central

Haverhill 2,100 2,250 2,400 3,600 2,650 5,050 Town Centre

Haverhill 0 -50 200 700 400 1,550 Non- Central

Since the Appraisal was completed, additional consents have been granted for (Asda) 3,400 sq metres net of convenience goods floorspace in Bury St Edmunds and (Tesco) 3,988 sq metres net of convenience goods floorspace in Haverhill. Retail and leisure activity elsewhere will be focused on those Key Service and Local Service Centres identified in Core Strategy Policy CS4 and in the new local centres located in the areas for growth identified in Policies CS11 and CS12. The development of services and facilities in these locations will be expected to be of an appropriate scale and character to reflect the role and function of the local centres and in accordance with the sequential approach. 1 The forecasts in the table are cumulative, i.e. the forecasts for each date include the

5 The forecasts in the table are cumulative, i.e. the forecasts for each date include the forecasts for the previous dates and are not additional to those earlier requirements.

155 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report forecasts for the previous dates and are not additional to those earlier requirements.

Policy CS11 Bury St Edmunds Strategic Growth

Subject to other relevant policies, in particular CS2, larger, strategic greenfield sites will be released around Bury St Edmunds in a phased manner having regard to the need to develop previously developed land first and to ensure that all essential infrastructure is in place before any development is occupied or as required by the local planning authority. Land will be released in the following locations in order to accommodate the long term strategic growth for the town: i) 2011 onwards - Limited growth to the north-west that: • Maintains the identity and segregation of Fornham All Saints; • Provides new high quality strategic public open space and recreation facilities between the development and Fornham All Saints; • Provides traffic relief for Fornham All Saints in the form of a relief road between the A1101 south east of the village and the B1106 to the south; • Delivers around 900 homes of mixed tenure and size, including affordable homes; • Provides opportunities for B1 use class local employment; • Delivers additional education, community and leisure facilities to meet the needs of this development and the deficits of the wider area; and • Provides improved public transport, foot and cycle links to the town centre and other locally significant leisure, employment and service destinations. ii) 2011 onwards – Limited growth completing the existing Moreton Hall urban extension by: • Completing the Eastern Relief Road to junction 44 of the A14 (Rookery Crossroads); • Making provision for a secondary school; • Providing additional recreation and community facilities, including the relocation of Bury Town Football Club; • Delivering up to 500 homes of mixed tenure and size, including affordable homes; • Providing improved public transport, foot and cycle links to the town centre and other locally significant leisure, employment and service destinations; • Enabling potential transport links to the north of the railway line; The additional housing will not be permitted until the completion of the Eastern Relief Road to junction 44 of the A14 (Rookery Crossroads) iii) After 2016 - Limited growth to the west that: • Maintains the identity and segregation of Westley; • Provides new high quality public open space and recreation facilities between the development and Westley; • Provides traffic relief for Westley in the form of a relief road to the east of the village; • Delivers around 450 homes of mixed tenure and size, including affordable homes; • Makes provision for the long term development of a sub-regional health campus (West Suffolk Hospital) set within high quality landscapes; • Delivers additional education, community and leisure facilities to meet the needs of this development and the deficits of the wider area; and • Provides improved public transport, foot and cycle links to the town centre and other locally significant leisure, employment and service destinations. iv) After 2021 - Long term strategic growth - north-east Bury St Edmunds that: • Maintains the identity and segregation of Great Barton and creates a new, high quality entrance to Bury St Edmunds; • Facilitates the provision of an A143 Great Barton bypass; • Contributes to reducing congestion at appropriate junctions on the A14 in Bury St Edmunds;

156 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report • Provides improved public transport, foot and cycle links to the town centre and south towards the A14 and strategic employment sites; • Delivers around 1,250 homes of mixed tenure and size, including affordable homes; • Provides opportunities for B1 use class local employment; • Provides new high quality strategic public open space and recreation facilities; and • Delivers additional education, community and leisure facilities to meet the needs of this development and the deficits of the wider area; v) After 2021 - Long term strategic growth – south-east Bury St Edmunds that: • Positively uses the framework for new development provided by the existing natural environment and character of the area including maintaining significantly important open spaces that provide the setting of the historic centre; • Makes a positive contribution to reducing the potential for flooding both in the area and downstream in the Lark Valley • Contributes to reducing congestion at appropriate junctions on the A14 in Bury St Edmunds; • Delivers a relief road that reduces levels of through traffic using the A134 Rougham Road and Sicklesmere Road; • Provides improved public transport, foot and cycle links to the town centre and north towards the A14 and strategic employment sites; • Contributes to reducing congestion at appropriate junctions on the A14 in Bury St Edmunds; • Provides new high quality strategic public open space and recreation facilities; and • Delivers additional education, community and leisure facilities to meet the needs of this development and the deficits of the wider area; • Delivers around 1,250 homes of mixed tenure and size, including affordable homes; • In each case, the actual amount of development will be determined by environmental and infrastructure considerations and the preparation and adoption of detailed masterplans in which the local community and other stakeholders have been fully engaged.

Policy CS12 Haverhill Strategic Growth Land north-west of Haverhill allocated in Policies HAV2 and HAV8 of the Replacement St Edmundsbury Borough Local Plan 2016 is confirmed by this Core Strategy, with the potential to deliver 1,100 new homes and other services and facilities and the north-west relief road. The development will be undertaken in accordance with the masterplan that was approved by the Council in June 2009. In addition, it will be necessary to release a larger, strategic greenfield site at Haverhill to deliver the development strategy of the Local Development Framework. Subject to other relevant policies, in particular CS2, the site will be released in a phased manner, having regard to the need to develop previously developed land first and to ensure that all essential infrastructure is in place before any development is occupied and that agreements are in place to deliver the desirable infrastructure required as a result of the development. Land on the north-eastern edge of Haverhill will accommodate the future long term strategic growth for the town subject to other relevant policies, in particular CS2, and will: •Maintain the identity and segregation of Kedington and Little Wratting; •Provide new high quality strategic public open space and recreation facilities; •Protect by appropriate means the Scheduled Ancient Monument at Wilsey Farm; •Deliver a north-east relief road for Haverhill between the A143 and the A1017 and the local distributor road network; •Provide improved public transport, foot and cycle links to the town centre and other locally significant destinations and other locally significant leisure, employment and service destinations; •Deliver additional education, community and leisure facilities to meet the needs of this development and the deficits of the wider area; •Deliver around 2,500 high specification eco-friendly homes of mixed tenure and size, including affordable homes; that are built to the minimum ; and

157 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report •Provide opportunities for B1 use class local employment. It is unlikely that the development at the north-eastern edge will commence before 2016. The actual amount of development will be determined by environmental and infrastructure capacity considerations and the preparation and adoption of detailed masterplans in which the local community and other stakeholders have been fully engaged.

Policy CS13 Rural Areas (New policy) The scale of development in Key Service Centres, Local Service Centres and Infill Villages, as defined in Policy CSX, 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. Development outside the settlements defined in Policy CSX will be strictly controlled, with a priority on protecting and enhancing the character, appearance and biodiversity of the countryside while promoting sustainable diversification of the rural economy. Policies in the Development Management DPD and Rural Site Allocations DPD will set detailed uses which are appropriate in rural areas. Policy CS14 Sequential approach to sites development

In accordance with the spatial strategy, and the criteria set out in other policies, particularly CS2, the Council will promote the re-use of previously developed land within housing settlement boundaries ahead of releasing strategic greenfield sites for new neighbourhoods. The need to release land for new neighbourhoods will be assessed against the delivery of housing within the towns concerned. Matters to be considered in making such an assessment will include:

• The potential to deliver national and regional targets for the development of previously developed land; • The projected delivery of the annual target for constructing new homes in the borough; • The delivery of required infrastructure; and • Achieving the objectives of the spatial strategy. Policy CS15 Community infrastructure capacity and tariffs

An Infrastructure Delivery Plan will be prepared to supplement the Core Strategy and ensure that development and the delivery of infrastructure is coordinated. All new proposals for development will be required to demonstrate that the necessary on and off-site infrastructure capacity required to support the development and to mitigate the impact of it on existing community facilities infrastructure exists or will exist prior to that development being occupied. In circumstances where the provision or improvement of infrastructure or other works or facilities is necessary, both within and beyond the borough boundary, to address community or environmental needs associated with new development or to mitigate the impact of development on the environment or existing communities, standard charges and/or standard formulae will be imposed for the payment of financial contributions towards such infrastructure, works or facilities to ensure that all such development makes an appropriate and reasonable contribution to the costs of provision.

The requirement to pay the standard charge and/or standard formulae will be reviewed and modified as appropriate in circumstances where the provision of infrastructure, works or facilities normally covered by standard charges is to be provided as part of the development proposals. The provision of infrastructure will be linked directly to phasing of development on land throughout the borough to ensure that there is no detrimental impact on existing infrastructure, the environment or residential amenity. It will be coordinated and delivered in partnership with other authorities and agencies such as the local highways authority, local education authority, the environment agency, primary care trusts, utility companies and other private and public sector partners. The Local Strategic Partnership will also have an important role to play in the co-ordination of infrastructure delivery. Key infrastructure requirements to deliver the objectives of the Core Strategy include, but are

158 St Edmundsbury Borough Council Local Development Framework: Core Strategy Submission Document Sustainability Appraisal Report not limited to: • New relief roads in Bury St Edmunds and Haverhill; • Improved sustainable transport links between new neighbourhoods and town centres and other destinations, including cycle networks; • Additional school place provision, including new school sites; • Junction improvements to A14; • Additional GPs and Dentists; • Local convenience shops and community facilities across the borough; • Leisure, open space, recreation provision and public realm enhancements; and • Additional substations and upgrades to wastewater works

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13. References

Countryside Council for Wales, et al. (June 2004), Strategic Environmental Assessment and Biodiversity: Guidance for Practitioners.

Countryside Council for Wales, et al (May 2004) (updated June 2007), Strategic Environmental Assessment and Climate Change: Guidance for Practitioners.

European Commission (2001) Directive 2001/42/EC "on the assessment of the effects of certain plans and programmes on the environment”.

ODPM (September 2005). A Practical Guide to the Strategic Environmental Assessment Directive.

ODPM (November 2005) Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents

Environmental Assessments of Plans and Programmes Regulations (Statutory Instrument 2004 no. 1633).

The Planning and Compulsory Purchase Act 2004

The Town and Country Planning (Local Development)(England) (Amendment) Regulations 2008

160

St Edmundsbury Borough Council Local Development Framework:

Core Strategy Submission Document

Final Sustainability Appraisal Report

Appendices

July 2009

Notice This report was produced by Atkins for St Edmundsbury Borough Council for the specific purpose of the Core Strategy Development Plan Document Sustainability Appraisal.

Document History

JOB NUMBER: 5081433 DOCUMENT REF: Final 5081433 SEBC CS SAR Appendices.doc

2 Final MJ MJ CW CW 14/07/09

1 1st Draft for Comment CS/OP/PN OP CW CW 23/06/09

Revision Purpose Description Originated Checked Reviewed Authorised Date

1 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Contents

Appendices Appendix A - Baseline Data Tables 4 Appendix B – Strategic Options Assessment Table 80 Appendix C – Strategic Sites Assessment Tables 86 Appendix D – Assessment of Plan Policies 143 Appendix E - Consultation Comments on Scoping Report 200 Appendix F - Consultation Comments on Initial Sustainability Appraisal (Issues and Options Report)209 Appendix G - Consultation Comments on Preferred Options and Strategic Sites Issues and Options SAR 231

List of Tables Table B.1 – Scoring of Assessment 81 Table B.2 - Assessment of Strategic Options for Spatial Strategy 82 Table C.1 – Key to Strategic Sites Assessment 87 Table C.2 – Bury St. Edmunds - Site 1 88 Table C.3 - Bury St. Edmunds - Site 2 93 Table C.4 – Bury St. Edmunds - Site 3 North of Westley Road 98 Table C.5 – Bury St. Edmunds - Site 3 South of Westley Road 103 Table C.6 - Bury St. Edmunds - Site 4 108 Table C.7 - Bury St. Edmunds - Site 4a 113 Table C.8 - Bury St. Edmunds - Site 5 118 Table C.9 - Bury St. Edmunds - Site 6 123 Table C.10 - Haverhill - Site 1 128 Table C.11 - Haverhill - Site 2 133 Table C.12 - Haverhill - Site 3 138 Table D.1 - Assessment Tables – Terms and Symbols 144 Table D.2 – Policy CS1 St. Edmundsbury Spatial Strategy & Policy CS5: Settlement Hierarchy and Identity145 Table D.3 - Policy CS2: Sustainable Development 150 Table D.4 - Policy CS3: The Natural and Built Environment 154 Table D.5 - Policy CS4: Design and Local Distinctiveness 157 Table D.6 - Policy CS6: Affordable Housing 161 Table D.7 - Policy CS7: Gypsy and Travellers Accommodation 164 Table D.8 - Policy CS8: Sustainable Transport 168 Table D.9 - Policy CS9: Strategic Transport Improvements 171 Table D.10 - Policy CS10: Employment and the Local Economy 174 Table D.11 - Policy CS11: Retail, Leisure and Office Development 177 Table D.12 - Policy CS12:Bury St Edmunds Strategic Growth 181 Table D.13 - Policy CS13:Haverhill Strategic Growth 188 Table D.14 - Policy CS14: Phasing 193 Table D.15 - Policy CS15: Infrastructure 196

2 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Table E.1 - Summary of Comments Made by Consultees on Scoping Report and how they have been incorporated into the SA Process 201 Table F.1 - Consultation comments on St Edmundsbury Core Strategy Issues and Options Initial SAR 210 Table G.1 – Consultation comments on St Edmundsbury Core Strategy Preferred Options and Strategic Sites Issues and Options SAR 232

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Appendix A - Baseline Data Tables

4 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

SOCIAL

Population St Edmundsbury 2007 East of England: No target St Edmundsbury population The population of St Defra East of Population Mid-year population estimate: 2007 (mid-year population identified. 2006: Edmundsbury has England estimate): 5,661,300 102,000 persons grown significantly Factsheet, 2008 102,900 persons over the past two persons Office for decades. This National 2006: 5,606,600 persons Between 1981 and 2006, the growth is expected (2,752,700 male; 2,853,800 Statistics population of St Edmundsbury to continue, Regional Trends female) has grown by 16.9%, particularly with the Report 2008 compared with a growth rate identification in the East of England Plan England: of 15.5% in the East of England and 8.4% in England. of Bury St Edmunds 2006: 50,762,900 persons as a key centre for (24,926,400 male; development and 25,836,600 female) change (Policy BSE1) and the requirement for additional housing and employment opportunities within the Borough.

Proportion of St Edmundsbury, 2007: East of England, 2001: No targets No trends identified The proportion of St SEBC Recycling Population the Urban population: 57,855 Urban population: 62.3% of identified Edmundsbury’s Plan 2006 – population (57% of Borough population) Regional population population that lives 2012 living in in rural areas is urban areas Rural population: 43,645 (43% Rural population: 37.7% of higher than that for of Borough population) Regional population both the East of England and England. England, 2001: Urban population: 76.7% of country population Rural population: 23.3% of country population`

5 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

Age structure St Edmundsbury East of England: No target St Edmundsbury The age profile of St ONS, reported in Population 2007 Mid-year population 2007 Mid-year population identified. change in population (as a % Edmundsbury SEBC LDF estimate number and estimate number and of total population) between broadly reflects that Annual percentage of total population percentage of total 2002 and 2007: of the East of Monitoring England. However, Report 2007-08 within different age bands: population within different All ages:+4.4% age bands: the growth in the 0-15 years: 17,900 (17.3%) Children and young people: number of older 16-24 years: 11,500 (11.1%) 0-15 years: 1,007,900 +1.6% people in the (17.8%) Borough is almost 25-44 years: 28,200 (27.4%) Working age: +2.1% 16-24 years: 700,600 double that 45-64 years: 27,100 (26.3%) (12.3%) Older people: +14.7% experienced in the East of England as a 65-74 years: 9,600 (9.3%) 25-44 years: 1,555,600 whole. 75+ years: 8,600 (8.3%) (27.4%) In the rural areas of St 45-64 years: 1,477,200 Edmundsbury, the proportion (25.5%) of the population aged 0-24 65-74 years: 484,800 (8.5%) years is lower than that for the Borough as a whole; the 75+ years: 465,200 (8.2%) proportion of the population aged 65+ is higher than that East of England: for the Borough as a whole. Change in population (as a % of total population) between 2002 and 2007: All ages:+4.2% Children and young people: -0.2% Working age: +4.2% Older people:+8.8%

Ethnicity St Edmundsbury East of England: No target St Edmundsbury The proportion of St ONS, reported in Population 2007 (% of total population): 2007 (% of total population) identified. 2001 (% of total population): Edmundsbury’s SEBC LDF population who are Annual White: 96.1% White: 92.2% White: 98.03% white is higher than Monitoring that of both the East

6 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Mixed: 1.0% Mixed: 1.5% Mixed: 0.73% of England region Report 2007-08 Asian or Asian British: 1.0% Asian or Asian British: 3.3% Asian or Asian British: 0.47% and England as a whole. However, the Black or Black British: 0.9% Black or Black British: 1.8% Black or Black British: 0.35% proportion of white Chinese or Other Ethnic Chinese or Other Ethnic Chinese or Other Ethnic residents in St Group: 1.0% Group: 1.2% Group: 0.42% Edmundsbury has decreased since

2001, with a growth England: in the number of 2007 (% of total population) black and minority ethnic groups. White: 88.6% Mixed: 1.6% Asian or Asian British: 5.5% Black or Black British: 2.8% Chinese or Other Ethnic Group: 1.4%

Gender St Edmundsbury East of England No target set No trend data is available The gender split in 2001 Census Population 2001 Census: 2001 Census: St Edmundsbury is data more even than that Females:49,507 persons Females: 2,749,805 in East of England (50.42% of total population) persons (51.03% of total and England. Males:48,686 persons population) (49.58% of total population) Males: 2,638,335 persons (48.97% of total population)

England 2001Census: Females: 25,216,687 persons (51.32% of total population) Males: 23,922,144 persons (48.68% of total population)

7 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

Proportion of St Edmundsbury East of England No target set No trend data available. The religious profile 2001 Census Population population 2001 Census: 2001 Census: of St Edmundsbury stating their is broadly similar to religion Christian: 74.26 % Christian: 72.14% that of the East of Buddhist: 0.17% Buddhist: 0.22% England and England, with a Hindu: 0.10% Hindu: 0.58% slightly higher Jewish: 0.12% Jewish: 0.56% proportion of Muslim: 0.28% Muslim: 1.46% Christians and slightly lower Sikh: 0.02% Sikh: 0.25% proportion of Other Religion: 0.25% Other Religion: 0.29% Muslims. No Religion: 16.77% No Religion: 16.74%

England 2001Census: Christian: 71.74% Buddhist: 0.28% Hindu: 1.11% Jewish: 0.52% Muslim: 3.1% Sikh: 0.67% Other Religion: 0.29% No Religion: 14.59%

Proportion of St Edmundsbury East of England No target No trend data available The proportion of the Census 2001 Population, the 2001 Census: 2001 Census: identified Borough’s Human population population with a Health with limiting 11,846 persons with limiting 686,737 persons with limiting long term long term long term illness. This is limiting long term illness. illness is similar to illness 29.91% of the population of This is 30.77% of the that for the East of the Borough. population of the region. England and lower

8 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) England than that for the 2001Census: Country. 6,862,037 persons with limiting long term illness. This is 33.55% of the population of the country.

Self St Edmundsbury: East of England: No target No trend data available The self-assessed 2001 Census Population, assessed Proportion of the population Proportion of the population identified health of residents of Human health who in 2001 assessed who in 2001 assessed St Edmundsbury is Health themselves as being in: themselves as being in: similar to that of the East of England and Good Health: 70.87% Good Health: 70.35% better than that of Fairly Good Health: 22.09% Fairly Good Health: 22.05% England as a whole. Not Good Health: 7.04% Not Good Health: 7.60%

England: Proportion of the population who in 2001 assessed themselves as being in: Good Health: 68.76% Fairly Good Health: 22.21% Not Good Health: 9.03%

Percentage St Edmundsbury: Suffolk: To increase % The proportion of rural The percentage of Suffolk’s Population of rural Total Rural Population: Total rural population: of rural population with access to all rural population with Environment population population five listed services appears access to all five Annual living in 2004/05: 41,136 2004/05: 217,776 living in to be relatively stable. With listed facilities 04/05 Monitoring parishes parishes with 47.8% of the rural population in St Edmundsbury Report 2004/5 which have a access to 5 having access in 2003/04. is significantly above Rural Population living in Rural Population living in St Edmundsbury food shop or services. However, access is expected the figure for Suffolk. parishes with access to all five parishes with access to all LDF Annual general to decrease as a result of St Edmundsbury listed facilities: five listed facilities: Monitoring store, post likely forthcoming closures of figure for 04/05 Report 2007/08 office, pub, 2004/05: 20,465 2004/05: 71,883 4 post offices and 1 food remains higher than

9 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) primary shop. the baseline for school and % of rural population with % of rural population with 2001/02. The rural meeting access to all five listed access to all five listed population of St place facilities: facilities: Edmundsbury is relatively well 2004/05: 47.71% 2004/05: 33% provided with facilities.

Percentage St Edmundsbury: Suffolk: To achieve a St Edmundsbury: The percentage has Suffolk’s Population of Rural 2005/06: 35.8% 2005/06: 42.5% one-third 2004/05: 32% increased so that Environment Households increase in % over one third of Annual within 13 2004/05: 37.2% of households 2003/04: 24.3% rural households are Monitoring minutes’ 2003/04: 26% in rural areas 2002/03: 22.7% within 13 minutes Report 2005/06 Walk of an within about walk of an hourly 2002/03: 22.7% 2001/02: 23% Hourly Bus 10 minutes bus service. Service 2001/02: 23% walk of hourly However, in recent or better bus years the service by percentage in St 2010 Edmundsbury has (Transport fallen below that of Ten Year Suffolk as a whole. Plan, 2000).

Proportion of St Edmundsbury No comparator data No target No trend data available. A high percentage of Suffolk County Population population Households (2004) within 15 available. identified. the borough’s Council - DfT with access or 30 minutes of a food shop households have accessibility to a food by public transport: access to a food shop shop within 15 or 30 15mins: 26,295 (64.8%) minutes by public 30mins: 36,086 (88.9%) transport.

Households (2004) without access to a car within 15 or 30 minutes of a food shop by public transport: 15mins: 5,352 (78.5%)

10 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 30mins: 6,452 (94.7%)

Proportion of St Edmundsbury: East of England: None St Edmundsbury: A relatively high Suffolk County Population, population Households (2005) within 30 Households (2005) within 30 identified proportion of Council Human with access and 60 minutes of a hospital and 60 minutes of a hospital Households (2004) within 30 households in the DfT accessibility Health to hospital or by public transport: by public transport: and 60 minutes of a hospital borough appear to indicators GP or dentist 30mins: 1917158 (83.3%) by public transport: have reasonable surgery 30mins: 38,729 (92.3%) access to hospitals SCC local 60mins: 2290021(99.6%) 30mins: 23,849 (58.8%) Transport Plan 60mins: 41,983 (100%) and GP surgeries. 60mins: 38,666 (95.3%) 2016 – 2011 Generally figures for access in St St Edmundsbury: East of England: Edmundsbury Households (2005) without St Edmundsbury: Households (2005) without compare favourably access to a car within 30 access to a car within 30 and Households (2004) without to data available for and 60 minutes of a hospital 60 minutes of a hospital by access to a car within 30 and the East of England, by public transport: public transport: 60 minutes of a hospital by with marginally public transport: 30mins: 6,541 (93.07%) 30mins: 387922 (85.4%) better access to a 60mins: 452876 (99.7%) 30mins: 5,030 (73.8%) hospital but 60mins: 7,028 (100%) marginally worse 60mins: 6,657 (97.7%) access to a GP.

St Edmundsbury: East of England: St Edmundsbury: Households (2005) within 15 Households (2005) within Accessibility to GP and 30 minutes of a GP 15 and 30 minutes of a GP Households (2004) within 15 and Hospitals in St surgery by public transport: surgery by public transport: and 30 minutes of a GP Edmundsbury surgery by public transport: improved between 15mins: 35,190 (83.8%) 15mins: 1957,284 (85.1%) 15mins: 27,912 (68.8%) 2004 and 2005. 30mins: 41,983 (100%) 30mins: 2293,449 (99.7%) 30mins: 38,339 (94.5%)

St Edmundsbury: East of England: St Edmundsbury: Households (2005) without Households (2005) without access to a car within 15 and access to a car within 15 Households (2004) without 30 minutes of a GP surgery by and 30 minutes of a GP access to a car within 15 and public transport: surgery by public transport: 30 minutes of a GP surgery by public transport: 15mins: 6,002 (85.4%) 15mins: 399,080 (87.9%) 15mins: 5,563 (81.6%)

11 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 30mins: 7,028 (100%) 30mins: 453,601 (99.9%) 30mins: 6,676 (97.9%)

No data is currently available No data is currently for access to dentist surgery. available for access to dentist surgery.

Overall death Suffolk West Primary Care East of England: Reduce the Suffolk West Primary Care Crude mortality rates NHS Population, rate by all Trust* crude mortality rates Crude mortality rate from all number of Trust* crude mortality rates for West Suffolk PCT Office for Human causes per (deaths per 100,000 residents) causes in 2005: 940 early deaths (deaths per 100,000 and standardised National Health 100,000 from all causes: residents) all causes mortality rates for St Statistics population 2005: 951.9 2004: 922.1 Edmundsbury are Regional Trends Standardised mortality ratio comparable with Report 2008 (UK=100): 2003: 979.0 those for East of England and Office for *Data not available for just St 2005: 93 2002: 1004.6 England. National Edmundsbury as health care in 2001: 984.1 Standardised St Edmundsbury is provided 2002: 92 Statistics mortality ratio (UK=100) in Mortality rates Regional Trends as part of the Suffolk West 2002: fluctuate but can be Report 2004 Primary Care Trust. seen to have England: St Edmundsbury: 91 decreased on the Crude mortality rate from all whole between 2001 Standardised mortality ratio causes in 2005: 950 and 2005. (UK=100) in 2005: Standardised mortality ratio St Edmundsbury: 94 in 2005: 98

Number of St Edmundsbury RTA 2006 fatal and serious Reduce the St Edmundsbury 2004: Decrease in the Suffolk County Population, people killed casualties: accidents on all roads per number of Fatal: 8 number of people Council Human and seriously 2005: 100,000 population: people killed killed or seriously Defra East of Health injured (KSI) or seriously Serious: 60 injured was Fatal: 7 East of England: 51.9 England in road traffic injured in road KSI / 100,000 pop: 67.7 observed between Factsheet, 2008 accidents England: 47.7 accidents in 2004 and 2005. The Serious: 45 (RTA) per Suffolk KSI in RTAs rate for Office for KSI / 100,000 pop: 51.77 100,000 St Edmundsbury is National population comparable to that Statistics Regional Trends of the East for England but higher Report 2008 than that for

12 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) England.

Life St Edmundsbury: East of England: None St Edmundsbury: The average life Suffolk Population, expectancy 2004 – 2006: Average 2006: identified. 2002 – 2004: expectancy of males Observatory Human (years) and females in the Health Male: 78.6 years Male 77.3 years Male: 77.5 years Defra East of borough compares England Female: 82.7 years Female 81.4 years Female: 81.9 years very favourably to Factsheet, 2008 that for the East of

England and St Edmundsbury East of England 2001-2003: England with LDF Annual Monitoring 2002 – 2004: Male 77.3 years consistently above average life Report 2007/08 Male: 77.6 years Female 81.7 years expectancies for Female: 81.6 years both male and female residents. Data indicates that life England: expectancy for both sexes has been increasing in each 2002 – 2004 monitoring period. Male: 76.4 years Female: 80.8 years

Change in St Edmundsbury accessible No comparator data Increase in the Limited data currently Whilst limited data is Suffolk Biological Population, amount of natural green space* (Aug available. amount of available. available, SEBC are Records Office Human accessible 2006): accessible committed to Health, natural green 3375.2 ha natural green increasing the Biodiversity, space space by 5% amount of Flora, Fauna (Districts) *Accessible Natural Green by 2010 accessible Space = Publicly accessible greenspace within site greater than 2ha in area the Borough. and managed with wildlife as a key element.

% of year 11 St Edmundsbury: East of England: None St Edmundsbury: Performance in St Suffolk Population pupils 2007: 70.7% 2007: 64.8% identified 2005: 67.4% Edmundsbury is Observatory gaining 5+ improving each year 2005/06: 59.3% 2004: 65.0% Office for A*-C grades and is above National regional and national

13 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) at GCSE figures. Statistics England: Regional Trends Report 2008 2007: 62.0% St Edmundsbury 2005/06: 59.2 LDF Annual Monitoring Report 2007/08

Proportion of St Edmundsbury % of population aged 16-64 None % of population in 2001 aged The percentage of Suffolk Population the % of population aged 16-74 (male) and 16 to 59 (female) identified. 16-74 with no qualifications: the population with Observatory population with no qualifications, 2007: with no qualifications in St Edmundsbury: 28.1% no qualifications Census 2001 with no 2007: increased between qualifications 36.3% 2001 and 2007 and St Edmundsbury East of England: 12.4% LDF Annual is significantly higher England:13.2% than figures for the Monitoring East of England and Report 2007/08 England. % of population in 2001 aged 16-74 with no qualifications: England: 28.9%

Working age St Edmundsbury: National mean % of the None St Edmundsbury: The proportion of the Suffolk Population population Number (%) working age population who identified. 2006: 29% working age Observatory with NVQ are qualified to NVQ4 and population with NVQ 2007: 14,900 (24.7%) 2005: 24.8% St Edmundsbury level 4 or above: level 4+ LDF Annual higher 2006: 30.72% 2004: 15.4% qualifications in St Monitoring Edmundsbury can Feb 2003 - 04: 9000 (15.4%) Report 2007/08 be seen to fluctuate. Feb 2002 - 03: 12000 (20.4%) The proportion is Audit Commission - Feb 2001 - 02: 14000 (23.6%) slightly lower than the national average. www.areaprofiles .audit- commission.gov. uk

14 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

Crime rate St Edmundsbury East of England: None St Edmundsbury Trend data shows a Suffolk Population, per 1000 Number of crimes per 1,000 Recorded crime rate/1,000 identified. Number of crimes per 1,000 fluctuating crime rate Observatory Human population population: population: population: in the borough with a Defra East of Health significant reduction 2007 – 08: 69.2 2007/08: 75 2005 - 06: 81.1 England in crime between Factsheet, 2008 2005/06: 85.90 2004 - 05: 76.8 2005/06 and 2007/08 reversing Office for 2003 - 04: 69.6 the previously National England: 2002 - 03: 73.3 observed increasing Statistics Regional Trends Recorded crime rate/1,000 2001 - 02: 70.7 crime rate trend. Crime rates in St Report 2008 population: 2000 - 01: 67.4 Edmundsbury are St Edmundsbury 2007/08: 91 lower than those for LDF Annual 2005/06: 104.24 East of England and Monitoring England. Report 2007/08 Home Office Crime in England and Wales Report 2007/08

Fear of Percentage of residents National mean percentage To reduce the Percentage of residents The proportion of Suffolk Speaks, Population, Crime surveyed who say that they of residents surveyed who number of surveyed who say that they residents who feel British Crime Human feel fairly safe or very safe say that they feel fairly safe recorded feel fairly safe or very safe safe or very safe in Survey Health outside during the day or very safe outside during incidents of outside during the day St Edmundsbury Audit 2006/07: 98.32% the day anti-social 2005/06: 98.3% during the day is Commission - 2006/07: 97.38% behaviour by above the national www.areaprofiles 5% by 2008 2004/05: 98.2% mean and is .audit- Percentage of residents (Suffolk LAA increasing. The commission.gov. 2005 – 2008) proportion of surveyed who say that they Percentage of residents Percentage of residents uk residents who feel feel fairly safe or very safe surveyed who say that they surveyed who say that they safe after dark outside after dark feel fairly safe or very safe feel fairly safe or very safe fluctuates but is 2006/07: 73.64% outside after dark outside after dark broadly comparable 2006/07: 71.02% 2005/06: 70.4% to the national mean.

St Edmundsbury 2005: 2004/05: 75.6% % of respondents who feel

15 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) safe in the area where they live: 91%

% of respondents who feel their area is safe with low levels of crime and disorder: 65%

Number / St Edmundsbury Suffolk: None St Edmundsbury Limited information SCC Racial Population, rate of racist Racial incidents: April 2006 – March 2007: identified. April – Dec 2004: 56 incidents available. The rate of Harassment Human incidents racist incidents in St Initiative Health April 2006 – March 2007: 60 445 incidents Proportion per 1,000 Edmundsbury www.suffolk.gov. incidents Proportion per 1,000 population: 0.5 increased between uk Proportion per 1,000 population: 0.7 (based on 2004 and 2007 but is population: 0.6 mid-2005 population lower than that for estimates) Suffolk.

Number of St Edmundsbury: No comparator data None St Edmundsbury: The number of noise SEBC Human domestic and 2005/06: 465 available identified 2004/5: 419 complaints, Environmental Health commercial particularly domestic Health noise 2003/4: 483 complaints fluctuates Department complaints 2002/3: 411 but can be seen to have increased

overall between 2002 and 2006.

Proportion of St Edmundsbury: Suffolk: None St Edmundsbury: Low levels of Index of Multiple Population, Lower Super 2007 IMD: 2007 IMD: identified. 2004 IMD: deprivation in Deprivation Human Output Areas comparison with (IMD) – Data Health assessed as Most deprived 10% = 0% Most deprived 10% = 3.06% Most deprived 10% = 0% Suffolk. However, available from being the Most deprived 25% = 0% Most deprived 25% = 3.06% Most deprived 25% = 0% the rankings show Department for most that LSOAs in Communities Most deprived 40% = 11.7% Most deprived 40% = Whilst the overall rank of St deprived Haverhill are more and Local 10.35% Edmundsbury is good, both 10% and consistently Government and the borough’s score and 25% of deprived; suggesting Suffolk County St Edmundsbury: ranking has declined since the wards in the that deprivation in Council 2007 IMD Rank: 260 last Index of Deprivation in country Haverhill is more St Edmundsbury

16 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 2004. widespread rather LDF Annual than just Monitoring concentrated in Report 2007/08 St Edmundsbury: small pockets. Suffolk County 2004 IMD Rank: 267 Furthermore, the Council Index of borough’s IMD rank Multiple decreased from Deprivation 2004 to 2007, Results 2008 meaning that St Edmundsbury became more deprived in comparison with the rest of the nation during this period. Policy SS11 requires that Local Development documents set out policies to tackle the problem of economic, social and environmental deprivation in these areas. Of particular note are the large rural hinterlands, including those in St Edmundsbury, where the levels of deprivation have increased both relative to elsewhere in England and in terms of actual

17 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) scores.

Number of St Edmundsbury: Percentage of all None St Edmundsbury: The uptake of SEBC Housing Population housing March 2008: 4936 (approx. households claiming identified March 2007: 4814 housing benefits has Benefit benefit 11% of all households1) housing benefit in 2005.06: steadily increased Department recipients May 2006: 4760 since 2003, East of England: 12% Office for May 2005: 4530 suggesting that there National England: 14% is insufficient May 2004: 4387 Statistics affordable housing Regional Trends May 2003: 4210 available within St Report 2008 Edmundsbury. St Edmundsbury LDF Annual Monitoring Report 2007/08

Unemployme St Edmundsbury: East of England: None St Edmundsbury: Despite an increase Suffolk Population, nt rate – (%) July 2008 – 1.6% May 2007: 4.8% identified. May 2006: 1.7% in recent years, Observatory Material unemployed unemployment Assets May 2006: 5.2% May 2005: 1.3% Office for persons levels for St National May 2005: 4.0% May 2004: 1.2% Edmundsbury Statistics remain well below May 2004: 3.8% May 2003: 1.3% Regional Trends regional and national Report 2008 May 2003: 4.0% levels. St Edmundsbury

In 2008, St LDF Annual England: Edmundsbury was Monitoring the local authority Report 2007/08 May 2007: 5.5% with the highest May 2006: 5.7% employment rate in Great Britain outside May 2005: 4.8% London. May 2004: 4.8% May 2003: 5.0%

1 Atkins’ calculation of a proportion of housing benefit recipients based on the assumption that there are 46,099 households in St Edmundsbury according to the most recent Council Tax figures.

18 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

Long-term St Edmundsbury: Suffolk unemployment by None St Edmundsbury: St Edmundsbury has Suffolk Population, unemployme < 6 months: duration: identified. unemployment by duration: relatively low long- Observatory Material nt term (6+ months) Assets March 2006: 75.6% < 6 months: < 6 months: unemployment. 6 - 12 months: March 2006: 71.7% March 2005: 76.8% Rates are below those for Suffolk. March 2006: 13.2% March 2005: 70.7% March 2004: 76.2% 12 - 24 months: March 2004: 67.2% March 2003: 77.5% March 2006: 7.8% March 2003: 69.9% 6 - 12 months: 24> months: 6 - 12 months: March 2005: 12.9% March 2006: 3.4% March 2006: 15.4% March 2004: 12.5% March 2005: 14.2% March 2003: 14.2% March 2004: 15.9% 12 - 24 months: March 2003: 16.3% March 2005: 7.1% 12 - 24 months: March 2004: 8.8% March 2006: 8.9% March 2003: 5.9% March 2005: 8.8% 24> months: March 2004: 11.7% March 2005: 3.2% March 2003: 9.1% March 2004: 2.5% 24> months: March 2003: 2.4% March 2006: 3.9% March 2005: 6.2% March 2004: 5.2% March 2003: 4.7%

Average St Edmundsbury mean annual Mean 2005: None St Edmundsbury mean annual While figures show National Population, Earnings pay (gross) for full-time East of England: £30,640 identified. pay (gross) for full-time an upward trend for Statistics - Material employee jobs: employee jobs: pay in the borough Annual Survey of Assets GB: £28,398 2005: £27,958 2004: £26,431 rates are still below Hours and Median April 2007: that for the East of Earnings 2003: £18,358 England and

19 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) St Edmundsbury median East of England: £24,913 2002: £20,579 England. The annual pay (gross) for full-time England: £24,055 median figures also Office for employee jobs: indicate that there St Edmundsbury median National 2007: £21,871 are a lot of low paid Statistics Median 2005: annual pay (gross) for full-time jobs in the borough. employee jobs: Regional Trends East of England: £24,364 Report 2008 2005: £20,594 GB: £23,027 2004: £19,680

2003: £16,027 2002: £16,552

Annual net St Edmundsbury: East of England: Proposed East St Edmundsbury: Although in 2006/07 East of England Population, dwelling 2007/08: 546 completions 2006/07: 24,799 of England 2006/07: 536 completions the number of Plan Annual Material completions annual target housing completions Monitoring Assets East of England average of housing in St Edmundsbury Report 2006/07 annual completions between completions St Edmundsbury average was above the H1 2001 and 2007: 21,761 for St annual completions between policy target, in Edmundsbury 2001 and 2007: 415 previous years the (Policy H1) number of between 2001 completions has not and 2021: 500 reached the target level. As such, an increase in the number of completions each year will be required in order to meet the East of England Plan target.

Affordable St Edmundsbury net affordable East of England net Policy H3 - St Edmundsbury net Proportion of Suffolk’s Population, Housing completions: affordable completions and Affordable affordable completions: affordable Environments Material 2007/08: 136 completions percentage of overall Housing of the 2004/05: 20 completions has Monitoring Assets (25%) completions each year: Replacement increased Report 2004/05 St 2003/04: 19 significantly between (SSAG) With a further 158 net number 2006/07: 4,411 (18%) Edmundsbury 2002/03: 75 2004/05 and SEBC Planning

20 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) of units for affordable housing 2005/06: 4,042 (17%) Borough Local 2001/02: 40 2007/08, reversing a Department approved in 2007/08. 2004/05: 3,682 (17%) Plan 2016: trend of decreasing East of England 40% completion numbers Plan Annual 2003/04: 2,182 (11%) Affordable housing in recent years. The affordable completions as a percentage Monitoring 2002/03: 2,166 (11%) housing on: proportion of net Report 2006/07 of total completions: completions which 2001/02: 1,939 (10%) i) sites of 0.5+ Audit ha or 15+ 2004/05: 10.6% were affordable in St Edmundsbury is Commission - dwellings, in 2003/04: 8.35% www.areaprofiles settlements of higher than for the 2002/03: 53.55 East of England. .audit- 3,000+ commission.gov. ii) sites of uk 0.17+ ha or 5+ dwellings, in settlements of less than 3000

Provision for St Edmundsbury East of England authorised The East of No trend data is available. The Borough is not East of England Population, gypsy and authorised pitches, January pitches, January 2006: England Plan on track to reach the Plan Annual Material traveller 2006: Public: 885 sets a target in Policy H4 target. An Monitoring Assets pitches Policy H4 of additional 15 pitches Report 2006/07 Public: 0 Private: 963 17 pitches in will be required by Private: 2 St 2011. Edmundsbury by 2011.

Special St Edmundsbury Special No comparison data Cambridge St Edmundsbury Special The proportion of SEBC Strategic Population, Needs needs housing completions: available. sub-region, needs housing completions: housing completions Housing Material Housing 2005/06: 06 2006 – 08, 2% 2004/05: 21 which are special Department Assets of housing to needs fluctuates but be special 2003/04: 11 is significantly higher St Edmundsbury Special needs. 2002/03: 76 than the target set for the Cambridge needs housing completions 2001/02: 40 expressed as a % of all sub-region.

housing completions in the borough: St Edmundsbury Special 2004/05: 12.3% needs housing completions

21 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) expressed as a % of all housing completions in the borough: 2003/04: 1.8% 2002/03: 16.2% 2001/02: 11.8%

Number of St Edmundsbury (April 1st HIP In 2003, percentage of None St Edmundsbury (April 1st HIP RSL figures are at SEBC Strategic Population, homes returns) RSL: dwellings rented from RSL: identified. returns) RSL: their lowest since Housing Material managed by 2006: 7238 (approx. 16%2) East of England: 7% 2005: 7322 2003 although still Department – Assets Registered above the 2002 Housing Social *RSL provide homes and England: 8% 2004: 7388 baseline. However, Investment Landlords housing services to people in 2003: 7351 it is a high Programme (RSL*) housing need. There are percentage (HIP) Returns various types of RSL such as 2002: 1187 compared to the Office for housing associations, housing 2001 Census: 3.4% regional and national National cooperatives and charitable averages. trusts. All RSL are non-profit Statistics making and are entirely Regional Trends separate and independent Report 2008 from the council.

Dwellings per St Edmundsbury Dwellings per East of England: “To avoid 170 dwellings were built in The density of SEBC Planning Material hectare of hectare: 1994: 23 dwellings/ha developments 2004-5, of which: dwelling completions Department – Assets Net which make can be seen to have Housing Land 546 net completions in 2006: 36 dwellings/ha 43% = <30 dwellings/ha Developable 2007/08, of which: inefficient use increased since Availability Study Area of land” 41% = 30-50 dwellings/ha 2003 and to be 37.9% <30 dwellings/ha Defra East of (PPG3). 16% = 50> dwellings/ha above the figures for England Recommende East of England. 24.4% 30-50 dwellings/ha Factsheet, 2008 d minimum Over 60% of housing 37.7% >50 dwellings/ha guideline = 30 2003/04: 48 dwellings/ha completions in St Edmundsbury LDF Annual dwellings/hect 2002/03: 28 dwellings/ha 2007/08 were also are. above the PPG3 Monitoring

2 Atkins’ calculation of a proportion of homes managed by RSL based on the assumption that there are 46,099 households in St Edmundsbury according to the most recent Council Tax figures.

22 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 2001/02: not recorded recommended Report 2007/08 2000/01: 37 dwellings/ha minimum. This indicator measures completions on large sites (10+ units) and many of the permissions coming through were granted some years ago.

Average St Edmundsbury average Average property price in None St Edmundsbury average House prices in St Suffolk Population, property property price (1st quarter): the last quarter of 2006: identified. property price (1st quarter): Edmundsbury have Observatory Material price and 2008 (2nd quarter): £197,503 East of England: £220,000 2006: £193,424 risen steadily since Office for Assets Housing 2003 and are England: £205,000 2005: £188,280 National Affordability * consistently above Statistics (average St Edmundsbury Housing Suffolk average property 2004: £170,399 the Suffolk average. Regional Trends ratio) However, average Affordability (average ratio – price (1st quarter): 2003: £150,217 Report 2008 ST house prices in the 1 Qtr): 2006: £176,076 Borough are lower St Edmundsbury 2006/07: 8.86 LDF Annual 2005: £174,579 St Edmundsbury Housing than those for East Monitoring *The Housing Affordability ratio 2004: £158,490 Affordability (average ratio – of England and Report 2007/08 determines the affordability of 1ST Qtr): England. housing by comparing the 2003: £139,942 Housing affordability average house price for each 2006: 7.87 average ratios have housing category against East of England Housing 2005: 7.66 increased steadily average incomes. The Affordability (average ratio – 2004: 7.34 since 2003, and are calculation assumes a 5% 1ST Qtr): currently significantly deposit therefore the ratio is 2003: 6.53 higher than those for that of average house price 2006/07: 7.72 East of England multiplied by 95% to average region, indicating income. major housing affordability problems.

23 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

Number of 1st April 2006 St Proportion of dwellings None No trend or comparator data The number of unfit SEBC Population, unfit homes Edmundsbury: failing to meet ‘Decent identified. is currently obtainable. dwellings in the Defra East of Material per 1,000 Total number of dwellings in Homes’ standard in 2003: borough should be England Assets dwellings the borough: 44,680 East of England: 27% reduced. Factsheet, 2008 Number unfit dwellings: 1,443 England: 31% Number of unfit homes per 1,000 dwellings: 32.3

Number and 5,800 (15.5%) dwellings are None No trend or comparator data There is a clear SEBC Material percentage estimated to have at least one identified. is currently obtainable. association between Assets, of estimated Category 1 Hazard. Category Category 1 Hazards Population, as having 1 Hazards are associated with and low income Human Category 1 pre-1919 dwellings, the households and Health Hazard privately rented sector, those with heads of under detached houses and household over 60. Housing bungalows. There was no Health and elevated level of Safety Rating Category 1 Hazards System where households were in receipt of benefit, where residents had a disability and where the head of household was under 25 years. The highest proportion of Category 1 Hazards by area was found in the Rural sub-area at 24.8% followed by the Bury St Edmunds sub-area at13.4%.

24 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

Number and St Edmundsbury net Percentage of total dwelling Regional St Edmundsbury net Figures fluctuate SEBC Planning Material percentage completions on PDL: completions on PDL in East target of 50% completions on PDL: however the Department Assets, Soil of new 2007/8: 297 (= 54.4% of total of England: (RPG6). 2006/7: 43% borough has met its East of England dwellings completions) 2006/07: 72% No specific target every year Plan Annual completed on 2004/5: 72 since 2002. The 2005/06: 71% target for Monitoring previously Suffolk. (= 42.4% of total completions) proportion of Report 2006/07 developed completions on PDL 2004/05: 71% 2003/4: 294 land (PDL) Borough in St Edmundsbury St Edmundsbury 2003/04: 64% target of 40% (= 48.0% of total completions) is significantly lower LDF Annual from SEBC Monitoring 2002/03: 59% 2002/3: 267 than that for the East Replacement Report 2007/08 2001/02: 57% of England as a Local Plan (= 57% of total completions) whole. However, it

PPG3: 60% 2001/2: 101 may be due to a generally lower level on brownfield. (= 30% of total completions) of PDL availability in RPG: 50% on the borough. brownfield.

Number of St Edmundsbury: East of England: None St Edmundsbury: Records indicate SEBC – Material vacant all vacant dwellings: Local Authority vacant identified. all vacant dwellings: that the number of Strategic Assets dwellings dwellings: vacant dwellings is Housing falling. Department

Total Properties in borough: Total Properties in borough: 2006: 44,680 2000 4,000 2005: 44,150 2001 3,900 2004: 43,791 All Empty Properties*: 2003: 43,947 2002 3,500 2006: 938 2002: 42,924 * These figures includes short 2003 3,600 term (<6 months) and long 2004 4,200 All Empty Properties*: term (6> months) vacant 2005: 953 dwellings. 2005 3,400

% Empty: 2004: 814 2006: 2.10% 2003: 1,290 2002: 995

25 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

% Empty: 2005: 2.16% 2004: 1.86% 2003: 2.94% 2002: 2.32%

*Number of St Edmundsbury: 2007/08 820 visits/uses St Edmundsbury: The figures fluctuate DCLG Population visits to/uses 2007/08: 1,504 Suffolk average: 672 in St 2006/07: 866 due to the temporary www.bvpi.gov.uk of Council Edmundsbury closure (e.g. for * Visit/usage to those England average: 2095 2005/06: 635 SEBC Policy funded or in 2009/10 refurbishment) of Department part-funded museum(s) means: a visit by a 2004/05: 834.0 museums. A museums member of the public, significant increase St Edmundsbury 2005/06 2003/04: 1,680 per 1,000 telephone or email by post etc. in the number Borough Council population enquiries for research Suffolk average: 344 2002/03: 1,004 visits/uses in Best Value purpose, e-enquiries to a (BV170a) England average: 1,687 2001/02: 520 (Moyse’s Hall 2007/08 was Performance museum’s website or museum closed) observed. Figures Plan 2007/08 presentations by museum staff for St Edmundsbury Audit to a specific audience. 2000/01: 1,152 are consistently Commission higher than those for Best Value Data Suffolk but lower 2007/08 than for England.

ENVIRONMENTAL

Number and St Edmundsbury: Suffolk: None identified. No trend data available. Large areas of the Suffolk’s Biodiversity, area of SPA: 3,473 ha – 5.3% of Ramsar: 8,141 ha borough have an Environments Flora, Fauna designated Borough (1 site: Breckland) ecological Monitoring ecological SPA: 20,606.5 ha designation and as Report 2004/05 sites SAC: 2 sites: Breckland (part) SSSI: No: 145, Area: such must be (SSAG) and Waveney & Little Ouse 31,384 ha protected from the Suffolk Biological Valley Fens pressures of Country Wildlife Site: No: Records Centre SSSI: 5,449.58 ha – 8.3% of development. 889, Area: 19,240 ha St Edmundsbury Borough Local Nature Reserve: No: LDF Annual National Nature Reserve: Monitoring

26 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 169.99 ha – 0.25% of Borough 27, Area: 390.44 ha Report 2007/08 County Wildlife Sites: 144 sites (3,526ha) Local Nature Reserve: 42.4ha (2 sites: Haverhill Railway Walks, and Moreton Hall Community Woods) Country Parks: 3 sites: West Stow Country Park, Knettishall Heath Country Park and Clare Castle Country Park.

European Breckland SPA: 39433.66 ha. No comparator data. No trend data available, These valuable sites Joint Nature Biodiversity, sites Predominantly coniferous and the habitats, Conservation Flora, Fauna woodland, arable land, dry flora and fauna that Committee grassland and steppes, they support must be http://www.jncc.g supporting significant safeguarded from ov.uk/page-4 populations of the Stone damage and Curlew (Burhinus destruction. oedicnemus), the European Nightjar (Caprimulgus europaeus) and the woodlark (Lullula arborea).

Waveney & Little Ouse Valley Fens SAC: 193.18ha. Predominantly inland water bodies; bogs, marshes, water fringed vegetation and fens; heath scrub, Maquis and garrigue, and Phygrana; Humid grassland and Mesophile grassland; and broad-leaved deciduous woodland, providing key

27 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) habitats which support fen sedge (Cladium mariscus), calcareous fens (Caricion davallianae) and Desmoulin's Whorl Snail

Breckland SAC: 7548.06 ha. Predominantly supporting Inland dunes with open Corynephorus and Agrostis grasslands; Natural eutrophic lakes with Magnopotamion or Hydrocharition-type vegetation; European dry heaths; Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco- Brometalia), Alluvial forests with Alnus glutinosa and Fraxinus excelsior and Triturus cristatus.

Number and Barnham Heath: 76.5ha SSSI condition in East of None identified. No trend data available. The majority of the Suffolk Biological Biodiversity, reported Area favourable: 89.46% England, February 2008: ecological SSSIs in Records Centre Flora, Fauna condition of the borough are Area unfavourable recovering: % area meeting PSA Natural England ecological target: 77.65% partly in an SSSIs 10.54% unfavourable or http://www.sssi.n % area favourable: 64.86% aturalengland.or mixed condition. % area unfavourable g.uk/Special/sssi Black Ditches, Cavenham: 13 of the 23 SSSIs /index.cfm 1.67ha recovering:12.79% in St Edmundsbury meet the Public Area favourable: 26.55% % area unfavourable no change: 6.91% Service Agreement Area unfavourable no change: (PSA) targets (i.e. % area unfavourable 73.45% are wholly in declining: 15.42% favourable or

28 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) % area destroyed/part unfavourable but Blo' Norton And Thelnetham destroyed: 0.02% recovering Fen: 21.03 ha condition). Area favourable: 34.78% A further 7 of the SSSIs are meeting Area unfavourable recovering: PSA targets in over 29.34% half of their areas. Area unfavourable no change: However, 1 of the 35.87% SSSIs is meeting PSA targets in under half of its area, with Bradfield Woods: 83.0 ha a further 2 SSSIs not Area unfavourable recovering: meeting their PSA 77.73% target at all. Area unfavourable no change: 5.79% Area unfavourable declining: 16.47%

Breckland Farmland: 13,335.70ha Area favourable: 100%

Breckland Forest: 18,078.70 ha Area favourable: 100%

Bugg's Hole Fen, Thelnetham: 4.0ha % Area destroyed / part destroyed: 100%

29 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

Cavendish Woods: 52.0 ha Area unfavourable recovering: 85.43% Area unfavourable declining: 14.57%

Fakenham Wood And Sapiston Great Grove: 108.6 ha Area unfavourable recovering: 100%

Hay Wood, Whepstead: 10.5ha Area unfavourable recovering: 100%

Hopton Fen: 14.37 ha Area unfavourable recovering: 100%

Horringer Court Caves: 4ha Area unfavourable declining: 100%

Knettishall Heath: 91.2ha Area favourable: 43.03% Area unfavourable recovering:

30 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 11.85% Area unfavourable no change: 45.12%

Lackford Lakes: 106.08 ha Area favourable: 94.57% Area unfavourable recovering: 5.43%

Little Heath, Barnham: 45.73ha Area favourable: 13.52% Area unfavourable recovering: 86.48%

Pakenham Meadows: 5.8 ha Area unfavourable recovering: 100%

Shaker's Lane, Bury St. Edmunds: 1.26 ha Area unfavourable recovering: 100%

Stanton Woods: 62.87ha Area favourable: 3.51% Area unfavourable recovering: 84.05% Area unfavourable no change:

31 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 12.45%

The Glen Chalk Caves, Bury St. Edmund's: 1.58ha Area unfavourable recovering: 100%

Thetford Heaths: 269.36 ha Area favourable: 36.32% Area unfavourable recovering: 63.68%

Trundley And Wadgell's Wood, Great Thurlow: 80 ha Area unfavourable no change: 100%

West Stow Heath: 42.62 ha Area favourable: 76.79% Area unfavourable no change: 23.21%

Weston Fen: 48.6 ha Area favourable: 49.73% Area unfavourable recovering: 27.93% Area unfavourable no change: 22.34%

32 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

Number and Thetford Heaths: 269.36 ha No comparator data. None identified. No trend data available. 100% of the area of Natural England Soil reported Area favourable: 36.32% both geological http://www.sssi.n condition of SSSIs meets PSA aturalengland.or designated Area unfavourable recovering: targets. 63.68% g.uk/Special/sssi geological /index.cfm SSSIs Breckland Forest: 18,078.70 ha Area favourable: 100%

Condition of No data is currently available. County This indicator will be added Wildlife Sites when data becomes available. (National Indicator 197).

BAP Habitats No local information regarding The following Biodiversity No loss of No trend data available. There are a large Suffolk Biodiversity, and Species BAP habitats and species is Action Plans have been designated number of Biodiversity Flora, Fauna available. produced for Suffolk: BAP habitats or designated BAP Action Plan Habitat action plans species habitats and species http://www.suffol in Suffolk, many of k.gov.uk/Environ Acid Grassland • which will be present ment/Biodiversity in St Edmundsbury. • Ancient and/or Species- /BiodiversityActio It is necessary that nPlans.htm rich Hedgerows any permitted development does • Cereal Field Margins not detrimentally affect these habitats • Coastal and Floodplain and species. Grazing Marsh

• Coastal Sand Dunes

• Coastal Vegetated

33 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Shingle

• Fens

• Lowland Hay Meadows

• Lowland Heathland

• Lowland Mixed Deciduous Woodland

• Maritime Cliffs and Slopes

• Mudflats

• Reedbeds

• Saline Lagoons

• Saltmarsh

• Sea Grass Beds

• Eutrophic Ponds

• Traditional orchards

• Urban

• Wet Woodland

• Wood Pasture and Parkland

Species Action Plans

Mammals

34 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) • Brown hare Lepus europaeus

• Dormouse Muscardinus avellanarius

• European otter Lutra lutra

• Harbour porpoise Phocoena phocoena

• Pipistrelle bat Pipistrellus pipistrellus

• Barbastelle Bat Barbastella barbastellus

• Red squirrel Sciurus vulgaris

• Water vole Arvicola terrestris

• Water Shrew Neomys fodiens NB All bats will be included in a grouped plan to be completed 2009.

Amphibians and Reptiles Great crested newt Triturus cristatus Natterjack toad Bufo calamita Adder or Northern Viper

35 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Vipera berus

Birds • Bittern Botaurus stellaris

• Grey partridge Perdix perdix

• Skylark Alauda arvensis

• Song thrush Turdus philomelos

• Stone curlew Burhinus oedicnemus

• Bullfinch Pyrrhula pyrrhula

• Corn Bunting Miliaria calandra

• Linnet Carduelis cannabina

• Nightjar Caprimulgus europaeus

• Reed Bunting Emberiza schoeniclus

• Barn Owl Tyto alba

Local Character Species • Spotted Flycatcher

36 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Muscicapa striata

• Tree Sparrow Passer montanus

• Turtle Dove Streptopelia turtur

• Woodlark Lullula arborea

• Little tern Sterna albifrons

Invertebrates • Ramshorn snail Anisus vorticulus

• Narrow-mouth whorl snail Vertigo angustior

• Desmoulin’s whorl snail Vertigo moulinsiana

• Shining ram’s-horn snail Segmentina nitida

• A leaf beetle Cryptocephalus exiguus

• Stag beetle Lucanus cervus

• Antlion Euroleon nostras

• Bright wave moth Idaea ochrata

37 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) • Dingy Skipper Erynnis tages

• White-mantled Wainscot moth Archanara neurica

• Silver-studded Blue Plebejus argus

• Starlet sea-anemone Nematostella vectensis

• Depressed river mussel Pseudanodonta complanata

• White-clawed crayfish Austropotamobius pallipes

Plants • Cornflower Centaurea cyanus

• Greater Water-parsnip Sium latifolium

• Shepherd’s needle Scandix pectinveneris

• Pillwort Pilularia globulifera

• Red-tipped Cudweed

38 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Filago lutescens

• Small-flowered Catchfly Silene gallica

• Spreading Hedge-parsley Torilis arvensis

• Tassel Stonewort Tolypella intricata

• Tower Mustard Arabis glabra

• Native Black Poplar Populus nigra ssp.betulifolia

• Unspotted Lungwort Pulmonaria obscura

• Man orchid Aceras anthropophorum

Lichens and Fungi • Orange-fruited elm-lichen Caloplaca luteoalba

• Sandy stilt puffball Battarraea phalloides

• Starry breck-lichen Buellia asterella

• Oak Polypore

39 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Buglossoporus pulvinus

Landscape St Edmundsbury has 16,687 East of England 2004: The No target No trend data available. The borough’s Defra East of Landscape, ha of Special landscape area region has 14% of the identified. distinct landscape England Biodiversity, (25.5% of Borough) country's greenbelt land types must be Factsheet, 2008 Flora, Fauna The Suffolk Landscape and preserved in order to Suffolk Character Assessment 22 character areas. They ensure that the Landscape identified 14 landscape types are under threat by integrity and high Character which are located within St urbanization and landscape value of Assessment Edmundsbury: particularly developments the borough is not http://www.suffol lost. geared to cars (e.g. out of klandscape.org.u town retail centres). k/ Ancient plateau claylands Key Characteristics • Flat or gently rolling arable landscape of clay soils dissected by small river valleys

• Field pattern of ancient enclosure – random patterns in the south but often co-axial in the north. Small patches of straight-edged fields associated with the late enclosure of woods and greens

• Dispersed settlement pattern of loosely clustered villages, hamlets and isolated farmsteads of medieval origin

40 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) • Villages often associated with medieval greens or tyes

• Farmstead buildings are predominantly timber-framed, the houses colour-washed and the barns blackened with tar. Roofs are frequently tiled, though thatched houses can be locally significant

• Scattered ancient woodland parcels containing a mix of oak, lime, cherry, hazel, hornbeam, ash and holly

• Hedges of hawthorn and elm with oak, ash and field maple as hedgerow trees.

• Substantial open areas created for WWII airfields and by 20th-century agricultural changes

• Network of winding lanes and paths often associated with hedges create visual intimacy Condition Although agricultural intensification in the 20th century has thinned out the historical field patterns, enough remains to give a distinctive character to the

41 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) landscape. There is, also, still a strong vernacular feel to the settlements, especially south of the Gipping. There are localised impacts of development associated with the A14 corridor and some former airfield sites, such as Stanton and Eye. Due to hedgerow removals and the enclosure of many of the greens, the ecological continuity is now localised in a series of hotspots based on the ancient woodlands and associated hedgerow networks or small river valleys.

Estate sandlands Key Characteristics • Flat or very gently rolling plateaux of freely-draining sandy soils, overlying drift deposits of either glacial or fluvial origin

• Chalky in parts of the Brecks, but uniformly acid and sandy in the south-east

• Absence of watercourses

• Extensive areas of heathland or acid grassland

42 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) • Strongly geometric structure of fields enclosed in the 18th & 19th century.

• Large continuous blocks of commercial forestry

• Characteristic ‘pine lines’ especially, but not solely, in the Brecks

• Widespread planting of tree belts and rectilinear plantations

• Generally a landscape without ancient woodland, but there are some isolated and very significant exceptions

• High incidence of relatively late, estate type, brick buildings

• North-west slate roofs with white or yellow bricks. Flint is also widely used in as a walling material

• On the coast red brick with pan-tiled roofs, often black- glazed Condition The two sections of this landscape are very different; in

43 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) the south-east much of this area has a strong urban influence. Martlesham has lost much of its rural character and much of the remnant heathland, such as at Rushmere and Foxhall, is in a suburban environment and further ‘tamed’ by being used for golf courses. Even in the central and northern parts of the coastal area there is a steady pressure of suburbanisation and tourism related development. In the Brecks the landscape remains strongly rural, except in the environs of Bury St Edmunds and Thetford, but is dominated by high-tech modern farming and forestry. The occasional new intrusion, such as the Elveden Forest Holiday Village, has made little impact as it is buried in the forest.

Plateau estate farmlands Key Characteristics • A landscape of large regular fields with small woodlands on light loamy soils

• Flat landscape of light loams

44 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) and sandy soils

• Large scale rectilinear field pattern

• Network of tree belts and coverts

• Large areas of enclosed former heathland

• 18th- 19th & 20thC Landscape Parks

• Clustered villages with a scattering of farmsteads around them

• Former airfield sites

• Vernacular architecture is often 18th & early 19thC estate type of brick and tile Condition The eastern parts of this landscape suffer considerable localised effects from the A14 and A12 trunk roads. While in the wider landscape hedges tend to have a lot of elm suckering and be in poor condition. In general the picture in the west is more mixed with considerable growth of villages simplifying the landscape

45 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) locally. However, the overall pattern of large fields with hedges and woodland coverts remains apparent through some of the detail has been lost through 20th-century agricultural improvements, and through the construction and redevelopment of airfields at Rougham, Ipswich and Bentwaters.

Rolling estate farmlands Key Characteristics • Gently sloping valley sides and plateau fringes

• Generally deep loamy soils

• An organic pattern of fields modified by later realignment

• Important foci for early settlement

• Coverts and plantations with some ancient woodlands

• Landscape parks with a core of wood pasture

• Location for mineral workings and related activity, especially in the Gipping valley

46 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Condition The influence of single estate ownership remains strong over much of this landscape, so the condition is often good despite the post war modification of the field patterns; In these areas hedges woods and trees are well maintained as is much of the built features of an estate landscape. However, in the east on the Shotley Peninsular and around Rendlesham there are areas where the pattern and features of the landscape are highly modified by agricultural improvement.

Rolling estate sandlands Key Characteristics • Sloping or rolling river terraces and coastal slopes

• Sandy and free draining soils with areas of heathland

• Late enclosure with a pattern of tree belts and straight hedges

• Parklands

• A focus of settlement in the

47 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Estate Sandlands landscape

• In the east are19thC red brick buildings with black glazed pan tiles

• Lark valley buildings are frequently of brick or flint with tiled or slate roofs

• Tree belts and plantations throughout

• Occasional and significant semi natural woodlands and ribbons of wet woodland

• Complex and intimate landscape on valley sides Condition Many of these valley side landscapes are under considerable development pressure because there are concentrations of settlement and land use change. However there are excellent areas of semi-natural landscapes and intact landscapes in many places.

Rolling valley farmlands Key Characteristics • Gentle valley sides with some

48 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) complex and steep slopes

• Deep well drained loamy soils

• Organic pattern of fields smaller than on the plateaux

• Distinct areas of regular field patterns

• A scattering of landscape parks

• Small ancient woodlands on the valley fringes

• Sunken lanes

• Towns and villages with distinctive mediaeval cores and late mediaeval churches

• Industrial activity and manufacture, continuing in the Gipping valley

• Large, often moated, houses Condition Much of this landscape retains it historic patterns, of both the agricultural and built environment. However, the Gipping valley has been a focus of economic activity so has been subject to transport and industrial developments.

49 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Conversely the Stour and its tributaries have been subject to some gentrification, with significant changes in land use, such as the increase in horse pastures and the loss of much commercial orchard production.

Rolling valley farmlands & furze Key Characteristics • Valley landscapes with distinctive areas of grass and gorse heaths

• Valleys with prominent river terraces of sandy soil

• Small areas of gorse heathland in a clayland setting

• Straight boundaries associated with late enclosure

• Co- axial field systems

• Mixed hedgerows of hawthorn dogwood and blackthorn with oak ash and field maple

• Fragmentary cover of

50 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) woodland

• Sand and gravel extraction

• Golf Courses Condition The condition of this landscape is very mixed with some important semi-natural habitats such as Wortham Ling and parts of Stuston Common in good condition. However, as with the valley clayland and valley farmland landscapes away from the valley sides the completeness and connectivity of the hedgerow network reduces.

Undulating ancient farmlands Key Characteristics • A landscape of open undulating farmland with blocks of ancient woodland

• Undulating arable landscape

• Field pattern generally a random ancient pattern with occasional areas of regular fields associated with former mediaeval deer parks

51 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) • Oak ash and field maple as hedgerow trees

• Substantial open areas created for airfields and by post WWII agricultural improvement

• Studded with blocks of ancient woodland

• Dispersed settlement pattern of loosely clustered villages, hamlets and isolated farmsteads

• Villages often associated with greens or former greens

• Rich stock of mediaeval and Tudor timber-framed and brick buildings and moated sites

• A large scale landscape with long undulating open views trees, either in hedges or in woods, are always a prominent feature

• In the undulating landscape, crop production, especially oilseeds can be visually prominent Condition

52 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

The historic pattern of field boundaries has been degraded through 20th-century agricultural rationalisation that has resulted in a large number of hedges being removed, as at Rede or Mickley Green. Furthermore, inappropriate tree planting on greens has also had an adverse effect on the character of the historic landscape. However despite these changes the landscape maintains much of its historic character.

Undulating estate farmlands Key Characteristics • Undulating arable landscape with parklands plantations and ancient woodland

• Undulating arable landscape

• Organic field pattern rationalised by estate ownership

• Oak ash and field maple as hedgerow trees

• Complex arrangements of plantations especially in the north

53 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) • Ancient woodlands

• Landscape parks and ornamental tree species

• Substantial open areas created for airfields and by post WWII agricultural improvement

• Dispersed settlement pattern of loosely clustered villages, hamlets and isolated farmsteads especially in the north

• Settlements more clustered and less dispersed in the south

• Rich stock of mediaeval and Tudor timber-framed and brick buildings and moated sites

• A landscape of well wooded farmland in many places often with a well kept appearance Condition Much of the area has a rather well kept appearance with strong linkages of hedgerows and woodland maintained by the influence of shooting on

54 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) these estates. However, in the south, the pressure of industrial farming on the management of land and the larger field size has modified this landscape removing much of the detail of the field pattern.

Urban No additional information about the characteristics of the urban landscape is available.

Valley meadowlands

Key Characteristics • Flat valley floor grasslands on silty and peat soils

• Flat landscapes of alluvium or peat on valley floors

• Grassland divided by a network of wet ditches

• Occasional carr woodland and plantations of poplar

• Occasional small reedbeds

• Unsettled

55 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) • Cattle grazed fields

• Fields converted to arable production Condition Some these landscapes are in excellent condition, However many are affected by intakes into arable production, by horse grazing and by under grazing. The sense of tranquillity and isolation of this landscape can also be intruded upon by the development of the adjacent rolling valley landscapes which are often a focus of settlement and development.

Valley meadows & fens Key Characteristics • Flat, narrow, river valley bottoms

• Deep peat or mixtures of peat and sandy deposits

• Ancient meres within the valley bottoms & important fen sites

• Small grassland fields, bounded by dykes running at

56 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) right angles to the main river

• Sparse scattering of small alder carr & plantation woodlands

• Part of a wider estate type landscape

• Largely unsettled, except for the occasional farmstead

• Drier fields turned over to the production of arable crops

• Cattle grazing now often peripheral to commercial agriculture

• Loss to scrub encroachment, tree planting and horse paddocks Condition Some parts of this landscape are still in fine condition having a rural feel and maintain the traditional management of cattle grazing; this pattern is shown at its best at Blyford. There is though a lot of neglect and poor management in these landscapes, the small and difficult to access fields are often peripheral to any form of active agriculture. These difficult fields are being

57 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) lost to scrub encroachment, tree planting and horse paddocks.

Wooded chalk slopes Key Characteristics • Rolling valleys

• Shallow free draining chalk soils

• Scattered plantation woodlands

• Fringed with ancient woodland

• Planned rectilinear field patterns

• Hawthorn hedges with few trees

• Compact villages and a scattering of farms

• Flint and thatch vernacular buildings Condition This landscape is in generally reasonable condition. However the historic pattern has been degraded by agricultural improvement. The development style in the

58 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) villages has created a rather suburban feeling.

Wooded valley meadowlands & fens Key Characteristics • Flat valley bottom

• Extensive peat deposits

• Cattle grazed pasture

• Network of drainage ditches

• Areas of unenclosed “wild” fenland

• Widespread plantation and carr woodland

• Important sites for nature conservation

• Localised settlement on the valley floor “islands”

• Sense of quiet and rural isolation in many places Condition This landscape is generally in good condition, with a lot of conservation effort being placed on the key fen sites. However the visual condition is threatened in places by the

59 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) conversion of traditional grazing into pony paddocks with their associated field shelters and fencing tape, rather than the more robust and discreet methods used for cattle. There has also been a certain amount of mineral extraction in the Waveney valley in the 20th century that has left a legacy of large lakes, as at Weybread, Wortwell, Earsham and Ditchingham. There has also been some extraction in some of the tributary valleys of the Little Ouse, such as at Hinderclay. RIGS There is one site designated No comparator data No targets No trend data available. Development within Replacement St Soil as RIGS near Thelnetham available. identified St Edmundsbury Edmundsbury within the St Edmundsbury. must not prejudice Borough Local the integrity and vale Plan 2016 of these sites.

Number of St Edmundsbury Listed Suffolk Listed Buildings No targets St Edmundsbury Listed 3rd highest number SEBC Cultural listed Buildings 2008: 2006: identified. Buildings 2006: of listed buildings in Conservation Heritage buildings and Grade I: 98 Grade I: 414 Grade I: 98 Suffolk. The number Department buildings at of listed buildings in Grade II*: 160 Grade II*: 876 Grade II*: 160 SCC – Suffolk’s risk St Edmundsbury has Environment Grade II: 2,986 Grade II: 15,365 Grade II: 2,977 gradually increased Monitoring since 1995. Total: 3,244 Total: 16,655 Total: 3,235 Report 2004/5

St Edmundsbury The number of LDF Annual St Edmundsbury Buildings at Suffolk Buildings at Risk: St Edmundsbury Buildings at buildings at risk has Monitoring Risk: Risk: 2003: 136 (0.8%) (most fallen since 2003 Report 2007/08 2008: 17 (0.5%) up-to-date figure available) 2007: 20 and the borough has met the Suffolk

60 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Feb 2006: 24 (0.7%) target of 0.7%. 2003: 33 (1%)

Area of St Edmundsbury, 2008: No comparator data. To ensure that Increase in 1 more Nationally The increase in the SCC – Suffolk Cultural historic parks Nationally designated historic 100% of historic designated park since 2001 number of Sustainability Heritage and gardens parks and gardens: 4 parks parks and an increase by 95.7 ha. designated parks in Appraisal Group covering 1,542 (ha). The parks gardens are the Borough is SEBC – are: maintained and favourable. Conservation enhanced. However, it is vital Department Euston Park (Grade II* listed) that the integrity and Ickworth Park (Grade II* listed value of these areas St Edmundsbury continues to be LDF Annual Abbey Gardens (Grade II protected. Monitoring listed) Report 2007-08 Culforth Park (Grade II listed) County designated historic parkland: N/A

Number and St Edmundsbury CAs: Suffolk CAs 2004/5: None identified. St Edmundsbury CAs: The number of SEBC Cultural area of 2008 : 35 (1,864 ha) 171 (covering 6,370 2004 - 2006: 35 (1,684 ha) Conservation Areas Conservation Heritage Conservation properties) and Article 4 Department Areas (CAs) 2003: 34 Directions has SCC – Suffolk’s and Article 4 SEBC Article 4 Directions: 2002: 31 increased over Environment directions recent years. It is 2007 – 2008 : 1,015 properties Suffolk Article 4 Directions 2001: 31 Monitoring 2004/5: vital that these areas Report 2004/5 1996: 27 and properties 22 (covering 6,934 continue to be St Edmundsbury properties) protected. LDF Annual SEBC Article 4 Directions: Monitoring

2004 - 2006: 6 (1,015 Report 2007/08 properties) 2003: 5 (1,003 properties) 2002: 2

Number of St Edmundsbury: Suffolk: To prevent St Edmundsbury: Whilst there is a lack SCC – Suffolk’s Cultural Scheduled No SAMs have been damage to any of trend information Environment Heritage

61 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Ancient 2003-4: 0 damaged since 2000/01. SAMs as a 2002-3: 0 the complete lack of Monitoring Monuments result of 2001-2: 0 damage to ancient Report 2004/5 (SAMs) development monuments between damaged as 2000-1: 1 01/02 – 03/04 is very a result of 1999-0: 0 positive. development 1998-9: 2 1997-8: 0

% of river St Edmundsbury: East of England, 2006: No target St Edmundsbury: In 2004 and 2005 www.defra.gov.u Water, length DEFRA has assessed the Good: 74% identified none of St k Biodiversity, assessed as Edmundsbury’s Flora, Fauna biological quality of rivers as England, 2006: Defra East of good being good (grades A and B), rivers were England biological fair (grades C and D), poor Good: 71% assessed as being Factsheet, 2008 quality % River length quality of poor or bad (grade E) and bad (Grade F). biological quality. Audit Good Fair Poor Bad Commission - % River length quality Percentage of rivers in Year various biological % % % % www.areaprofiles .audit- Good Fair Poor Bad conditions in 2005: Year 1990 70 24 6 0 commission.gov. East of England: % % % % uk Good: 75% 1995 68 32 0 0 2005 64 36 0 0 Fair: 21% 2000 84 12 4 0 Poor: 2% Bad: -% 2002 81 14 4 0

2003 77 19 4 0 England: Good: 71% 2004 68 32 0 0 Fair: 24%

Poor: 4%

Bad: 1%

% of river St Edmundsbury: East of England, 2006: No target St Edmundsbury: The proportion of St Audit Water, length Edmundsbury’s Commission - Biodiversity,

62 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) assessed as % of river length assessed as Good: 44% identified % of river length assessed as rivers that were www.areaprofiles Flora, Fauna good good chemical quality good chemical quality assessed as having .audit- chemical 2005: 41.07% 2004: 27.55% good chemical water commission.gov. quality England, 2006: quality in 2005 was uk 2003: 36.11% Good: 66% higher than in 2004 and 2003. However,

the chemical quality National mean % of river of St Edmundsbury’s length assessed as good rivers is worse than biological quality the average quality 2005: 53.9% of rivers in the East of England and England. Percentage of rivers in various chemical conditions in 2005: East of England: Good: 45% Fair: 42% Poor: 12% Bad: -%

England: Good: 64% Fair: 29% Poor: 7% Bad: 1%

Groundwater There are 16 Groundwater No data available. None identified. No data available. It is essential that Environment Water quality Source Protection Areas within development, Agency/ the Borough, mainly in Bury St particularly in DEFRA Edmunds and to the north of Groundwater Source the Borough. Protection Areas, is

63 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) strictly controlled in order to prevent pollution as polluting these catchment areas could pose a serious public health risk

Flood Risk – St Edmundsbury: East of England: No planning St Edmundsbury: No planning Suffolk’s Water, Planning 2006/07: 0 2006/07: 3 applications 2004/05: 0 applications have Environment Climatic applications approved been approved Annual Factors approved against 2003/04: 1 against EA advice Monitoring against England: Environment 2002/03: 1 since 2003/04. It is Report 2004/5 Environment Agency advice. important that this 2006/07: 13 East of England Agency trend continues. Annual advice Monitoring Report 2006/07

Properties at St Edmundsbury 2006 Suffolk properties at risk of None identified. No trend data available A very low Environment Water, risk of properties located in Flood flooding from rivers and the proportion of Agency Climatic flooding from Zone 3 (high risk) and 2 (low to sea: 11,943 (this excludes property in the Factors, rivers medium risk: 1,337 (1,240 Forest Heath DC) borough is at risk of Population residential and 97 commercial) flooding. This will continue if no st planning applications 1 April 2006 St are approved Edmundsbury: against EA advice Total number of dwellings in the borough: 44,680

Number of Potentially contaminated sites No comparator data. None identified. Potentially contaminated sites Whilst remediation SEBC land Soil potential and in borough: in borough: has reduced the contamination declared Start of 2006/7: 1,137 Start of 2005/6: 1,171 number of potentially officer contaminated contaminated sites sites The number of potentially within the Borough, returned to The borough has no sites that contaminated sites has been there still exist a beneficial were declared as reduced by 34 sites, of which: significant number of

64 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) use Contaminated under Part IIA of - 5 sites were investigated potentially the Environmental Protection and remediated under Part IIa contaminated sites Act 1990 (EPA). EPA (Oils spills etc); which should be - 16 sites were investigated remediated. and remediated under the planning regime (Brownfield site development or similar); and - 13 sites were subjected to a desk study by this Service under Part IIA EPA and no further works were required.

Have annual St Edmundsbury 2006 air Suffolk max recorded To not exceed St Edmundsbury max The concentrations SEBC Air, Human mean pollutants (max estimated annual mean air pollution threshold limits recorded annual mean air of the six monitored Environmental Health concentration level): levels (2001): and to meet pollution levels (2001): key pollutants are at Health s of any key - Nitrogen dioxide (NO ): - NO : 36.50μg/m³ objectives - NO : 35.0μg/m³ very low levels within Department air 2 2 contained in 2 the borough and do 22.3μg/m³ (2005) - PM : 32.1 μg/m³ (2005) - PM : 20.3 μg/m³ (2005) Defra East of pollutants* 10 National Air 10 not exceed levels set England been - Particulates (PM10): Quality out in the UK - SO2: 32.90 μg/m³ (2001) - SO2: 9.62 μg/m³ (2001) Factsheet, 2008 exceeded? 24.6μg/m³ (2005) Strategy. Government Air - CO: 0.4μg/m³ - CO: 0.3μg/m³ Quality Strategy. UK Air Quality - Sulphur dioxide (SO2): 4μg/m³ (2001) - Benzene: 0.78μg/m³ - Benzene: 0.44μg/m³ Concentrations Archive decreased for all http://www.airqu - Lead: Not monitored (there - 1,3-butadiene: 0.28μg/m³ - 1,3-butadiene: 0.18μg/m³ pollutants except ality.co.uk/archiv are no new industrial sources PM between 2001 e/index.php that could give rise to 10 East of England (2004): and 2006. Maximum potentially significant levels of annual mean air lead) - Nitrogen oxides (NOx): pollution levels for St 129,000 tonnes - Carbon monoxide (CO): Edmundsbury are 0.188μg/m³ - SO2: 55,200 tonnes lower than those for Suffolk as a whole. - Benzene: 0.329μg/m³ - PM10: 14,700 tonnes 1,3-butadiene: 0.102μg/m³ *There are seven key air pollutants that the UK

65 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) Government requires Local Authorities to monitor (NO2, PM10, SO2, lead, CO, benzene and 1,3-butadiene).

Number of No Air Quality Management Suffolk currently has 4 air To not exceed No trend data available. Air quality in the Suffolk’s Air, Human Air Quality Areas and no dwellings quality management areas: threshold limits. Borough is good. Environment Health Management affected by poor air quality. three in Ipswich and one in To meet Annual Areas and Suffolk Coastal. objectives Monitoring dwellings contained in Report 2004/5 affected National Air UK Air Quality Quality Archive Strategy. http://www.airqu ality.co.uk/archiv e/index.php

Daily St Edmundsbury: National (mean): Achieving the No trend data available Lack of trend data Audit Water domestic 2004: 146 litres 2004: 154.14 litres equivalent of 3 makes it difficult to Commission - water use stars under the assess the position. www.areaprofiles (per capita Code for However, .audit- consumption, Sustainable consumption is commission.gov. litres) Homes for marginally below uk water use national levels. (105litres/capita /day) is a desirable target for new homes.

Household St Edmundsbury: East of England: Reduce the St Edmundsbury: The volume of waste Suffolk’s Population, and Household (tonnes)*: 2004-5: 21 million tonnes amount of Household (tonnes)*: produced in St Environment Material municipal waste going to Edmundsbury Annual Assets 2005/06: 47,986 of waste (construction and 2004/05: 48,752 waste demolition, industry and landfill (county fluctuates greatly. Monitoring produced commerce and municipal, level LATS). 2003/04: 46,903 The volume of Report 2004/5 household waste Municipal (tonnes)**: including household 2002/03: 49,690 Defra East of waste). produced is roughly England 2005/06: 26,280 No formal 2001/02: 49,394 stable, whereas the target year-on- Factsheet, 2008 2000/01: 46,126 volume of municipal year reduction Office for

66 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) * These figures include green Household waste produced desirable. 1999/00: 46,758 waste produced has National garden waste. Quantities of 2005/06 (kilograms per reduced by a Statistics green waste fluctuate household per week): significant amount Regional Trends Municipal (tonnes)*: dramatically each year East of England: 23.7 kg since 2002/03. Report 2008 dependent on weather and 2004/05: 29,467 have a dramatic effect on England: 23.2 kg 2003/04: 35,507 household waste totals. 2002/03: 44,455

2001/02: 39,730 ** This figure is calculated by adding black bin waste and trade waste to give a rough municipal tonnage.

Kg of St Edmundsbury: Kg of household waste No formal St Edmundsbury: The amount of Audit Population, household 2006/07:475.5 kg collected per head: target: year-on- 2005/06: 477.4 kg household waste Commission - Material waste national mean: year reduction collected per head in www.areaprofiles Assets 2004/05: 491.5 kg collected per 2006/07: 441.33 desirable. St Edmundsbury has .audit- head reduced since commission.gov. 2004/05 but is higher uk than the national mean.

% of St Edmundsbury: East of England: BVPI targets: St Edmundsbury: The proportion of Suffolk’s Material household 2008/09 (1st and 2nd quarter): 2006/07: 38.3% 2007/08: 50% 2007/08: 50.4% household waste Environment Assets waste 54.28% recycled in the Annual produced 2005/06: 34% 2003/04: 33% 2006/07: 50.1% borough is Monitoring that is 2005/06: 40% 2005/06: 48.62% significantly higher Report 2004/5 recycled than that for the East England: 2004/05: 50.64% SEBC Key of England and Performance 2006/07: 31% 2003/04: 33.7% England, and is Indicators – 2005/06: 27% 2002/03: 29.8% increasing year on Second Quarter year. In January Report 2006 St 2008/2009 Edmundsbury Borough Council Defra East of was announced as England the Country's top Factsheet, 2008

67 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) performer for waste Office for management and National recycling and the Statistics first authority to Regional Trends break the 50% mark Report 2008 for recycling.

Consumption St Edmundsbury: East of England domestic None identified St Edmundsbury: Domestic gas DTI - Population, of gas - domestic use kWh: use kWh: domestic use kWh: consumption is www.dti.gov.uk Material Domestic 2004: 20,744 consistently below Assets use per 2004: 19,618 2003: 19,323 figures for East of consumer 2003: 20,456 2002: 19,374 England and GB. and total However, industrial St Edmundsbury: 2002: 20,446 2001: 19,016 commercial gas consumption is 2001: 20,144 /industrial commercial and industrial use relatively high. The use kWh: East of England St Edmundsbury: data appear to show commercial and industrial 2004: 2,346,318 increasing use kWh: commercial and industrial use consumption of gas kWh: 2004: 652,108 by domestic uses 2003: 2,489,349 over recent years. 2003: 683197 2002: 1,320,903 2002: 707,128 2001: 2,065,734 2001: 706,349

GB domestic use kWh: 2004: 20,496 2003: 20,111 2002: 20,118 2001: 19,942 GB commercial and industrial use kWh: 2004: 706,904 2003: 729,372

68 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 2002: 781,524 2001: 777,139

Renewable St Edmundsbury: Amount of energy obtained RSS 14 targets St Edmundsbury: There are no Suffolk’s Climatic Energy 2007/08: 0 from renewable sources in for East of 2004/05: 0 commercial Environment Factors Generation: 2004: England for renewable energy Annual 2003/04: 0 Installed East of England: 0.45% renewable facilities within the Monitoring Generating energy 2002/03: 0 borough. Report 2004 Capacity. UK average: 2% (excluding St Edmundsbury offshore wind): LDF Annual 10% (2010); Renewable energy Monitoring 17% (2020) generating capacity of Report 2007/08 renewables obligation East of England accredited generating Annual stations in East of England Monitoring (MW): Report 2006/07 Offshore wind: 60 Onshore wind: 88.875 Biomass: 92.666 Landfill gas: 174.118 Sewage gas: 3.719 Total: 419.378

Average St Edmundsbury domestic use East of England domestic None identified St Edmundsbury domestic Available figures DTI - Population, annual (per customer): use (per customer): use (per customer): show a decrease in www.dti.gov.uk Climatic domestic 2006: 4,954 kWh 2006: 4,873 kWh 2005: 5,068 kWh domestic electricity East of England Factors and consumption and an 2005: 4,954 kWh 2004: 5,232 kWh Annual commercial increase in industrial Monitoring and industrial St Edmundsbury commercial 2004: 5,091 kWh 2003: 5,209 kWh energy consumption Report 2006/07 of electricity in the borough since and industrial use: 2003: 5,043 kWh (Regional and use (per 2003. local electricity 2006: 85,238 kWh St Edmundsbury commercial consumer, consumption kWh) 2004: 71,156 kWh East of England and industrial use: Figures also indicate data commercial and industrial 2003: 73,103 kWh

69 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) use: that average (experimental) 2006: 77,414 kWh domestic energy http://www.berr.g consumption in St 2005: 75,069 kWh ov.uk/energy/stat Edmundsbury is istics/regional/re 2004: 71,796kWh above both that for gional-local- the East of England 2003: 70,587 kWh electricity/page3 and GB. Similarly, 6213.html) energy consumption Audit GB domestic use (per by industry in 2006 Commission - customer): is higher than in the region and GB. www.areaprofiles 2006: 4,457 kWh .audit- 2004: 4,628 kWh commission.gov. uk 2003: 4,600 kWh

GB commercial and industrial use: 2006: 81,952 kWh 2004: 77,620 kWh 2003: 77,909 kWh

Carbon Local estimates of CO2 East of England estimates No target Local estimates of CO2 Per capita domestic Defra East of Climatic Dioxide emissions (tonnes CO2) - of CO2 emissions (tonnes identified emissions (tonnes CO2) - CO2 emissions have England Factors emissions Domestic emissions per CO2) - Domestic emissions Domestic emissions per decreased in St Factsheet, 2008 capita: per capita: capita: Edmundsbury and 2006: 2.43 tonnes 2006: 2.48 tonnes 2005: 2.41 tonnes are comparable to national but higher Defra Emissions 2005: 2.5 tonnes 2004: 2.7 tonnes than regional figures. of carbon dioxide for local authority Local estimates of CO2 2003: 3.2 tonnes Total emissions per emissions (2006): areas: East of England estimates capita in 2006 http://www.defra. increased from 2005 - Total emissions per capita: of CO2 emissions (tonnes Local estimates of CO gov.uk/environm 2 level and are higher 13.44 tonnes CO2) - Total emissions per emissions (tonnes CO ) - ent/statistics/glob 2 than regional and Summary by sector (kt CO ): capita: Total emissions per capita: atmos/galocalgh 2 national figures, as a 2005: 8.11 tonnes g.htm - Industry and Commercial: result of the more

70 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 844 (61%) 2006: 8.09 2005:12.10 tonnes industrial nature of St Edmundsbury - Domestic: 248 (18%) Summary by sector (kt 2004: 12.7 tonnes the borough. The LDF Annual - Road Transport: 289 (21%) CO ): recent increase in Monitoring - LULUCF: 12 (0) 2 2003: 14.3 tonnes total emissions in St Report 2007-08 - Industry and Commercial: Total: 1,369 Edmundsbury is East of England 16,902 likely to be as a Summary by sector (kt CO ) Annual (37%) 2 result of industrial - Domestic:13,912 (2005): Monitoring growth seen in Report 2006/07 (31%) - Industry and Commercial: Haverhill between - Road Transport: 13,966 692 (56.5%) 2005 and 2006. (31%) - Domestic: 243 (19.5%) - LULUCF: 592 (1%) - Road Transport: 296 (24%) Total: 45,372 - LULUCF: 12 (0) Total: 1,220 National mean estimates of CO2 emissions (tonnes CO2) - Domestic emissions per capita: 2006: 2.54 tonnes 2004: 2.67 tonnes

National mean estimates of CO2 emissions (tonnes CO2) - Total emissions per capita: 2006: 8.94 tonnes 2004: 10.4 tonnes

Traffic Average 7 day flow of traffic Estimated traffic flows for None identified. Average 7 day flow of traffic Traffic volumes fell Suffolk County Air, Climatic volumes in past monitoring points* in St all vehicle types (million past monitoring points* in St in 2005 – for the first Council Factors key locations Edmundsbury borough vehicle kilometres) Edmundsbury borough time since 2000 (thousands of vehicles) (thousands of vehicles) (records go back to Suffolk (million vehicle km): Audit 1996). However, 2006: 6,053 traffic volumes Commission - www.areaprofiles

71 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 2005: 5,947 remain high. .audit- Road Road commission.gov. Class 2005 2004: 5,968 Class 2002 2003 2004 uk

Trunk 89.5 Trunk 88.7 91.2 92.0

A 210.5 A 205.3 207.9 211.0

B 52.1 B 49.1 53.3 53.2

C 21.3 C 17.7 18.9 19.5

Total 373.4 Total 360.8 371.3 375.6

* There are 80 different monitoring points along roads in St Edmundsbury where monitoring has taken place since 1996.

Percentage St Edmundsbury Census 2001 2001: A year–on-year No trend data available. The data indicates Census 2001 Air, Climatic of journeys to travel to work (number): Travel to work by car, van, increase in the that a high Office for Factors work Travel to work by car: minibus, works van % of travel by proportion of National undertaken sustainable journeys undertaken 34,882 people (69.5%) East of England: 64.7% Statistics by modes. in the borough are Regional Trends sustainable Travel to work by public England: 61.0% made by car, with Report 2008 modes the proportion of transport: journeys to work in 1,517 people (3.0%) Travel to work by bus, St Edmundsbury by coach, private bus and rail car being St Edmundsbury residents East of England: 10.9% significantly higher in 2001 than that for aged 16-74 in employment England: 14.9% (Census 2001): 98,193 the East of England 2006: and England. The proportion of Travel to work by car, van, journeys to work minibus, works van undertaken by public transport in the

72 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) East of England: 75.0% borough is England: 69.8% significantly lower than that for the East of England and Travel to work by bus, England. coach, private bus and rail East of England: 10.5% England: 15.1%

Proportion of St Edmundsbury Census 2001 2001: To increase the No trend data available. The proportion of Census 2001 Air, Climatic journeys to travel to work (number): East of England: number of residents of St Office for Factors, work on foot Travel to work on foot: walking Edmundsbury who National Human or by cycle 9.1% foot journeys to travel to work on foot Health 5,977 people (11.9%) Statistics 3.9% bicycle work in Suffolk is higher than Regional Trends by 1% by 2006 regional and national Travel to work by bicycle: Report 2008 1,734 people (3.5%) and 2% by figures. The England: 2011. (2001 proportion of

10.0% foot base of 31,607) residents who travel St Edmundsbury residents To increase the to work by bicycle is aged 16-74 in employment 2.8% Bicycle number of slightly lower than (Census 2001): 98,193 cycling journeys regional but higher than national figures. 2006: to work in Suffolk by 5% East of England: by 2006 and 9.3% foot 10% by 2011. 3.9% bicycle (2001 base of 15,532)

England: 10.5% foot 3.0% Bicycle

Distances St Edmundsbury average National mean % of the None identified No trend data available. The available data Census 2001 Air, Climatic travelled to distance (km) travelled to fixed resident population would indicate that (KS015) Factors, work for the place of work: 15km travelling over 20 km to residents of the Audit Population

73 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) resident work borough commute a Commission - population % of the resident population 2001: 14.16% considerable www.areaprofiles travelling over 20 km to work distance to work, .audit- significantly further commission.gov. 2001: 20.7% than the national uk mean.

ECONOMIC

Take-up of Take-up of URBAN Annual B1-B8 floorspace To maintain a Take-up of URBAN Fluctuation and gaps SEBC Planning Material employment employment floorspace completions 2001-2007: supply of employment floorspace in information means Department Assets floorspace (completions): 2005-06: 372,000 m² available land (completions): time series East of England (completions) St Edmundsbury: where St Edmundsbury: observations are Annual 2006-07: 493,417 m² appropriate difficult to make. The 2007/08: 4,875m² 2002/03: 13,074m² Monitoring and to take up of rural Report 2006/07 encourage 2001/02: 624m² employment year-on-year floorspace was St Edmundsbury Take-up of RURAL 2000/01: 29,111m² employment significantly higher in LDF Annual employment floorspace: development. 2007/08 than Monitoring St Edmundsbury: Report 2007/08 Take-up of RURAL between 2001 and 2007/08: 1,313 m² employment floorspace: 2003. St Edmundsbury: 2002/03: 0m² 2001/02: 0m² 2000/01: 1,870m²

Business St Edmundsbury Business East of England Business None St Edmundsbury Business Business Suffolk Material formation formation rate ** %: formation rate ** %: identified. formation rate ** %: development rate Observatory Assets rate (or new 2007: 8.1 2007: 9.9 2006: 8.1 fluctuates but is www.suffolkobse VAT broadly similar to rvatory.info registrations 2006: 8.9 2004: 9.6 that of East of as % of total * All firms with a turnover 2003: 8.8 England. The Edmundsbury VAT business formation LDF Annual which exceeds £55,000 per 2002: 9.7 registered annum must register for VAT. rate in 2006 and Monitoring stock) * However, some firms 2001: 8.7 2007 was lower than Report 2007/08 voluntarily register for VAT and that observed

74 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) these firms are included within between 2001 and the figures. 2004.

** Business formation rates are the number of registrations as a percentage of stock during 2001.

Business St Edmundsbury VAT Suffolk VAT Stats – St Edmundsbury VAT In 2004 SEBC had Suffolk Material start ups and Registrations*: Registrations: Registrations*: 4th highest number Observatory - Assets closures 2006: 310 2004: 2050 2004: 345 of de-registrations of www.suffolkobse all districts in Suffolk rvatory.info 2003: 2130 2003: 310 and the 2nd highest St Edmundsbury VAT De- 2002: 2075 2002: 340 number of registrations. This registrations*: 2001: 1860 2001: 295 SEBC – St represents a net 2006: 235 Edmundsbury change of +65. The Profile 2006 number of VAT Suffolk VAT Stats – De- St Edmundsbury VAT De- East of England registrations in St *VAT registrations and de- registrations: registrations*: Annual Edmundsbury is registrations are used as proxy Monitoring 2004: 1,970 2004: 280 fairly constant. The measure for business Report 2006/07 formations and closures. Note 2003: 1,865 2003: 275 number of VAT de- registrations in 2006 - only firms with a turnover 2002: 1,715 2002: 235 which exceeds £55,000 per was lower than in ONS data 2001: 1,700 2001: 260 annum must register for VAT. previous years. reported in St However some firms Edmundsbury voluntarily register for VAT and LDF Annual these firms are included within Monitoring the figures. Report 2007/08

Employment St Edmundsbury % of total Suffolk: None St Edmundsbury % of total Employee % for Suffolk Population by industry % employment, 2006*: identified. employment agriculture, Observatory - distribution and www.suffolkobse Year 04 03 Year 04 03 02 manufacturing rvatory.info Agriculture appear to be in Year 06 ** 0.5 0.6 Agriculture 1.4 1.4 1.6 decline during the St Edmundsbury

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Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

Agriculture 1.3 Energy 1.9 1.3 Energy *** - - - period 2002-06. The LDF Annual Manufacturi 14. 14. proportion of people Monitoring Energy *** 0.5 ng 2 6 Manufacturin 18. 18. employed in Report 2007/08 g 1 19 3 agriculture and 17. Construction 5 4.1 manufacturing in St Manufacturing 3 24. 25. Construction 4.6 4.3 5.7 Edmundsbury is England Rural Distribution 3 7 significantly higher Development Construction 5 Transport 7.9 9.2 24. 26. 29. than for Suffolk. Programme 15. 14. Distribution 8 4 6 While % employed in 2000 - 2006 24. Banking 9 9 public admin and http://www.defra. Distribution 8 Transport 3.3 3.5 2.7 23. banking appears to gov.uk/ERDP/do cs/eastchapter/e Transport 3.5 Public admin 26 4 13. 11. 10. have increased ast13/employme Other 5.1 6.2 Banking 4 9 5 between 2002 and 13. 2004 and now nt.htm Banking 3 29. 27. 26. stabilised.. Figures East of England: Public admin 9 9 3 for transport and Public admin 30 construction Service: 67% Other 4 4.7 4.5 fluctuate slightly but Other 4.3 (Distribution, catering and overall appear to repairs; Transport and remain relatively communications; Banking, static. * Figures for SEBC do not add insurance and finance; These figures do not up to 100% this is due to Other services) rounding of data. reflect the major Agriculture, forestry and differences in ** This fig. omits Ipswich fishing: 2.5% employment Borough Council. between the ** No data for energy at district borough’s principal borough level. urban areas. Haverhill is more industrial in nature with more than three times the proportion of manufacturing employment compared to Bury which is dominated by public sector

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Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) employment, accounting for almost one third of total employment.

Number and St Edmundsbury: East of England: None St Edmundsbury: Little change East of England Material percentage Number and percentage of identified. between 2003 and Annual Assets of local units in all industries 2005. Minor Monitoring businesses 2003 – 05 by broad industry Year % % 04 % 03 increases in health, Report 2006/07 by main group: 2005 education, property industry type Agriculture 8 8.1 and business Agriculture 5.7 St Edmundsbury services, motor production 9.8 10 trades and LDF Annual % production 8.4 construction. Minor Monitoring 2005 construction 10 9.8 decreases in public Report 2007/08 construction 12 Agriculture 8.1 motor trades 4.9 4.8 administration and motor trades 4.3 other services, production 10 Wholesale 6.5 6.5 transport, hotels and Wholesale 6.4 catering and retail. construction 10.1 retail 11.2 11.5 With unit numbers retail 12 remaining static for 7.2 7.3 motor trades 5 hotels and all other industries. hotels and 6.3 catering Percentage figures Wholesale 6.5 catering transport 3 3.2 for St Edmundsbury retail 11.3 transport 4 2005 are very similar post and 1.2 1.2 to those for the hotels and 7.2 post and telecom 1.6 telecom county and compare catering very favourably to finance 1.4 finance 1.4 1.6 those for the East of transport 3.0 England. Between property and 26 property and 22.6 22 1998 and 2004, the post and telecom 1.2 business services business Banking and services finance 1.4 education 2.2 Finance industry, education 1.9 1.9 and the Public property and 23 Health 1.5 Admin, education business services Health 1.7 1.7 and health sectors public admin and 8.5 have seen significant

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Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England)

education 2 other services public admin 10 10.3 levels of growth, with a large decline in the Note: % figures do not add and other Health 2 services energy and water up to 100% this is due to and manufacturing public admin and 10.1 rounding of data by EERA sectors. other services for anonymity. Sector Growth within St Edmundsbury 1998-2004

Agriculture and Fishing: -0.9% Energy and Water: -38.4% Manufacturing: -19.8% Construction: 14.7% Distribution: 4.6% Transport and Communications: 0.2% Banking and Finance Industry: 53.5% Public Administration, education and health: 22.4% Other: 1.5%

% Vacant Not monitored No comparator data. The number of No trend data available. Further work Material units in town vacant units in required to obtain Assets centres any one town data for this should not indicator. exceed the national average

Import/export St Edmundsbury: No comparator data None No trend data available. Only Census data Census 2001 Population of workers to % of working residents who available identified. for 2001, therefore East of England district and/or remain in borough for work: difficult to establish Observatory major towns trends.

78 St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

Indicator Quantified data (St Comparators Targets Trends Issues Identified Source SEA Topic Edmundsbury) (Quantified data for East of England and England) 81.1% % of working residents who remain in Bury St Edmunds for work: 65.9%

Number / St Edmundsbury 2001: East of England 2001: None No trend data available. The proportion of the Census 2001 Population percentage 5,081 (10.1%) of population 243,485 (9.4%) of identified. working population of people aged 16-74 in employment population aged 16-74 in of St Edmundsbury working from (50,181) employment (2,579,378) who work at home home as was higher than that main place of England 2001: for the East of work 2,055,224 (9.2%) of England and population aged 16-74 in England in 2001. employment (22,441,498)

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Appendix B – Strategic Options Assessment Table

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B.1.1 This section presents the findings of the assessment of strategic spatial options in the St. Edmundsbury Core Strategy in full tabular format. A commentary/explanation for each of the assessment scorings is contained within the table. Table B.1 below explains the terms and symbols used in the assessment tables. Table B.1 – Scoring of Assessment 3 +++ Major positive - likely to result in substantial progress towards the objective 2 ++ Moderate positive - likely to result in some progress towards the objective 1 + Minor positive - likely to result in very limited progress towards the objective 0 0 Neutral outcome -0.5 +/- Range of possible positive and negative outcomes 0 ? Uncertain outcome -1 - Minor negative - likely to be to the very limited detriment of achieving the objective -2 -- Moderate negative - likely to be to the limited detriment of achieving the objective -3 --- Major negative - likely to be substantially detrimental to achieving the objective

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Table B.2 - Assessment of Strategic Options for Spatial Strategy

SA Objective Option 1 Option 2 Option 3 Option 4 Option 5 Commentary/Explanation

Business Urban Regeneration Rural New as Usual Growth of Haverhill development settlement

Score Score Score Score Score 1 To improve the health Options 2, 3 and 5 are likely to deliver higher levels of benefits, as of the population directing new growth to larger urban areas should help ensure better overall and reduce accessibility to health facilities and improve the provision of good cycle + ++ ++ +/- ++ health inequalities and pedestrian links with benefits for public health. Development in rural areas may provide opportunities for informal recreation but will restrain access to health facilities. 2 To maintain and Options 2, 3 and 5 direct new growth to larger urban areas. This should improve levels of help ensure better accessibility to educational, training and learning education and skills in facilities. Option 5 scores the highest, as development of new the population overall + ++ ++ + +++ settlement would also include provision of adequate community facilities, whereas additional growth in the existing settlements may put a strain on existing facilities. 3 To reduce crime and ? ? ? ? ? Insufficient information to make a meaningful assessment. anti-social activity 4 To reduce poverty There insufficient information to differentiate between most of the and social exclusion options, apart from Option 3, as deprivation levels in Haverhill are high 0 0 ++ 0 0 compared to the rest of the borough and a larger scale development in Haverhill is likely to bring about opportunities for regeneration. 5 To improve access to Directing new development to urban centres will improve accessibility key services for all to key services by enabling the use of public transport and non- sectors of the motorised transport modes. New development in rural areas may help + ++ ++ +/- ++ population retain existing community facilities in villages, however, it is likely to lead to a continued reliance on the private car and may marginalise some social groups. 6 To offer everybody Directing new development to urban centres would improve the opportunity for accessibility to existing employment opportunities and would also help rewarding and attract new employment. Conversely, new development in rural areas satisfying employment + ++ ++ - +/- is likely to restrict employment opportunities. Option 5, new settlement, although it may provide opportunities for creating new employment, it has potential for becoming a dormitory settlement with high dependency on the private car.

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7 To meet the housing Urban growth provides opportunity for larger scale development, which requirements of the is likely to also accommodate a proportion of affordable housing. whole community Option 5 provides opportunity to provide the quality of volume house + ++ ++ -- +++ building of different types on a larger scale. Rural development is likely to be smaller in scale and may not be able to accommodate the required level of growth and deliver affordable housing as part of the scheme. 8 To improve the quality Urban growth should provide opportunities for regeneration and of where people live provision of a mix of housing types, encouraging social cohesion, and to encourage interaction and engagement. New settlement whilst providing community + ++ ++ +/- +/- opportunities within it, may lead to the lost opportunities in the existing participation settlements. Similarly, rural development may also divert from acting on opportunities in urban areas and is less likely to be conducive to social cohesion. 9 To improve water and Further development focused on the existing urban envelope would air quality have the potential to result in: - negative effects on water quality due to high vulnerability of groundwater from intermediate leaching potential of soils - increased abstraction from potentially over-committed water supplies - increased densities of development, resulting in a considerable increase in impermeable surfaces, which may exacerbate the risk of pollutants entering watercourses from accelerated run off. The effects of development of new settlement would be less severe ------due the likely better baseline situation. More disperse development under Options 1 and 4 would help avoid incidences of overloading infrastructure, therefore these options would result in less severe negative effects than options 2 and 3. In terms of air quality effects, Option 4 is likely to perform the worst, it would lead to a continued reliance no the private car and air-borne pollution. Therefore, the combined effects for air and water quality of Option 4 are similar to those of Options 2 and 3.

10 To conserve soil Option 1 includes sequential approach for sites allocation, thereby resources and quality promoting the use of previously developed land. Urban development + ++ ++ - -- would also promote the reuse of derelict/ brownfield land, whilst Option 4 would lead to loss of green space within villages. Option 5 would result in loss of significant amount of greenfield land.

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11 To use water and More compact and dense development in urban areas is likely to lead mineral resources to more resource savings features and thus be more resource efficient. efficiently, and re-use + +++ +++ -- ++ Urban growth in existing settlements is likely to also provide and recycle where opportunities for the re-use of existing buildings or structures. possible 12 To reduce waste Compact urban development is also likely to make it more viable to + ++ ++ -- ++ implement effective recycling initiatives. 13 To reduce the effects Urban development is likely to help reduce the need to travel to access of traffic on the + ++ ++ -- ++ some local services, whilst rural development will exacerbate reliance environment on the private car. 14 To reduce All new development will inevitably result in more GHG emissions from contributions to buildings and associated transport. However, new settlement would climate change provide opportunities for energy-saving initiatives such as CHP. New ------development in the existing settlements may also provide potential for use of CHP systems, whilst rural development does not provide such opportunities and is likely to be less energy efficient and generate more GHG emissions from buildings and associated transport. 15 To reduce New development is likely to exacerbate the existing flood risk through vulnerability to increased hard surfacing which may disrupt the natural water cycle and climatic events ------increase the likeliness of localised flooding. A more dispersed approach to development under Options 1 and 4 may lessen impacts arising from new development. 16 To conserve and Further development in the urban existing settlement is likely to help enhance biodiversity preserve the countryside and natural habitats. Development of rural and geodiversity + ++ ++ - -- areas is likely to result in loss of green space and natural habitats. Effects of new settlement are similar but more severe due to the scale of development. 17 To conserve and Regeneration in the existing urban areas may result in some negative where appropriate effects on cultural features, or it may improve the settings of these enhance areas of features. Development in rural areas may negatively affect culturally historical and +/- ++ ++ - -- sensitive environments. New settlement may also affect culturally archaeological sensitive environments and unknown archaeological remains due to a importance large scale of the development.

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18 To conserve and Development in the existing urban areas is likely to provide enhance the quality opportunities for regeneration and improvement of townscape. and local Development in rural areas may result affect rural landscape but may distinctiveness of + ++ ++ +/- +/- also help preserve village character. New settlement will provide landscapes and opportunities for large scale high quality design development, but at the townscapes same time it may divert from regeneration opportunities in the existing towns and is likely to affect the existing landscape character. 19 To achieve Urban development under Option 2 and 3 will enable building on sustainable levels of strengths of existing centres and improving the overall quality and prosperity and attractiveness of the area. New settlement is likely to have the lowest economic growth cost of end product and provide opportunities to adopt sustainable throughout the plan development measures throughout the development and from the area outset. More dispersed type of development under Options 1 also +++ ++ ++ +/- ++ leads to significant positive effects by supporting the need for development in the rural service centres and thereby supporting sustainable community’s development. Although development under Option 4 may help maintain livelihood of rural areas, it is likely to put a disproportional amount of pressure on natural assets and ecosystems services compared to the expected gains. Therefore, a mixture of positive and negative effects is expected. 20 To revitalise town Options 2 and 3 supporting further growth in the existing urban centres centres - ++ ++ -- -- are likely to help revitalise town centres whilst the other options will divert from these opportunities. 21 To encourage efficient Options 2, 3 and 5, promoting urban development are likely to help patterns of movement promote the efficiency of transport networks, especially integration of in support of - ++ ++ -- ++ sustainable modes. economic growth 22 To encourage and Regeneration of the existing urban centres may attract further inward accommodate both investment. Although new settlement may also attract potential indigenous and investors, scale of development/ risk, investment and commitment inward investment + ++ ++ - +/- required for new settlement may be a deterrent to potential developers/ investors. Development in rural areas is less likely to provide stimulus for inward investment.

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Appendix C – Strategic Sites Assessment Tables

St Edmundsbury Borough Council Local Development Framework: Core Strategy (Submission Document) Final Sustainability Appraisal Report Appendices

C.1.1 This section presents the findings of the assessment of strategic sites in and around Bury St Edmunds and Haverhill in full tabular format. A commentary/explanation for each of the assessment ratings is contained within the table. The assessment of the sites was undertaken using the following qualitative assessment scale: Table C.1 – Key to Strategic Sites Assessment In conformity with the criterion Not relevant to criterion / Neutral effects ? Insufficient information is available Partially meets the criterion / possibly in conflict with the criterion/ some constraints identified In conflict with the criterion

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Table C.2 – Bury St. Edmunds - Site 1 SA Objective Indicator Notes Colour Code Bury St. Edmunds - Site 1 Corresponding to site submission reference 39; Mixed Use Development (77.87ha). Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 2.98km from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights of Nearby Public Rights of Way will improve Way? accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km)? distance. The nearest primary school is located about 1,252 metres from the site.

4 To reduce poverty and social exclusion Will the site be located near or within LSOAs As the site is not located within LSOA in the most in the most deprived 20% to 40% in the deprived 20% to 40% in the country, opportunities country? for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by public The site is within 30 mins of the town centre by all sectors of the population transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km) to key services? distance. Town centre is located approximately 2 km from the site. Is it within 30 mins of a supermarket/ shopping The site is within 30 mins of shops/supermarkets centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km) to supermarkets/shopping centre? distance. The nearest grocery shop is located about 1,432 metres from the site.

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Is the site proposed for mixed-use development with good accessibility to local The site is proposed for mixed use development facilities? and will have good accessibility to local facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for mixed use development rewarding and satisfying employment use with employment included? with employment included. 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is 77.87 hectares and as the whole community thresholds for the application of affordable such is above the relevant threshold for the housing policy? CS Policy H3 defines that, for application of affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where people Is the site proposed in a location with The site is located next to an open access land. live and encourage community accessible natural green space? participation Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is located within a groundwater source source protection zone? protection zone 2 and is within a major aquifer area. Is the site proposed within a water abstraction The site is within a water abstraction management management area? area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. Would it lead to the loss of best and most The site is located on Grade 2 and 3 Agricultural versatile agricultural land (Grade 1, 2 and 3a)? Land. Will it lead to remediation of contaminated The site is not thought to be located on land? contaminated land. 13 To reduce the effects of traffic on the Does the site have good accessibility to local The site is proposed for mixed use development environment facilities (as assessed above)? and it can be accessed by public transport, therefore, it should help minimise the need for travel and reliance on the private car.

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14 To reduce contributions to climate Will the site proposal promote the It is likely that the site will promote the change incorporation of small-scale renewable in incorporation of small-scale renewable in developments? developments, as Policy ENG1 of the Regional Plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable. Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code meet Code Level 3 or above of the Government's for Sustainable Homes? Code for Sustainable Homes for new-build dwellings and to achieve at least a BREEAM ‘very good' rating for non-residential developments. This will be applicable for this site. Meeting Code Level 3 or achieving high BREEAM rating will help minimise CO2 emissions. 15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is not located within Flood Zones 2, 3a or events 3a, 3b) identified in the SFRA and have a 3b or located within 9m of a river. proposed 'non-compatible' use or is located within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is not located in proximity to a SSSI, SAC and geodiversity Area (SPA), Special Area of Conservation or SPA. (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI Is the site in proximity to a County Wildlife The site is not located in proximity to a County Site, Local Nature Reserve or Ancient Wildlife Site, Local Nature Reserve or Ancient Woodland? Note: For the purposes of this Woodland. assessment, proximity will be taken to mean that the site is within 500m of a site. Are BAP habitats known to be on the site? There are no BAP habitats on the site or in its proximity.

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Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS. designated geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site

within 1km of a SSSI will be coded red and within 500m will be coded amber. The site adjacent to RIGS will be coded red and within 500m - amber. 17 To conserve and where appropriate Are there any listed buildings on or adjacent to There are no listed buildings on or adjacent to the enhance areas of historical and the site? site. archaeological importance Is the site in or adjacent to a Conservation The site is adjacent to a village Conservation Area? Note: For the purposes of this Area. assessment, proximity will be taken to mean that the site is within 40m of a Conservation Area. Is the site in or adjacent to a Historic Park and The site is not located in proximity to a Historic Garden? Note: For the purposes of this Park and Garden. assessment, proximity will be taken to mean that the site is within 40m of a Historic Park and Garden. Is the site in or adjacent to a Scheduled The nearest SAM is Fornham All Saints located Ancient Monument (SAM)? Note: For the about 100 meters away from the site. purposes of this assessment, proximity will be taken to mean that the site is within 40m of a SAM. Is the site in or adjacent to an Area of The site is not in or adjacent to an Area of Archaeological Importance or a potential Archaeological Importance. archaeological site? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of an Area of Archaeological Importance. 18 To conserve and enhance the quality Is the site in or adjacent to a Green Corridor? The site is not in or adjacent to a Green Corridor. and local distinctiveness of landscapes Note: For the purposes of this assessment, and townscapes proximity will be taken to mean that the site is within 40m of a Green Corridor.

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Will the site development lead to coalescence The site development will lead to coalescence of of urban extensions with nearby villages? urban extension with Fornham All Saints.

The site abuts Bury St. Edmunds settlement boundary. It is a large-scale development (77.87ha) that would significantly increase the area of Bury St. Edmunds and result in the loss of a large area of greenfield agricultural land. It will also lead to coalescence of the urban extension with Fornham All Saints. The site would benefit from the services offered within Bury St. Edmunds and it has the advantage of being located in close proximity to a public transport route and to Public Rights of Way. The site is proposed for mixed use and has good accessibility to local facilities. Although is located adjacent to a Conservation Area, the proposed site is not within or in close proximity to any other statutory or locally designated sites and is not located within a flood zone.

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Table C.3 - Bury St. Edmunds - Site 2 SA Objective Indicator Notes Colour Code Bury St. Edmunds - Site 2 Corresponding to site submission references 40 - (25.04ha) and 41 - (23.59ha); 48.63 ha in total - Residential and Mixed Use Development. Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 2.04km from the site. Will it lead to a direct loss of public open space The site will not result in any loss of public open or open access land? space or open access land. Will it improve accessibility by Public Rights of There are no nearby Public Rights of Way to Way? improve accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km)? distance. The nearest primary school is located about 1,252 metres from the site. 4 To reduce poverty and social exclusion Will the site be located near or within LSOAs in As the site is not located within LSOA in the most the most deprived 20% to 40% in the country? deprived 20% to 40% in the country, opportunities for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by public The site is within 30 mins of the town centre by all sectors of the population transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km) to key services? distance. Town centre is located approximately 2.5 km from the site. Is it within 30 mins of a supermarket/ shopping The site is within 30 mins of shops/supermarkets centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km) to supermarkets/shopping centre? distance. The nearest grocery shop is located about 2,135 metres from the site.

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Is the site proposed for mixed-use The site is proposed for employment. development with good accessibility to local facilities? 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for employment. rewarding and satisfying employment use with employment included? 7 To meet the housing requirements of Is the site proposal over the relevant The site is proposed for employment. the whole community thresholds for the application of affordable housing policy? CS Policy H3 defines that, for Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where people Is the site proposed in a location with The site is not located in proximity to an open live and encourage community accessible natural green space? access land. However, it is adjacent to a participation recreation/ amenity open space. Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is located within a groundwater source source protection zone? protection zone 2 and is within a major aquifer area. Is the site proposed within a water abstraction The site is within a water abstraction management area? management area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. Would it lead to the loss of best and most The site is located on Grade 2 and 3 Agricultural versatile agricultural land (Grade 1, 2 and 3a)? Land.

Will it lead to remediation of contaminated The site is not thought to be located on land? contaminated land.

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13 To reduce the effects of traffic on the Does the site have good accessibility to local The site can be accessed by public transport and environment facilities (as assessed above)? it is also within cyclable distances to the town centre and key services, therefore, it should help minimise the need for travel and reliance on the private car. As the nearest bus stop is located over 800m of the site, the site is coded amber. 14 To reduce contributions to climate Will the site proposal promote the incorporation It is likely that the site will promote the change of small-scale renewable in developments? incorporation of small-scale renewable in developments as Policy ENG1 of the Regional Plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable.

Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code for achieve at least a BREEAM ‘very good' rating for Sustainable Homes? non-residential developments. This will be applicable for this site. Achieving high BREEAM rating will help minimise CO2 emissions.

15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is not located within Flood Zones 2, 3a events 3a, 3b) identified in the SFRA and have a or 3b or located within 9m of a river. proposed 'non-compatible' use or is located within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is not located in proximity to a SSSI, and geodiversity Area (SPA), Special Area of Conservation SAC or SPA. (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI Is the site in proximity to a County Wildlife Site, The site is not located in proximity to a County Local Nature Reserve or Ancient Woodland? Wildlife Site, Local Nature Reserve or Ancient Note: For the purposes of this assessment, Woodland. The nearest County Wildlife Site is proximity will be taken to mean that the site is Hyde Wood and is located approximately 800 within 500m of a site. meters from the site.

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Are BAP habitats known to be on the site? There are no BAP habitats on the site or in its proximity. Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS. designated geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site

within 1km of a SSSI will be coded red and within 500m will be coded amber. The site adjacent to RIGS will be coded red and within 500m - amber. 17 To conserve and where appropriate Are there any listed buildings on or adjacent to There are no listed buildings on or adjacent to enhance areas of historical and the site? the site. archaeological importance Is the site in or adjacent to a Conservation The site is not in or adjacent to a Conservation Area? Note: For the purposes of this Area. assessment, proximity will be taken to mean that the site is within 40m of a Conservation Area. Is the site in or adjacent to a Historic Park and The site is not located in proximity to a Historic Garden? Note: For the purposes of this Park and Garden. assessment, proximity will be taken to mean that the site is within 40m of a Historic Park and Garden. Is the site in or adjacent to a Scheduled The site is not located in proximity to a SAM. Ancient Monument (SAM)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of a SAM. Is the site in or adjacent to an Area of The site is not in or adjacent to an Area of Archaeological Importance or a potential Archaeological Importance. archaeological site? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of an Area of Archaeological Importance. 18 To conserve and enhance the quality Is the site in or adjacent to a Green Corridor? The site is not in or adjacent to a Green Corridor. and local distinctiveness of landscapes Note: For the purposes of this assessment, and townscapes proximity will be taken to mean that the site is within 40m of a Green Corridor.

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Will the site development lead to coalescence The site development will not lead to of urban extensions with nearby villages? coalescence of urban extension with nearby villages. Economic 19 To achieve sustainable levels of Is the site proposed for mixed-use The site is proposed for employment. prosperity and economic growth development or employment? throughout the plan area 20 To revitalise town centres Is the site proposed for mixed-use The proposed site is located at the edge of the development or employment in town centres? town. 21 To encourage efficient patterns of Is the site proposed in a proximity to a public The site is located in proximity to a public movement in support of economic transport route or in a walkable/cyclable transport route. It is within cyclable distance, but growth distance? not walkable distance. The nearest bus stop is about 1,012 meters from the site. 22 To encourage and accommodate both Will it increase employment land availability? The site is proposed for mixed-use development indigenous and inward investment and will provide some employment opportunities. Summary Assessment

The site forms an urban extension to Bury St. Edmunds of 48.63ha. Its development would increase the area of Bury St. Edmunds and result in the loss of a comparatively large area of greenfield agricultural land. The site would benefit from the services offered within Bury St. Edmunds and it has the advantage of being located close to a public transport route - the nearest bus stop is located approximately 1km from the site. The site is proposed for employment only and has good accessibility to local facilities. The proposed site is not within or in close proximity to any statutory or locally designated sites and it is not located within an area of flood risk. The nearest County Wildlife Site (Hyde Wood) is located approximately 800m from the site.

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Table C.4 – Bury St. Edmunds - Site 3 North of Westley Road SA Objective Indicator Notes Colour Code Bury St. Edmunds - Site 3 North of Westley Road Corresponding to site submission references 5 - Residential and Mixed Use Development (52ha) and 6 Mixed Use Development (1.95ha); 53.95ha in total. Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 2.3km from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights of Nearby Public Rights of Way will improve Way? accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within walkable and cyclable distances. The and 2-5km)? nearest primary school is located adjacent to the south border of the site. 4 To reduce poverty and social exclusion Will the site be located near or within LSOAs As the site is not located within LSOA in the most in the most deprived 20% to 40% in the deprived 20% to 40% in the country, opportunities country? for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by public The site is within 30 mins of the town centre by all sectors of the population transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km) to key services? distance. Town centre is located approximately 2 km from the site. Is it within 30 mins of a supermarket/ shopping The site is within 30 mins of shops/supermarkets by centre by public transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km) to supermarkets/shopping centre? distance. The nearest grocery shop is located about 2.7km from the site.

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Is the site proposed for mixed-use The site is proposed for mixed use development, development with good accessibility to local including residential development and will have facilities? good accessibility to local facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for mixed use development rewarding and satisfying employment use with employment included? with employment included. 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is more than 50ha and as the whole community thresholds for the application of affordable such is above the relevant threshold for the housing policy? CS Policy H3 defines that, for application of affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where people Is the site proposed in a location with The site is located next to recreation/ amenity open live and encourage community accessible natural green space? spaces and the nearest open access land is participation located approximately 1.3km from the site. Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is located within a groundwater source source protection zone? protection zone 2 and it is also within a major aquifer area. Is the site proposed within a water abstraction The site is within a water abstraction management management area? area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. Would it lead to the loss of best and most The site is located on Grade 2 and 3 Agricultural versatile agricultural land (Grade 1, 2 and 3a)? Land.

Will it lead to remediation of contaminated The site is not thought to be located on land? contaminated land.

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14 To reduce contributions to climate Will the site proposal promote the It is likely that the site will promote the incorporation change incorporation of small-scale renewable in of small-scale renewable in developments as Policy developments? ENG1 of the Regional Plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable.

Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code meet Code Level 3 or above of the Government's for Sustainable Homes? Code for Sustainable Homes for new-build dwellings and to achieve at least a BREEAM ‘very

good' rating for non-residential developments. This will be applicable for this site. Meeting Code Level 3 or achieving high BREEAM rating will help minimise CO2 emissions. 15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is not located within Flood Zones 2, 3a or events 3a, 3b) identified in the SFRA and have a 3b or located within 9m of a river. proposed 'non-compatible' use or is located within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is not located in proximity to a SSSI, SAC and geodiversity Area (SPA), Special Area of Conservation or SPA. (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI

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Is the site in proximity to a County Wildlife The site is not located in proximity to a County Site, Local Nature Reserve or Ancient Wildlife Site, Local Nature Reserve or Ancient Woodland? Note: For the purposes of this Woodland. The nearest County Wildlife Site is assessment, proximity will be taken to mean Ickworth Park located approximately 1.3km from that the site is within 500m of a site. the site. Are BAP habitats known to be on the site? There are no BAP habitats on the site or in its proximity. Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS. designated geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site

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Will the site development lead to coalescence The site development will lead to coalescence of of urban extensions with nearby villages? urban extension with Westley. Economic 19 To achieve sustainable levels of Is the site proposed for mixed-use prosperity and economic growth development or employment? The site is proposed for mixed-use development throughout the plan area with employment. 20 To revitalise town centres Is the site proposed for mixed-use The proposed site is located at the edge of the development or employment in town centres? town. 21 To encourage efficient patterns of Is the site proposed in a proximity to a public The site is located in proximity to a public transport movement in support of economic transport route or in a walkable/cyclable route and the nearest bust stop is located growth distance? approximately 50m from the site. 22 To encourage and accommodate both Will it increase employment land availability? The site is proposed for mixed-use development indigenous and inward investment with employment. Summary Assessment The site abuts Bury St. Edmunds settlement boundary. It is a large-scale development (50+ha) that would significantly increase the area of Bury St. Edmunds and result in the loss of a large area of greenfield agricultural land. The development of the site would also lead to coalescence of urban extension with Westley and may affect the quality of groundwater, as it is located within a water abstraction management area and a groundwater source protection zone 2 . On the positive side, the site would benefit from the services offered within Bury St. Edmunds and it has the advantage of being located close to a public transport route - the nearest bus stop is located approximately 50m from the site and to a Public Right of Way. The site is proposed for mixed use with employment included and has good accessibility to local facilities. The proposed site is not within or in close proximity to any statutory or locally designated sites and is not located within a flood zone. The nearest County Wildlife Site (Ickworth Park) is located approximately 1.3km from the site.

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Table C.5 – Bury St. Edmunds - Site 3 South of Westley Road SA Objective Indicator Notes Colour Code Bury St. Edmunds - Site 3 South of Westley Road Corresponding to site submission reference 122 - Residential Use (53ha). Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 2.5km from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights of There are no nearby Public Rights of Way to Way? improve accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within walkable and cyclable distances. The and 2-5km)? nearest primary school is located approximately 200m from the site. 4 To reduce poverty and social exclusion Will the site be located near or within LSOAs As the site is not located within LSOA in the most in the most deprived 20% to 40% in the deprived 20% to 40% in the country, opportunities country? for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by The site is within 30 mins of the town centre by all sectors of the population public transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km) to key services? distance. Town centre is located approximately 2km from the site.

Is it within 30 mins of a supermarket/ shopping The site is within 30 mins of shops/supermarkets centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km) to supermarkets/shopping centre? distances. The nearest grocery shop is located about 2.5km from the site.

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Is the site proposed for mixed-use The site is proposed for residential development development with good accessibility to local and it will have good accessibility to local facilities? facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for residential development. rewarding and satisfying employment use with employment included? 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is 53ha and as such is the whole community thresholds for the application of affordable above the relevant threshold for the application of housing policy? CS Policy H3 defines that, for affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where people Is the site proposed in a location with The site is located adjacent to recreation/ amenity live and encourage community accessible natural green space? open spaces and the nearest open access land is participation located approximately 600m from the site. Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is located within a groundwater source source protection zone? protection zone 2 and it is also within a major aquifer area. Is the site proposed within a water abstraction The site is within a water abstraction management area? management area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. Would it lead to the loss of best and most Great part of the site is located on Grade 3 versatile agricultural land (Grade 1, 2 and Agricultural Land and a very small area north of 3a)? the site is located on Grade 2 Agricultural Land. Will it lead to remediation of contaminated The site is not thought to be located on land? contaminated land.

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15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is partially located within Flood Zones 3 events 3a, 3b) identified in the SFRA and have a on the area where River Linnet crosses the site. proposed 'non-compatible' use or is located within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is located approximately 450m from a and geodiversity Area (SPA), Special Area of Conservation SSSI (Horringer Court Caves SSSI). (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI Is the site in proximity to a County Wildlife The site is not located in proximity to a County Site, Local Nature Reserve or Ancient Wildlife Site, Local Nature Reserve or Ancient Woodland? Note: For the purposes of this Woodland. The nearest County Wildlife Site is assessment, proximity will be taken to mean Hyde Wood and is located approximately 670 that the site is within 500m of a site. meters from the site.

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within 1km of a SSSI will be coded red and within 500m will be coded amber. The site adjacent to RIGS will be coded red and within 500m - amber. 17 To conserve and where appropriate Are there any listed buildings on or adjacent to There are no listed buildings on or adjacent to the enhance areas of historical and the site? site. archaeological importance Is the site in or adjacent to a Conservation The site is not in or adjacent to a Conservation Area? Note: For the purposes of this Area. assessment, proximity will be taken to mean that the site is within 40m of a Conservation Area. Is the site in or adjacent to a Historic Park and The site is not located in proximity to a Historic Garden? Note: For the purposes of this Park and Garden. assessment, proximity will be taken to mean that the site is within 40m of a Historic Park and Garden. Is the site in or adjacent to a Scheduled The site is not located in proximity to a SAM. Ancient Monument (SAM)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of a SAM. Is the site in or adjacent to an Area of The site is not in or adjacent to an Area of Archaeological Importance or a potential Archaeological Importance. archaeological site? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of an Area of Archaeological Importance. 18 To conserve and enhance the quality Is the site in or adjacent to a Green Corridor? The site is not in or adjacent to a Green Corridor. and local distinctiveness of landscapes Note: For the purposes of this assessment, and townscapes proximity will be taken to mean that the site is within 40m of a Green Corridor.

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Will the site development lead to coalescence The site development will not lead to coalescence of urban extensions with nearby villages? of urban extension with nearby villages.

Economic 19 To achieve sustainable levels of Is the site proposed for mixed-use prosperity and economic growth development or employment? The site is proposed for residential development throughout the plan area without employment. 20 To revitalise town centres Is the site proposed for mixed-use The proposed site is located at the edge of the development or employment in town centres? town and is proposed for residential development only. 21 To encourage efficient patterns of Is the site proposed in a proximity to a public The site is located in proximity to a public movement in support of economic transport route or in a walkable/cyclable transport route and the nearest bust stop is about growth distance? 800 meters from the site. 22 To encourage and accommodate both Will it increase employment land availability? The site is proposed for residential development indigenous and inward investment only. Summary Assessment The site abuts Bury St. Edmunds settlement boundary. It is a large-scale development (53ha) that would significantly increase the area of Bury St. Edmunds and result in the loss of a large area of greenfield agricultural land. The site development may affect the quality of groundwater, as it is located within a water abstraction management area and a groundwater source protection zone 2 . On the positive side, the site would benefit from the services offered within Bury St. Edmunds and it would have the advantage of being located close to a public transport route - the nearest bus stop is located approximately 800m from the site. The site is proposed for residential use only and it has good accessibility to local facilities. The proposed site is located in proximity of Horringer Court Caves SSSI (about 450m). This may necessitate incorporation of mitigation measures in the site design and development. The nearest County Wildlife Site Hyde Wood is located approximately 670m from the site. The site is partially located within a high flood risk area (Flood Zone 3) where River Linnet crosses the site.

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Table C.6 - Bury St. Edmunds - Site 4 SA Objective Indicator Notes Colour Code Bury St. Edmunds - Site 4 Corresponding to site submission references 37, 89 and 128 (West side of the A14) - Residential, Mixed Use and Employment; 61 - Regional Sporting Centre; 95 - Residential and Mixed Use with Employment; 75ha in total. Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 850m from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights of Nearby Public Rights of Way will improve Way? accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within walkable and cyclable distances. The and 2-5km)? nearest primary school is located approximately 200m from the site. 4 To reduce poverty and social Will the site be located near or within LSOAs As the site is not located within LSOA in the most exclusion in the most deprived 20% to 40% in the deprived 20% to 40% in the country, opportunities country? for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by The site is within 30 mins of the town centre by all sectors of the population public transport? public transport. Is it within walkable/cyclable distances (800m It is within walkable and cyclable distance. Town and 2-5km) to key services? centre is located approximately 500m from the site. Is it within 30 mins of a supermarket/ The site is within 30 mins of shops/supermarkets shopping centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within walkable and cyclable distances. The and 2-5km) to supermarkets/shopping nearest grocery shop is located about 200m from centre? the site.

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Is the site proposed for mixed-use The site is proposed for mixed use development development with good accessibility to local and it will have good accessibility to local facilities? facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for residential, mixed use rewarding and satisfying employment use with employment included? development and employment. 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is 75ha and as such is the whole community thresholds for the application of affordable above the relevant threshold for the application of housing policy? CS Policy H3 defines that, for affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where people Is the site proposed in a location with The site is located in close proximity to live and encourage community accessible natural green space? recreation/ amenity open spaces and the nearest participation open access land is located adjacent to the site. Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is located within a groundwater source source protection zone? protection zone 2 and it is also within a major aquifer area. Is the site proposed within a water abstraction The site lies within a water abstraction management area? management area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. Would it lead to the loss of best and most The site is located on Grade 2 and 3 Agricultural versatile agricultural land (Grade 1, 2 and Land. 3a)? Will it lead to remediation of contaminated The site is not thought to be located on land? contaminated land.

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14 To reduce contributions to climate Will the site proposal promote the It is likely that the site will promote the change incorporation of small-scale renewable in incorporation of small-scale renewable in developments? developments as Policy ENG1 of the Regional Plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable. Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code meet Code Level 3 or above of the Government's for Sustainable Homes? Code for Sustainable Homes for new-build dwellings and to achieve at least a BREEAM ‘very good' rating for non-residential developments. This will be applicable for this site. Meeting Code Level 3 or achieving high BREEAM rating will help minimise CO2 emissions. 15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, A river body is crossing the site and a significant events 3a, 3b) identified in the SFRA and have a proportion of the site is located within Flood Zone proposed 'non-compatible' use or is located 2 and 3. within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is located approximately 80m from a and geodiversity Area (SPA), Special Area of Conservation SSSI (Shaker's Lane SSSI). (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI

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Is the site in proximity to a County Wildlife The site is located approximately 240m from a Site, Local Nature Reserve or Ancient Local Nature Reserve (Moreton Hall Community Woodland? Note: For the purposes of this Woods). There are no County Wildlife Sites or assessment, proximity will be taken to mean Ancient Woodlands in proximity. that the site is within 500m of a site. Are BAP habitats known to be on the site? There are no BAP habitats on the site or in its proximity. Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS. designated geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site

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Economic 19 To achieve sustainable levels of Is the site proposed for mixed-use prosperity and economic growth development or employment? The site is proposed for residential and mixed- throughout the plan area use development with employment. 20 To revitalise town centres Is the site proposed for mixed-use The proposed site is located at the edge of the development or employment in town centres? town. 21 To encourage efficient patterns of Is the site proposed in a proximity to a public The site is located in proximity to a public movement in support of economic transport route or in a walkable/cyclable transport route and the nearest bust stop is growth distance? located approximately 200m from the site. 22 To encourage and accommodate both Will it increase employment land availability? The site is proposed for residential and mixed- indigenous and inward investment use development with employment. Summary Assessment The site represents a large-scale urban extension (75ha), the development of which would significantly increase the area of Bury St. Edmunds and result in the loss of a large area of greenfield agricultural land. On the plus side, the site would benefit from the services offered within Bury St. Edmunds and it has the advantage of being located close to a public transport route - the nearest bus stop is located approximately 200m from the site and to Public Rights of Way. The site is proposed for residential and mixed use development with employment and has good accessibility to local facilities. The proposed site is located in proximity to the following designated sites: Shaker's Lane SSSI (about 80m) and Moreton Hall Community Woods Local Nature Reserve (about 240m). The site is also located approximately 150m from a Registered Park and Garden and the part of the northern boundary of the site is adjacent to a SAM. This may necessitate incorporation of mitigation measures in the site design and development to avoid potential effects on ecological and heritage assets and their settings. A water body crosses the site and a significant proportion of the proposed site is located within Flood Zones 2 and 3.

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Table C.7 - Bury St. Edmunds - Site 4a SA Objective Indicator Notes Colour Code Bury St. Edmunds - Site 4a No site submission reference - Proposed use - Residential and Public Open Space; 30ha in total. Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 1.5km from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights of Nearby Public Rights of Way will improve Way? accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within walkable and cyclable distances. The and 2-5km)? nearest primary school is located approximately 750m from the site. 4 To reduce poverty and social Will the site be located near or within LSOAs As the site is not located within LSOA in the most exclusion in the most deprived 20% to 40% in the deprived 20% to 40% in the country, opportunities country? for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by The site is within 30 mins of the town centre by all sectors of the population public transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not within and 2-5km) to key services? walkable distance. Town centre is located approximately 2km from the site.

Is it within 30 mins of a supermarket/ The site is within 30 mins of shops/supermarkets shopping centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km) to supermarkets/shopping distance. The nearest grocery shop is located centre? about 2.8km from the site.

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Is the site proposed for mixed-use The site is proposed for residential development development with good accessibility to local and public open space it will have good facilities? accessibility to local facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for residential development rewarding and satisfying employment use with employment included? and public open space. 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is 30ha and as such is the whole community thresholds for the application of affordable above the relevant threshold for the application of housing policy? CS Policy H3 defines that, for affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where Is the site proposed in a location with The site is located in close proximity to recreation/ people live and encourage community accessible natural green space? amenity open spaces and the nearest open access participation land is located adjacent to the site. Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is located within a groundwater source source protection zone? protection zone 2 and partially within a groundwater source protection zone 1. It also lies within a major aquifer area. Is the site proposed within a water abstraction The site is within a water abstraction management management area? area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. quality Would it lead to the loss of best and most The site is located on Grade 3 Agricultural Land. versatile agricultural land (Grade 1, 2 and 3a)? Will it lead to remediation of contaminated Insufficient information is available. ? land?

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13 To reduce the effects of traffic on the Does the site have good accessibility to local The site can be accessed by public transport and it environment facilities (as assessed above)? is also within cyclable distances to the town centre and key services, therefore, it should help minimise the need for travel and reliance on the private car. As the nearest bus stop is located about 500m of the site, the site is coded green. 14 To reduce contributions to climate Will the site proposal promote the It is likely that the site will promote the change incorporation of small-scale renewable in incorporation of small-scale renewable in developments? developments as Policy ENG1 of the Regional Plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable. Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code meet Code Level 3 or above of the Government's for Sustainable Homes? Code for Sustainable Homes for new-build dwellings and to achieve at least a BREEAM ‘very good' rating for non-residential developments. This will be applicable for this site. Meeting Code Level 3 or achieving high BREEAM rating will help minimise CO2 emissions. 15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is partially located within Flood Zone 2 events 3a, 3b) identified in the SFRA and have a and 3 and it is adjacent to a river body. proposed 'non-compatible' use or is located within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is located approximately 1.3km from a and geodiversity Area (SPA), Special Area of Conservation SSSI (Shaker's Lane SSSI). (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI

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Is the site in proximity to a County Wildlife The site is not located in proximity to a County Site, Local Nature Reserve or Ancient Wildlife Site, Local Nature Reserve or Ancient Woodland? Note: For the purposes of this Woodland. The nearest Local Nature Reserve, assessment, proximity will be taken to mean Moreton Hall Community Woods, is located that the site is within 500m of a site. approximately 1.2km from the site. Are BAP habitats known to be on the site? There are no BAP habitats on the site or in its proximity. Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS in designated geological site - SSSI or RIGS proximity to the site. (Regionally Important Geological/Geomorphological Sites). The site

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Economic 19 To achieve sustainable levels of Is the site proposed for mixed-use prosperity and economic growth development or employment? The site is proposed for residential development throughout the plan area and public open space without employment. 20 To revitalise town centres Is the site proposed for mixed-use The proposed site is located at the edge of the development or employment in town centres? town and is proposed for residential development only with public open spaces included. 21 To encourage efficient patterns of Is the site proposed in a proximity to a public The site is located in proximity to a public transport movement in support of economic transport route or in a walkable/cyclable route and the nearest bust stop is located growth distance? approximately 500m from the site. 22 To encourage and accommodate both Will it increase employment land availability? The site is proposed for residential development indigenous and inward investment and public open space. Summary Assessment Site 4a is an urban extension to Bury St. Edmunds of 30ha. Its development would result in the loss of a comparatively large area of greenfield agricultural land. The site is located within a groundwater source protection zone 2 and partially within a groundwater source protection zone 1, as well as within a water abstraction management area. Therefore, the site development may affect the quality of groundwater. On the plus side, the site would benefit from the services offered within Bury St. Edmunds and it would have the advantage of being located close to a public transport route - the nearest bus stop is located approximately 500m from the site and to Public Rights of Way. The site is proposed for residential development and public open space and it has good accessibility to local facilities. The proposed site is located in proximity to the Shaker's Lane SSSI (about 1.3km). However, there are no other statutory or locally designated sites in its proximity. The site is located within Flood Zones 2 and 3 and it is adjacent to a water body.

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Table C.8 - Bury St. Edmunds - Site 5 SA Objective Indicator Notes Colour Code Bury St. Edmunds - Site 5 Corresponding to site submission references 73 - Residential (6.23ha), 94 - Residential (30.38ha) and 130 - Residential and Commercial with additional ancillary uses (17.88ha); 54.49ha in total. Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 1.75km from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights of Nearby Public Rights of Way will improve Way? accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within cyclable distance but not within walking and 2-5km)? distance. The nearest primary school is located approximately 850m from the site. 4 To reduce poverty and social exclusion Will the site be located near or within LSOAs As the site is not located within LSOA in the most in the most deprived 20% to 40% in the deprived 20% to 40% in the country, opportunities country? for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by The site is within 30 mins of the town centre by all sectors of the population public transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km) to key services? distance. Town centre is located approximately 3km from the site. Is it within 30 mins of a supermarket/ shopping The site is within 30 mins of shops/supermarkets centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km) to supermarkets/shopping centre? distance. The nearest grocery shop that can provide is located about 3km from the site.

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Is the site proposed for mixed-use development with good accessibility to local The site is proposed for residential development facilities? and it will have good accessibility to local facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for mixed use development rewarding and satisfying employment use with employment included? with employment included. 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is 54.49ha and as such is the whole community thresholds for the application of affordable above the relevant threshold for the application of housing policy? CS Policy H3 defines that, for affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where people Is the site proposed in a location with The site is located next to recreation/ amenity live and encourage community accessible natural green space? open spaces and the nearest open access land is participation located approximately 1.45km from the site. Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is located within a groundwater source source protection zone? protection zone 2 and it is also lies within a major aquifer area. Is the site proposed within a water abstraction The site is within a water abstraction management management area? area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. Would it lead to the loss of best and most The site is located on Grade 3 Agricultural Land. versatile agricultural land (Grade 1, 2 and 3a)? Will it lead to remediation of contaminated The site is not thought to be located on land? contaminated land.

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13 To reduce the effects of traffic on the Does the site have good accessibility to local The site can be accessed by public transport and environment facilities (as assessed above)? it is also within cyclable distances to the town centre and key services, therefore, it should help minimise the need for travel and reliance on the private car. As the nearest bus stop is located approximately 100m from the site, the site is coded green. 14 To reduce contributions to climate Will the site proposal promote the It is likely that the site will promote the change incorporation of small-scale renewable in incorporation of small-scale renewable in developments? developments as Policy ENG1 of the regional plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable. Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code meet Code Level 3 or above of the Government's for Sustainable Homes? Code for Sustainable Homes for new-build dwellings and to achieve at least a BREEAM ‘very

good' rating for non-residential developments. This will be applicable for this site. Meeting Code Level 3 or achieving high BREEAM rating will help minimise CO2 emissions. 15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is not located within Flood Zones 2, 3a or events 3a, 3b) identified in the SFRA and have a 3b or within 9m of a river. proposed 'non-compatible' use or is located within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is located approximately 1.5km of a SSSI and geodiversity Area (SPA), Special Area of Conservation (The Glen Chalk Caves). However, is not located (SAC) or Site of Special Scientific Interest in proximity to a SAC or SPA. (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI

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Is the site in proximity to a County Wildlife The site is not located in proximity to a County Site, Local Nature Reserve or Ancient Wildlife Site, Local Nature Reserve or Ancient Woodland? Note: For the purposes of this Woodland. The nearest Local Nature Reserve is assessment, proximity will be taken to mean Moreton Hall Community Woods located that the site is within 500m of a site. approximately 1km from the site. Are BAP habitats known to be on the site? There are no BAP habitats on the site or in its proximity. Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS. designated geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site

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Is the site in or adjacent to an Area of The site is not in or adjacent to an Area of Archaeological Importance or a potential Archaeological Importance. archaeological site? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of an Area of Archaeological Importance. 18 To conserve and enhance the quality Is the site in or adjacent to a Green Corridor? The site is not in or adjacent to a Green Corridor. and local distinctiveness of landscapes Note: For the purposes of this assessment, and townscapes proximity will be taken to mean that the site is within 40m of a Green Corridor. Will the site development lead to coalescence of urban extensions with nearby villages? The site development will not lead to coalescence of urban extension with nearby villages. Economic 19 To achieve sustainable levels of Is the site proposed for mixed-use prosperity and economic growth development or employment? The site is proposed for residential development throughout the plan area with employment. 20 To revitalise town centres Is the site proposed for mixed-use The proposed site is located at the edge of the development or employment in town centres? town. 21 To encourage efficient patterns of Is the site proposed in a proximity to a public The site is located in proximity to a public movement in support of economic transport route or in a walkable/cyclable transport route and the nearest bust stop is growth distance? located approximately 100m from the site. 22 To encourage and accommodate both Will it increase employment land availability? The site is proposed for residential development indigenous and inward investment with employment. Summary Assessment The 54.49ha site abuts Bury St. Edmunds settlement boundary. Its development would lead to a comparatively substantial increase in the area of Bury St. Edmunds and result in the loss of a large area of greenfield agricultural land. It may also affect the quality of groundwater, as it is located within a water abstraction management area and a groundwater source protection zone 2. The proposed site is located in proximity to the Glen Chalk Caves SSSI (about 1.5km). The nearest Local Nature Reserve is Moreton Hall Community Woods located approximately 1km from the site. Similarly to the other proposed sites, this site would benefit from the services offered within Bury St. Edmunds and it would have the advantage of being located close to a public transport route - the nearest bus stop is located approximately 100m from the site and to Public Rights of Way. The site is proposed for residential and commercial development with additional ancillary uses (with employment) and has good accessibility to local facilities. The site is not located within a flood risk area.

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Table C.9 - Bury St. Edmunds - Site 6 SA Objective Indicator Notes Colour Code Bury St. Edmunds - Site 6 Corresponding to site submission references 48 and 65 (133ha in total); Site 48 - Residential and Community Facilities and Site 65 - Residential and Community Facilities.

1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 0.83km from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights of Nearby Public Rights of Way will improve Way? accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within cyclable distance but not within walking and 2-5km)? distance. The nearest primary school is located approximately 1,000m from the site. 4 To reduce poverty and social exclusion Will the site be located near or within LSOAs As the site is not located within LSOA in the most in the most deprived 20% to 40% in the deprived 20% to 40% in the country, opportunities country? for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by public The site is within 30 mins of the town centre by all sectors of the population transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km) to key services? distance. Town centre is located approximately 2.4 km from the site. Is it within 30 mins of a supermarket/ shopping The site is within 30 mins of shops/supermarkets centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km) to supermarkets/shopping centre? distance. The nearest grocery shop is located about 1,600m from the site.

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Is the site proposed for mixed-use Although the site is proposed for residential and development with good accessibility to local community facilities development, it has already facilities? good accessibility to existing local facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for residential and rewarding and satisfying employment use with employment included? community development and it is likely to provide some employment with the construction of new community facilities. 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is 133ha and as such is the whole community thresholds for the application of affordable above the relevant threshold for the application of housing policy? CS Policy H3 defines that, for affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where people Is the site proposed in a location with The site is located next to recreation/ amenity live and encourage community accessible natural green space? open spaces and the nearest open access land is participation located approximately 600m from the site. Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is located within a groundwater source source protection zone? protection zone 2 and is within a major aquifer area. Is the site proposed within a water abstraction The site is within a water abstraction management management area? area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. Would it lead to the loss of best and most The site is located on Grade 2 and 3 Agricultural versatile agricultural land (Grade 1, 2 and 3a)? Land.

Will it lead to remediation of contaminated The site is not thought to be located on land? contaminated land.

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13 To reduce the effects of traffic on the Does the site have good accessibility to local The site can be accessed by public transport and environment facilities (as assessed above)? it is also within cyclable distances to the town centre and key services, although a range of community facilities is also being proposed for the site. As the nearest bus stop is located approximately 150m from the site, the site is coded green. 14 To reduce contributions to climate Will the site proposal promote the It is thought that the site will promote the change incorporation of small-scale renewable in incorporation of small-scale renewable in developments? developments as Policy ENG1 of the regional plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable. Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code meet Code Level 3 or above of the Government's for Sustainable Homes? Code for Sustainable Homes for new-build dwellings and to achieve at least a BREEAM ‘very

good' rating for non-residential developments. This will be applicable for this site. Meeting Code Level 3 or achieving high BREEAM rating will help minimise CO2 emissions. 15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is not located within Flood Zones 2, 3a or events 3a, 3b) identified in the SFRA and have a 3b or located within 9m of a river. proposed 'non-compatible' use or is located within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is located approximately 800m of a SSSI and geodiversity Area (SPA), Special Area of Conservation (The Glen Chalk Caves). However, is not located (SAC) or Site of Special Scientific Interest in proximity to a SAC or SPA. (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI

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Is the site in proximity to a County Wildlife The site is not located in proximity to a County Site, Local Nature Reserve or Ancient Wildlife Site or Ancient Woodland. However, the Woodland? Note: For the purposes of this nearest Local Nature Reserve, Moreton Hall assessment, proximity will be taken to mean Community Woods, is located approximately that the site is within 500m of a site. 500m from the site. Are BAP habitats known to be on the site? There are no BAP habitats on the site or in its proximity. Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS. designated geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site

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Economic 19 To achieve sustainable levels of Is the site proposed for mixed-use The site is proposed for residential use and prosperity and economic growth development or employment? community facilities development. It may provide throughout the plan area some employment opportunities at the new community facilities. 20 To revitalise town centres Is the site proposed for mixed-use The proposed site is located at the edge of the development or employment in town centres? town. 21 To encourage efficient patterns of Is the site proposed in a proximity to a public The site is located in proximity to a public movement in support of economic transport route or in a walkable/cyclable transport route and the nearest bust stop is growth distance? located approximately 150m from the site. 22 To encourage and accommodate both Will it increase employment land availability? There may be some benefits against this indigenous and inward investment objective, but they are likely to be not significant. Summary Assessment The proposed site represents a large-scale urban extension of 133ha, potentially leading to a significant increase in the area of Bury St. Edmunds and resulting in the loss of a large area of greenfield agricultural land. The site development may affect the quality of groundwater, as it is located within a water abstraction management area and a groundwater source protection zone 2. The proposed site is located in proximity of the Glen Chalk Caves SSSI (about 800m) and to the Local Nature Reserve, Moreton Hall Community Woods (500m). On the positive side, the site would benefit from the services offered within Bury St. Edmunds and it would have the advantage of being located close to a public transport route - the nearest bus stop is located approximately 150m from the site and to Public Rights of Way. The site is proposed for residential use and community facilities and therefore it is likely to provide some employment opportunities and good accessibility to local facilities. The site is not located within an area of flood risk.

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Table C.10 - Haverhill - Site 1 SA Objective Indicator Notes Colour Code Haverhill - Site 1 No site submission reference - Proposed use - Mixed Use; 150ha in total. Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 3km from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights of Nearby Public Rights of Way will improve Way? accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km)? distance. The nearest primary school is located about 2km from the site.

Is it within 30 mins of a supermarket/ The site is within 30 mins of shops/supermarkets shopping centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km) to supermarkets/shopping distance. Town Centre is located approximately centre? 2.5km from the site where grocery shops can be found.

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Is the site proposed for mixed-use development with good accessibility to local The site is proposed for mixed use development facilities? and will have good accessibility to local facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for mixed use development rewarding and satisfying employment use with employment included? with employment included. 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is 150 hectares and as the whole community thresholds for the application of affordable such is above the relevant threshold for the housing policy? CS Policy H3 defines that, for application of affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where Is the site proposed in a location with The site is located next to an open access land people live and encourage community accessible natural green space? (about 500m). participation Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is partially located within a groundwater source protection zone? source protection zone. Is the site proposed within a water abstraction The site is within a water abstraction management area? management area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. Would it lead to the loss of best and most The site is located on Grade 2 Agricultural Land. versatile agricultural land (Grade 1, 2 and 3a)? Will it lead to remediation of contaminated Insufficient information is available. ? land? 13 To reduce the effects of traffic on the Does the site have good accessibility to local The site can be accessed by public transport, environment facilities (as assessed above)? therefore, it should help minimise the need for travel and reliance on the private car.

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14 To reduce contributions to climate Will the site proposal promote the It is likely that the site will promote the change incorporation of small-scale renewable in incorporation of small-scale renewable in developments? developments, as Policy ENG1 of the Regional Plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable. Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code meet Code Level 3 or above of the Government's for Sustainable Homes? Code for Sustainable Homes for new-build dwellings and to achieve at least a BREEAM ‘very good' rating for non-residential developments. This will be applicable for this site. Meeting Code Level 3 or achieving high BREEAM rating will help minimise CO2 emissions. 15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is partially located within Flood Zone 3 events 3a, 3b) identified in the SFRA and have a and a river body is crossing the site. proposed 'non-compatible' use or is located within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is located approximately 1km from a and geodiversity Area (SPA), Special Area of Conservation SSSI (Lawn Wood SSSI). (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI Is the site in proximity to a County Wildlife The site is not located in proximity to a County Site, Local Nature Reserve or Ancient Wildlife Site, Local Nature Reserve or Ancient Woodland? Note: For the purposes of this Woodland. The nearest Local Nature Reserve is assessment, proximity will be taken to mean Haverhill Railway Walks and is located that the site is within 500m of a site. approximately 1km from the site.

Are BAP habitats known to be on the site? The site is located adjacent to a BAP habitat - Wet Woodland.

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Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS. designated geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site

Is the site in or adjacent to a Historic Park and The site is not located in proximity to a Historic Garden? Note: For the purposes of this Park and Garden. assessment, proximity will be taken to mean that the site is within 40m of a Historic Park and Garden. Is the site in or adjacent to a Scheduled The nearest SAM is Moated Site located about Ancient Monument (SAM)? Note: For the 250m away from the site. purposes of this assessment, proximity will be taken to mean that the site is within 40m of a SAM. Is the site in or adjacent to an Area of The site is not in or adjacent to an Area of Archaeological Importance or a potential Archaeological Importance. archaeological site? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of an Area of Archaeological Importance. 18 To conserve and enhance the quality Is the site in or adjacent to a Green Corridor? The site is not in or adjacent to a Green Corridor. and local distinctiveness of Note: For the purposes of this assessment, landscapes and townscapes proximity will be taken to mean that the site is within 40m of a Green Corridor.

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Will the site development lead to coalescence The site development will not lead to coalescence of urban extensions with nearby villages? of the urban extension with nearby villages.

22 To encourage and accommodate both Will it increase employment land availability? The site is proposed for mixed-use development indigenous and inward investment with employment. Summary Assessment The proposed site represents a large-scale urban extension of 150ha, potentially leading to a significant increase in the area of Haverhill and resulting in the loss of a large area of greenfield agricultural land. The site lies within a water abstraction management area and partially within groundwater source protection zone. The proposed site is located in proximity to Lawn Wood SSSI (about 1km) and it is adjacent to a BAP habitat (Wet Woodland). The site development may also impact on the setting on the nearby village Conservation Area. This may necessitate incorporation of mitigation measures in the site design and development to avoid potential effects on ecologically and historically important areas and their settings. The site is located within Flood Zone 3 with a river body crossing it. On the positive side, the site would benefit from the services offered within Haverhill and it would have the advantage of being located in close proximity to a public transport route - the nearest bus stop is located approximately 200m from the site and to Public Rights of Way. The site is proposed for mixed use and has good accessibility to local facilities.

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Table C.11 - Haverhill - Site 2 SA Objective Indicator Notes Colour Code Haverhill - Site 2 No site submission reference - Proposed use - Mixed Use; 85ha in total. Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 2.5km from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights of Nearby Public Rights of Way will improve Way? accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km)? distance. The nearest primary school is located about 1.4km from the site.

4 To reduce poverty and social exclusion Will the site be located near or within LSOAs As the site is not located within LSOA in the most in the most deprived 20% to 40% in the deprived 20% to 40% in the country, country? opportunities for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by public The site is within 30 mins of the town centre by all sectors of the population transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km) to key services? distance. Town centre is located approximately 1.5 km from the site. Is it within 30 mins of a supermarket/ shopping The site is within 30 mins of shops/supermarkets centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km) to supermarkets/shopping centre? distance. Town Centre is located approximately 1.5km from the site where grocery shops can be found.

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Is the site proposed for mixed-use development with good accessibility to local The site is proposed for mixed use development facilities? and will have good accessibility to local facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for mixed use development rewarding and satisfying employment use with employment included? with employment included. 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is 85 hectares and as the whole community thresholds for the application of affordable such is above the relevant threshold for the housing policy? CS Policy H3 defines that, for application of affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where people Is the site proposed in a location with The site is located next to an open access land live and encourage community accessible natural green space? (about 500m). participation Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is not located within a groundwater source protection zone? source protection zone. Is the site proposed within a water abstraction The site is within a water abstraction management area? management area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 1 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. 0 Would it lead to the loss of best and most The site is located on Grade 2 Agricultural Land. versatile agricultural land (Grade 1, 2 and 3a)? Will it lead to remediation of contaminated Insufficient information is available. ? land? 1 To reduce the effects of traffic on the Does the site have good accessibility to local The site can be accessed by public transport, 3 environment facilities (as assessed above)? therefore, it should help minimise the need for travel and reliance on the private car.

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1 To reduce contributions to climate Will the site proposal promote the It is likely that the site will promote the 4 change incorporation of small-scale renewable in incorporation of small-scale renewable in developments? developments, as Policy ENG1 of the Regional Plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable. Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code meet Code Level 3 or above of the Government's for Sustainable Homes? Code for Sustainable Homes for new-build dwellings and to achieve at least a BREEAM ‘very good' rating for non-residential developments. This will be applicable for this site. Meeting Code Level 3 or achieving high BREEAM rating will help minimise CO2 emissions. 1 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is not located within Flood Zones 2, 3a 5 events 3a, 3b) identified in the SFRA and have a or 3b or located within 9m of a river. proposed 'non-compatible' use or is located within 9m of a river? 1 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is located approximately 1.5km from a 6 and geodiversity Area (SPA), Special Area of Conservation SSSI (Lawn Wood SSSI). (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI Is the site in proximity to a County Wildlife The site is not located in proximity to a County Site, Local Nature Reserve or Ancient Wildlife Site, or Ancient Woodland. However it is Woodland? Note: For the purposes of this located approximately 500m from a Local Nature assessment, proximity will be taken to mean Reserve (Haverhill Railway Walks). that the site is within 500m of a site. Are BAP habitats known to be on the site? The site is located adjacent to a BAP habitat - Wet Woodland.

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Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS. designated geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site

within 1km of a SSSI will be coded red and within 500m will be coded amber. The site adjacent to RIGS will be coded red and within 500m - amber. 1 To conserve and where appropriate Are there any listed buildings on or adjacent to There are no listed buildings on or adjacent to 7 enhance areas of historical and the site? the site. archaeological importance Is the site in or adjacent to a Conservation The nearest village Conservation Area is Area? Note: For the purposes of this Withersfield located approximately 500m from assessment, proximity will be taken to mean the site. The recommended gap between a that the site is within 40m of a Conservation village Conservation Area and new development Area. is 800m, therefore the site development may affect the settings of the Conservation Area.

Is the site in or adjacent to a Historic Park and The site is not located in proximity to a Historic Garden? Note: For the purposes of this Park and Garden. assessment, proximity will be taken to mean that the site is within 40m of a Historic Park and Garden. Is the site in or adjacent to a Scheduled The site is not located in proximity to a SAM. Ancient Monument (SAM)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of a SAM. Is the site in or adjacent to an Area of The site is not in or adjacent to an Area of Archaeological Importance or a potential Archaeological Importance. archaeological site? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of an Area of Archaeological Importance. 1 To conserve and enhance the quality Is the site in or adjacent to a Green Corridor? The site is not in or adjacent to a Green Corridor. 8 and local distinctiveness of landscapes Note: For the purposes of this assessment, and townscapes proximity will be taken to mean that the site is within 40m of a Green Corridor.

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Will the site development lead to coalescence The site development will not lead to of urban extensions with nearby villages? coalescence of the urban extension with nearby villages. Economic 1 To achieve sustainable levels of Is the site proposed for mixed-use 9 prosperity and economic growth development or employment? The site is proposed for mixed-use development throughout the plan area with employment. 2 To revitalise town centres Is the site proposed for mixed-use The proposed site is located at the edge of the 0 development or employment in town centres? town. 2 To encourage efficient patterns of Is the site proposed in a proximity to a public The site is located in proximity to a public 1 movement in support of economic transport route or in a walkable/cyclable transport route and the nearest bust stop is about growth distance? 600 meters from the site. 2 To encourage and accommodate both Will it increase employment land availability? The site is proposed for mixed-use development 2 indigenous and inward investment with employment. Summary Assessment The site represents an urban extension of 85ha, the development of which would significantly increase the area of Haverhill and result in the loss of a large area of greenfield agricultural land. The site lies within a water abstraction management area. The proposed site is located in proximity of Lawn Wood SSSI (about 1.5km) and to a Local Nature Reserve (about 500m). The site is also adjacent to a BAP habitat (Wet Woodland). The site development may also impact on the setting on the nearby village Conservation Area. This may necessitate incorporation of mitigation measures in the site design and development to avoid potential effects on ecologically and historically important areas and their settings. The site would benefit from the services offered within Haverhill and it would have the advantage of being located in close proximity to a public transport route - the nearest bus stop is located approximately 600m from the site and to Public Rights of Ways. The site is proposed for mixed use and has good accessibility to local facilities.

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Table C.12 - Haverhill - Site 3 SA Objective Indicator Notes Colour Code Haverhill - Site 3 No site submission reference - Proposed use - Mixed Use; 170ha in total. Social 1 To improve health of the population Is it within 30 mins of a GP, dentist and The site is within 30min of a GP, dentist and overall and reduce health inequalities hospital by public transport? hospital by public transport. The nearest doctor surgery is located about 1.5km from the site. Will it lead to a direct loss of public open The site will not result in any loss of public open space or open access land? space or open access land. Will it improve accessibility by Public Rights Nearby Public Rights of Way will improve of Way? accessibility to the site. 2 To maintain and improve levels of Is it within 30 mins of a school by public The site is within 30 mins of a primary school by education and skills in the population transport? public transport. overall Is it within walkable/cyclable distances (800m It is within walkable and cyclable distances. The and 2-5km)? nearest primary school is located about 500m from the site.

4 To reduce poverty and social Will the site be located near or within LSOAs As the site is not located within LSOA in the most exclusion in the most deprived 20% to 40% in the deprived 20% to 40% in the country, country? opportunities for regeneration are not likely. 5 To improve access to key services for Is it within 30 mins of the town centre by The site is within 30 mins of the town centre by all sectors of the population public transport? public transport. Is it within walkable/cyclable distances (800m It is within cyclable distance but not walkable and 2-5km) to key services? distance. Town centre is located approximately 1.2 km from the site. Is it within 30 mins of a supermarket/ The site is within 30 mins of shops/supermarkets shopping centre by public transport? by public transport. Is it within walkable/cyclable distances (800m It is within cyclable distances but not walkable and 2-5km) to supermarkets/shopping distance. Town Centre is located approximately centre? 1.2km from the site where grocery shops can be found.

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Is the site proposed for mixed-use development with good accessibility to local The site is proposed for mixed use development facilities? and will have good accessibility to local facilities. 6 To offer everybody the opportunity for Is the site proposed for employment or mixed The site is proposed for mixed use development rewarding and satisfying employment use with employment included? with employment included. 7 To meet the housing requirements of Is the site proposal over the relevant The proposed site area is 170 hectares and as the whole community thresholds for the application of affordable such is above the relevant threshold for the housing policy? CS Policy H3 defines that, for application of affordable housing policy. Bury St. Edmunds and Haverhill, for sites of 0.5ha and above, or 15 dwellings or more, 40% shall be affordable; for sites between 0.3ha and 0.5ha or between 10 and 14 dwellings, 30% shall be affordable, and for sites between 0.17ha and 3ha or between 5 and 9 dwellings, 20% should be affordable. 8 To improve the quality of where Is the site proposed in a location with The site is located adjacent to a people live and encourage community accessible natural green space? recreation/amenity open space. participation Environmental 9 To improve water and air quality Is the site proposed within a groundwater The site is partially located within a groundwater source protection zone? source protection zone. Is the site proposed within a water abstraction The site is within a water abstraction management area? management area. Is the site proposed within an Air Quality The site is not within an Air Quality Management Management Area (AQMA)? Area. 10 To conserve soil resources and quality Is the site proposed on Greenfield land? The site is proposed on Greenfield Land. Would it lead to the loss of best and most The site is located on Grade 2 Agricultural Land. versatile agricultural land (Grade 1, 2 and 3a)? Will it lead to remediation of contaminated Insufficient information is available. ? land? 13 To reduce the effects of traffic on the Does the site have good accessibility to local The site can be accessed by public transport, environment facilities (as assessed above)? therefore, it should help minimise the need for travel and reliance on the private car.

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14 To reduce contributions to climate Will the site proposal promote the It is likely that the site will promote the change incorporation of small-scale renewable in incorporation of small-scale renewable in developments? developments, as Policy ENG1 of the Regional Plan states that new development of more than 10 dwellings or 1,000m2 of non residential floor space should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable. Is there a clear commitment to meet Code One of the requirements of the Policy CS2 is to Level 3 or above of the Government’s Code meet Code Level 3 or above of the Government's for Sustainable Homes? Code for Sustainable Homes for new-build dwellings and to achieve at least a BREEAM ‘very good' rating for non-residential developments. This will be applicable for this site. Meeting Code Level 3 or achieving high BREEAM rating will help minimise CO2 emissions. 15 To reduce vulnerability to climatic Does the site lie within the flood risk zones (2, The site is not located within Flood Zones 2, 3a events 3a, 3b) identified in the SFRA and have a or 3b or located within 9m of a river. proposed 'non-compatible' use or is located within 9m of a river? 16 To conserve and enhance biodiversity Is the site in proximity to a Special Protection The site is not located in proximity to a SSSI, and geodiversity Area (SPA), Special Area of Conservation SAC or SPA. (SAC) or Site of Special Scientific Interest (SSSI)? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 2km of a SSSI Is the site in proximity to a County Wildlife The site is not located in proximity to a County Site, Local Nature Reserve or Ancient Wildlife Site, or Ancient Woodland. However it is Woodland? Note: For the purposes of this located approximately 350m from a Local Nature assessment, proximity will be taken to mean Reserve (Haverhill Railway Walks). that the site is within 500m of a site. Are BAP habitats known to be on the site? There are no BAP habitats on the site or in its proximity.

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Would it lead to a loss of or damage to a There are no geological SSSIs or RIGS. designated geological site - SSSI or RIGS (Regionally Important Geological/Geomorphological Sites). The site

within 1km of a SSSI will be coded red and within 500m will be coded amber. The site adjacent to RIGS will be coded red and within 500m - amber. 17 To conserve and where appropriate Are there any listed buildings on or adjacent There are no listed buildings on or adjacent to the enhance areas of historical and to the site? site. archaeological importance Is the site in or adjacent to a Conservation The site is not in or adjacent to a Conservation Area? Note: For the purposes of this Area. assessment, proximity will be taken to mean that the site is within 40m of a Conservation Area. Is the site in or adjacent to a Historic Park The site is not located in proximity to a Historic and Garden? Note: For the purposes of this Park and Garden. assessment, proximity will be taken to mean that the site is within 40m of a Historic Park and Garden. Is the site in or adjacent to a Scheduled There is a SAM within the proposed site (Moated Ancient Monument (SAM)? Note: For the Site at Great Wilsey Farm). purposes of this assessment, proximity will be taken to mean that the site is within 40m of a SAM. Is the site in or adjacent to an Area of The site is not in or adjacent to an Area of Archaeological Importance or a potential Archaeological Importance. archaeological site? Note: For the purposes of this assessment, proximity will be taken to mean that the site is within 40m of an Area of Archaeological Importance. 18 To conserve and enhance the quality Is the site in or adjacent to a Green Corridor? The site is not in or adjacent to a Green Corridor. and local distinctiveness of Note: For the purposes of this assessment, landscapes and townscapes proximity will be taken to mean that the site is within 40m of a Green Corridor.

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Will the site development lead to coalescence The site development will not lead to coalescence of urban extensions with nearby villages? of urban extension.

Economic 19 To achieve sustainable levels of Is the site proposed for mixed-use prosperity and economic growth development or employment? The site is proposed for mixed-use development throughout the plan area with employment. 20 To revitalise town centres Is the site proposed for mixed-use The proposed site is located at the edge of the development or employment in town centres? town. 21 To encourage efficient patterns of Is the site proposed in a proximity to a public The site is located in proximity to a public movement in support of economic transport route or in a walkable/cyclable transport route and the nearest bust stop is growth distance? adjacent to the site. 22 To encourage and accommodate both Will it increase employment land availability? The site is proposed for mixed-use development indigenous and inward investment with employment. Summary Assessment The proposed site represents a large-scale urban extension of 170ha, potentially leading to a significant increase in the area of Haverhill and resulting in the loss of a large area of greenfield agricultural land. The proposed site is located in close proximity of a Local Nature Reserve (about 350m) and also there is a SAM within the site - the Moated Site at Great Wilsey Farm. This may necessitate incorporation of mitigation measures in the site design and development to avoid potential effects on ecological and heritage assets and their settings. The site lies within a water abstraction management area. The site would benefit from the services offered within Haverhill and it would have the advantage of being located in close proximity to a public transport route - the nearest bus stop is located adjacent to the site and to Public Rights of Ways. The site is proposed for mixed use and has good accessibility to local facilities.

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Appendix D – Assessment of Plan Policies

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D.1.1 This section presents the findings of the detailed assessment of the policies set out in the St Edmundsbury Core Strategy. Each table contains predictions and evaluation of effects for each SA objective, in accordance with the methodology described in Section 3, together with a commentary/explanation of the assessment and recommendations of the mitigation measures. Table D.1 below explains the terms and symbols used in the tables.

Table D.1 - Assessment Tables – Terms and Symbols

Magnitude Scale Duration Permanence Certainty Major positive Local Within or in proximity to St Edmundsbury ST-MT Short term - Medium term Temp Temporary Low Minor positive Sub-Reg Western Suffolk and surrounding districts ST-LT Short term - Long term Perm Permanent Med

- No effect Reg/Nat East of England and beyond MT-LT Medium term - Long term High ? Unclear effects ST Short term

Minor negative MT Medium term

Major negative LT Long term

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Table D.2 – Policy CS1 St. Edmundsbury Spatial Strategy & Policy CS5: Settlement Hierarchy and Identity Policy CS1 St. Edmundsbury Spatial Strategy & Policy CS5: Settlement Hierarchy and Identity Policy CS1 Policy CS5 To date (1 April 2008) development (including land with a valid planning consent but not yet built) All proposals for new development will be expected to have regard to the position of the site provided for 6,380 new homes and has been distributed across the borough as follows: within the settlement hierarchy as follows: - Bury St Edmunds 42% Towns - Haverhill 40% Bury St Edmunds Haverhill - Rural Area 17% Key Service Centres Barrow Clare During the remainder of the LDF period, to 2031, new homes will be distributed as follows: Ixworth Kedington Bury St Edmunds 5,950: Stanton Wickhambrook - Previously developed land 650+ Local Service Centres - Greenfield 1,800 Bardwell Barningham - Strategic Urban Extensions 3,500 Cavendish Chedburgh Great Barton Great & Little Thurlow Haverhill 3,900: Great & Little Welnetham Hopton - Previously developed land 250 Hundon Ingham - Greenfield 1,150 Risby Rougham - Strategic Urban Extensions 2,500 Infill Villages Barnham Bradfield St George Rural Area: Chevington Coney Weston - Previously developed land 105 Cowlinge Fornham All Saints - Greenfield Fornham St Martin Great Bradley Hawkedon Hepworth Area Action Plans for Bury St Edmunds and Haverhill and a Site Allocations Development Plan Document Honington & Sapiston RAF Honington for the rural area will identify the location and precise boundaries of future development land. Horringer Lidgate Market Weston Ousden Pakenham Rede Stanningfield Stansfield Stoke by Clare Stradishall Thelnetham Troston Whepstead Withersfield Countryside All other settlements not identified in the list above and where a housing settlement boundary is not identified on the Proposals Map. 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 and functional vitality of the settlement as a whole. The coalescence of towns with surrounding settlements through new development will not be allowed to happen.

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Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health of Local MT- Perm Med + + ++ ++ Focusing development in existing towns None identified. the population overall and LT and service centres could contribute to reduce health inequalities securing long term investment in local health facilities as a result of economies of scale and increase in demand. The settlement hierarchy focuses development in sustainable locations maximising the opportunity for walking and cycling to work, study and services. 2 To maintain and improve Local MT- Perm Med + + ++ ++ Focusing development in existing towns None identified. levels of education and LT and services centres could contribute to skills in the population securing long term investment in local overall education facilities as a result of economies of scale and increase in demand. 3 To reduce crime and anti- - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social activity 4 To reduce poverty and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social exclusion 5 To improve access to key Local MT- Perm High + ++ ++ ++ The towns of Bury St Edmunds and See assessment of Policy CS8 as services for all sectors of LT Haverhill will be the main focus for the this policy states that all the population location of new development, supported by development proposals will be appropriate levels of development in Key required to be accessible to people Service Centres, Local Service Centres of all abilities including the mobility and Infill Villages. This will support impaired resulting in permanent improved access to services resulting in positive cumulative effects if these permanent medium to long term positive 2 policies are effectively effects. implemented. 6 To offer everybody the - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. opportunity for rewarding and satisfying employment 7 To meet the housing Sub- ST- Perm High + ++ ++ ++ Spatial distribution of housing across the Reference to affordable housing of requirements of the whole Reg LT borough totalling 10,000 new homes to cross referring to Policy CS 6 which community 2031 will have permanent significant sets out the affordable housing effects on meeting housing requirements targets for the borough is for the borough. recommended. 8 To improve the quality of Local ST- Perm Med + + + + Maintaining the identity and cohesion of None identified. where people live and to LT nearby settlements should help preserve encourage community the quality of residential amenity and thus participation deliver positive, permanent effects for this objective.

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9 To improve water and air Sub- MT- Perm Med ------The spatial strategy aims to achieve Effective implementation of CS quality Reg LT environmentally sustainable economic Policy 2 should ensure that any growth with the protection of the natural new development incorporates environment however; any new measures to improve water and development is likely to have negative local air quality to a certain extent. effects on water resources and local air quality. Increasingly over time, the development of more housing will give rise to increases in population, which is likely in turn to increase traffic movement and generate additional building and transport related emissions, contributing to localised degradation in air quality and added pressure on water resources. 10 To conserve soil Local MT- Perm Med 0 - -- - In the short-term new development will be Effective implementation of CS resources and quality LT sited on the previously developed land Policy 2 should ensure that any through the sequential approach. Some new development incorporates housing is likely to be on greenfield sites in measures to conserve water the medium to longer term which will have resources and local air quality to a negative effects on this objective. certain extent. No indication of housing densities is provided. 11 To use water and mineral Local MT- Perm Med ------The spatial strategy aims to achieve Effective implementation of CS resources efficiently, and LT environmentally sustainable economic Policy 2 should ensure that any re-use and recycle where growth with the protection of the natural new development incorporates possible environment. However, increasingly over measures to make efficient use of time, the development of more housing will water however, no reference to re- give rise to increases in population use and recycle of minerals and resulting in pressure on water resources. waste resources. See assessment of Policy CS2. 12 To reduce waste Local MT- Perm Med ------More housing is likely to result in additional See assessment of Policy CS2. LT waste. 13 To reduce the effects of Local MT- Perm Med 0 - -- - Although the sequential approach should See assessment of Policy CS8: traffic on the environment LT help reduce the need to travel, traffic Sustainable Transport - effective volumes are likely to increase, as housing implementation of the sustainable is built over the plan period. This will result transport hierarchy which promotes in negative effects on the environment, the walking and cycling above the use significance increases in the long term due of the car in all new development to the cumulative effect. should offset these negative effects.

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14 To reduce contributions to Reg/Nat MT- Perm High ------More housing, increasing over the plan No specific reference to climate climate change LT period, will continue to contribute to climate change in the Core Strategy. change through greenhouse gas emissions Suggest separate policy dealing from development and increased traffic with climate change at a strategic flows. level or reference should be made in Policy CS2: Sustainable development.

15 To reduce vulnerability to Reg/Nat MT- Perm High - - - - New development will increase amount of See comment above for SA climatic events LT impermeable surfaces and may increase Objective 14. flood risk. 16 To conserve and enhance Local MT- Perm Med 0 - -- - In the short-term new development will be Effective implementation of CS biodiversity and LT sited on the previously developed land Policy 2 should ensure that any geodiversity through the sequential approach. Some new development incorporates housing is likely to be on greenfield sites in measures to protect and enhance the medium to longer term which will have biodiversity, wildlife and negative effects on this objective. geodiversity therefore offsetting these negative effects to a certain degree. 17 To conserve and where Local ST- Perm Med +/- +/- - - The spatial strategy aims to achieve See assessment of Policy CS4 as appropriate enhance LT environmentally sustainable economic effective implementation of this areas of historical and growth with the protection of the built and policy aimed to create high quality archaeological historic environment. Focusing developments may offset these importance development in existing settlements may negative effects. have negative effects on historic buildings. Some housing is likely to be on greenfield sites in the medium to longer term which will have negative effects on this objective. Increased traffic levels can also have negative effects on the setting of historic buildings 18 To conserve and enhance Local MT- Perm Med +/- +/- - - Concentrating development in housing See assessment of Policy CS4 as - LT the quality and local settlement areas is likely to protect the effective implementation of this distinctiveness of local landscape however; intensification of policy aimed to create high quality landscapes and development in existing areas may have developments may offset these townscapes negative effects in the setting of heritage negative effects. resources and provision of urban open space.

19 To achieve sustainable Local ST- Perm Med + + + + Additional housing in existing settlement None identified. levels of prosperity and LT areas could provide a local supply of economic growth workers required by new and existing throughout the plan area businesses.

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20 To revitalise town centres Local ST- Perm High ++ ++ ++ ++ The towns of Bury St Edmunds and None identified. LT Haverhill will be the main focus for the location of new development, supported by appropriate levels of development in Key Service Centres, Local Service Centres and Infill Villages. This approach should ensure positive significant permanent effects in revitalising existing centres.

21 To encourage efficient Local ST- Perm Med + + + + Sequential approach to siting new See assessment of Policy CS8 as patterns of movement in LT development may help reduce the need to this policy states that all support of economic travel, particularly by private car. development proposals will be growth required to follow the sustainable transport hierarchy resulting in permanent positive cumulative effects if these 2 policies are effectively implemented.

22 To encourage and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. accommodate both indigenous and inward investment

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Table D.3 - Policy CS2: Sustainable Development Policy CS2: Sustainable Development A high quality, sustainable environment will be achieved by designing and incorporating measures appropriate to the nature and scale of development, including: The protection and enhancement of natural resources: a) making the most efficient use of land and infrastructure; b) protecting and enhancing biodiversity, wildlife and geodiversity, and avoiding impact on areas of nature conservation interest; c) safeguarding and enhancing wildlife corridors and ecological networks; d) conserving and, wherever possible, enhancing the character and quality of local landscapes and the wider countryside and public access to them, in a way that recognises and protects the fragility of these resources; e) conserving other natural resources including, air quality and soil and, wherever possible, enhancing them; f) protecting the quality and potential yield of water resources; g) maximising the efficient use of water including recycling of dirty water; and sustainable design of the built environment: h) providing the infrastructure and services necessary to serve the development; i) minimising the use of resources and energy, and exploring the feasibility and viability of decentralised energy (low carbon and/or renewable) in all new developments; j) incorporating the principles of sustainable construction including provision for recycling; and the minimisation of energy and resource efficiency at construction and occupancy phases. Developments should comply with the appropriate national standards such as the Code for Sustainable Homes and BREEAM; k) wherever possible, creating carbon neutral development; l) orientating buildings to maximise the benefit from sunlight and passive solar heating unless to do so would conflict with the grain of the surrounding area’s townscape, landscape or topography; m) aiming to meet, as a minimum, Code Level 3 of the Government’s Code for Sustainable Homes for new-build dwellings; n) maximising the use of recycled materials; o) taking account of flood risk; p) considering the natural drainage of surface water, including, where appropriate, the use of Sustainable Urban Drainage Systems (SUDS); q) making a positive contribution towards the vitality of the area through an appropriate mix of uses. In areas of strategic growth this will include employment, community, social, health and recreation facilities (including the protection and provision of informal and formal recreation, parks, open spaces and allotments); r) creating a safe environment which enhances the quality of the public realm; s) making a positive contribution to local distinctiveness, character, townscape and the setting of settlements; t) wherever possible, conserving or enhancing the historic environment including archaeological resources.

Effects Assessment

SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the Local ST- Perm Low + + ++ ++ CS2 (q) requires new None identified. health of the LT development to make a positive population overall contribution towards the vitality and reduce health of the area included the inequalities protection and provision of informal and formal recreation, parks and open spaces which may have indirect positive effects on improving health through provided increased opportunities for recreation.

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2 To maintain and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. improve levels of education and skills in the population overall 3 To reduce crime and Local LT Perm Low + + + + Provision of employment, None identified. anti-social activity community, social, health and recreation facilities as part of new development (CS2:q) may have indirect positive effects on crime levels. Policy also aims to create a safe environment (CS2:r). 4 To reduce poverty Local LT Perm Low + + + + Provision of community and None required. and social exclusion social facilities as part of new development should help create cohesive communities. 5 To improve access to Local ST- Perm High ++ ++ +++ +++ This policy strives to provide See assessment of Policy CS1 and CS8. key services for all LT the infrastructure and services Effective implementation of all three sectors of the necessary to serve policies should result in permanent population development which should significant cumulative effects in improving result in improving access to accessibility for communities. key facilities. 6 To offer everybody - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. the opportunity for rewarding and satisfying employment 7 To meet the housing - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. requirements of the whole community 8 To improve the - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. quality of where people live and to encourage community participation 9 To improve water Local ST- Perm High + ++ ++ ++ This policy strives to conserve None identified. and air quality LT natural resources including air quality (CS2:e) and protecting the quality of water (CS2:f) through designing and incorporating measures into new development resulting in permanent significant positive effects.

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10 To conserve soil Local ST- Perm High + ++ ++ ++ The policy strives to conserve None identified. resources and quality LT natural resources including soil wherever possible. If successfully implemented, this policy will have positive effects, increasing over time. 11 To use water and Local ST- Perm High + ++ ++ ++ This policy strives to maximise None identified. mineral resources LT the efficient use of water efficiently, and re-use including recycling of dirty and recycle where water (CS2:g). The policy possible requires new development to protect the water environment, which implies measures to promote water conservation will be supported and promotes the reuse of recycled materials (CS2:n) resulting in permanent significant positive effects. 12 To reduce waste Local ST- Perm High + ++ ++ ++ This is one of the key aims of None identified. LT the policy. In applying it to all new development, the benefits should increase over time. 13 To reduce the effects ? Local ST- Perm High +/- +/- +/- +/- No reference to minimising See assessment of Policy CS8: of traffic on the LT effects of car use or promoting Sustainable Transport - effective environment shift to non-motorised users in implementation of the sustainable this policy so as it currently transport hierarchy which promotes stands, this policy does not walking and cycling above the use of the achieve positive effects. car in all new development should ensure effects on traffic on the environment are reduced. Recommend that this policy includes a criterion that cross-refers to the overall aim of Policy CS8. 14 To reduce Reg/Nat ST- Perm High + ++ ++ ++ Policy CS2:m requires new Effective implementation of Policy CS8 contributions to LT development to meet Level 3 should ensure positive effects are climate change (25% improvement in CO2 achieved. Recommend that this policy emissions over Target includes a criterion that cross-refers to Emission Rate as determined the overall aim of Policy CS8. by the 2006 Building Regulation Standards) of the Government’s Code for Sustainable Homes and refers to creating carbon neutral development where possible. However, no reference to minimising the effects of car use and its contribution to increases in GHG emissions.

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15 To reduce Reg/Nat ST- Perm High + ++ ++ ++ Key aims of this policy (CS2:o None identified. vulnerability to LT & p) are to take account of climatic events flood risk, use of SUDS and other forms of natural drainage of surface water in new development. 16 To conserve and Local ST- Perm High + ++ ++ ++ This is the one of the key aims None identified. enhance biodiversity LT of the policy. In applying it to and geodiversity all new development, the benefits should increase over time. 17 To conserve and Local ST- Perm High + ++ ++ ++ This is the one of the key aims None identified. where appropriate LT of the policy. In applying it to enhance areas of all new development, the historical and benefits should increase over archaeological time. importance 18 To conserve and Local ST- Perm High + ++ ++ ++ This is the one of the key aims None identified. enhance the quality LT of the policy. In applying it to and local all new development, the distinctiveness of benefits should increase over landscapes and time. townscapes 19 To achieve - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. sustainable levels of prosperity and economic growth throughout the plan area 20 To revitalise town - Local LT Perm Low + + + + Policy CS2:q aims to add to the None identified. centres vitality of the area through an appropriate mix of uses, which may benefit the vitality and viability of the town centres. 21 To encourage - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. efficient patterns of movement in support of economic growth 22 To encourage and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. accommodate both indigenous and inward investment

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Table D.4 - Policy CS3: The Natural and Built Environment Policy CS3: The Natural and Built Environment The diversity, character and quality of the natural and built environment will be protected, conserved, managed, and where possible enhanced. A network of designated sites, protected habitats and species (BAPS), wildlife or green corridors, and other green spaces will be identified and protected and habitat creation supported through policies in the Development Management DPD and other DPDs in the Local Development Framework.

Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health Local ST- Perm Low + + + + Positive but not significant indirect None identified. of the population overall LT effects on improving health identified and reduce health as provision of green spaces may inequalities provide increased opportunity for passive recreation 2 To maintain and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. improve levels of education and skills in the population overall 3 To reduce crime and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. anti-social activity 4 To reduce poverty and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social exclusion 5 To improve access to Local ST- Temp Low + + + + Positive but not significant indirect None identified. key services for all LT effects identified as provision of green sectors of the spaces may provide increased population opportunity for access to recreational facilities. 6 To offer everybody the - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. opportunity for rewarding and satisfying employment 7 To meet the housing - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. requirements of the whole community 8 To improve the quality - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of where people live and to encourage community participation

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9 To improve water and Local LT Perm Low 0 0 + + Conservation, management and None identified. air quality enhancement of habitats and wildlife corridors may have minor positive effects on local air quality through providing carbon sink.

10 To conserve soil Local MT- Perm High + + + + The enhancement and identification of None identified. resources and quality LT new sites for habitats and species should help to conserve soils. 11 To use water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. mineral resources efficiently, and re-use and recycle where possible 12 To reduce waste - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. 13 To reduce the effects of - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. traffic on the environment 14 To reduce contributions - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. to climate change 15 To reduce vulnerability - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. to climatic events 16 To conserve and Sub- ST- Perm High ++ ++ +++ +++ This policy directly strives to protect, Specific reference to international, enhance biodiversity Reg LT conserve and enhance biodiversity and national and local nature conservation and geodiversity protected BAP habitats and species will designated sites in the policy wording is be identified resulting in permanent recommended to strengthen the significant effects which should protection of these sites. enhance biodiversity and the local and sub-regional level. 17 To conserve and where Local ST- Perm Low + + + + Whilst this policy title refers to the Suggest including reference to the appropriate enhance LT natural and built environment, it does protection and enhancement of the built areas of historical and not refer to the built environment in the environment in the policy wording itself archaeological policy wording itself only in the to strengthen the policy wording and to importance supporting text. achieve more significant positive effects for this objective.

18 To conserve and Local ST- Perm Low + + + + Whilst the supporting text to this policy Suggest including reference to the enhance the quality and LT refers to the conservation and protection and enhancement of local distinctiveness of enhancement of landscapes the policy landscapes in the policy wording itself landscapes and wording itself does not. No explicit to strengthen the policy wording and to townscapes reference to conserving and enhancing achieve more significant positive local townscapes. effects for this objective.

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19 To achieve sustainable - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. levels of prosperity and economic growth throughout the plan area 20 To revitalise town - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. centres 21 To encourage efficient - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. patterns of movement in support of economic growth 22 To encourage and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. accommodate both indigenous and inward investment

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Table D.5 - Policy CS4: Design and Local Distinctiveness Policy CS4: Design and Local Distinctiveness Proposals for new development must create and contribute to a high quality, sustainable environment. Proposals will be expected to address, as appropriate, the following components: • detailed heritage and conservation design appraisals and information; • consideration of protection of the landscape and historic views; • an understanding of the local context and an indication of how the proposal will enhance the area; • protection of the natural environment; • in housing proposals the density and mix of housing; • provision or enhancement of open space, play, leisure and cultural facilities; • access and transport considerations.

Concept Statements and Masterplans will be required for sites which by virtue of size, location or proposed mix of uses are determined by the local planning authority to require a masterplanning approach. A landscape/townscape character appraisal will be an essential prerequisite for concept statements, design briefs and master plans. Area Action Plans and Site Allocations DPDs will define those sites where this approach is required.

The promotion of secure attractive, safe and people-friendly streets, to encourage more walking, cycling, recreation and local shopping, will be a priority for the council. Where appropriate the street environment will be improved/developed with a combination of the following (not exclusive): • Quality pavements and well-coordinated street furniture • Improvements to footpaths and cycle routes • Street trees and well-maintained landscaping • Clear and minimal signage • Traffic management schemes • Shared spaces and home zones • Cycle paths • Crime deterrence and safety measures, including lighting and CCTV • Public art New developments will be required to contribute towards public realm improvements. They should also provide active street frontages to create attractive and safe street environments.

Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health of Local ST- Perm Low + + + + All new proposals are required to The remit for this policy is that the population overall LT address the provision of enhancement proposals for new development must and reduce health of open space and leisure facilities create and contribute to a high quality, inequalities which may have indirect positive effects sustainable environment, this is similar in providing more opportunities for to the aim of CS1 and CS2. This policy passive recreation. seems to combine a number of CS policies CS2, CS3, CS8 - is this policy necessary?

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2 To maintain and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. improve levels of education and skills in the population overall

3 To reduce crime and Local ST- Perm Med + ++ ++ ++ A key priority for this policy is to Suggest that this policy is too detailed anti-social activity LT promote secure and safe streets to for a Core Strategy Policy and encourage more walking, cycling and recommend including this policy in the recreation. Measures such as crime development management DPD which deterrence and safety measures, would be derived from Policy CS2. including lighting and CCTV will be promoted which should help to reduce crime 4 To reduce poverty and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social exclusion 5 To improve access to Local ST- Perm Low + + + + This policy requires new proposals to key services for all LT address access and transport sectors of the considerations which could improve population access. 6 To offer everybody the - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. opportunity for rewarding and satisfying employment 7 To meet the housing Local ST- Perm Med + + + + This policy requires new development See general recommendation above. requirements of the LT to address the density and mix of whole community housing which should go some way to achieving positive effects in meeting housing requirements for the whole community. 8 To improve the quality Local ST- Perm High ++ ++ ++ ++ A high quality, sustainable environment See general recommendation above. of where people live LT is the key aim of this objective. New and to encourage developments are requires contributing community participation towards public realm improvements which should improve the quality of where people live resulting in significant permanent long term effects. 9 To improve water and - Local LT Perm Low 0 0 0 0 No obvious effects. It is suggested that the criterion relating air quality to 'protection of natural environment' should be removed from this policy as this is covered in Policy CS2. 10 To conserve soil - Local LT Perm Low 0 0 0 0 No obvious effects. As above. resources and quality

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11 To use water and - Local LT Perm Low 0 0 0 0 No obvious effects. As above. mineral resources efficiently, and re-use and recycle where possible 12 To reduce waste - Local LT Perm Low 0 0 0 0 No obvious effects. As above. 13 To reduce the effects of - Local LT Perm Low 0 0 0 0 No obvious effects. As above. traffic on the environment 14 To reduce contributions - Local LT Perm Low 0 0 0 0 No obvious effects. As above. to climate change 15 To reduce vulnerability - Local LT Perm Low 0 0 0 0 No obvious effects. As above. to climatic events 16 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. As above. enhance biodiversity and geodiversity 17 To conserve and where Local ST- Perm High ++ ++ ++ ++ All new proposals are required to take See general recommendation above. appropriate enhance LT account of detailed heritage and areas of historical and conservation design appraisals and the archaeological protection of historic views as well as importance concept statements and master plans being required for larger sites. This should ensure that development is in keeping with areas and buildings of historic importance resulting in significant permanent effects.

18 To conserve and Local ST- Perm High ++ ++ ++ ++ Concept statements and master plans See general recommendation above. enhance the quality and LT for larger sites should ensure that the local distinctiveness of development is in keeping with the landscapes and surrounding local landscape resulting in townscapes significant permanent effects.

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21 To encourage efficient - Local LT Perm Low + ++ ++ ++ This Policy should benefit this objective None identified. patterns of movement in by providing for a mix of uses and support of economic promoting sustainable modes of growth transport through improvements to footpaths and cycle routes and traffic management schemes. 22 To encourage and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. accommodate both indigenous and inward investment

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Table D.6 - Policy CS6: Affordable Housing Policy CS6: Affordable Housing Developers will be expected to allocate land within sites where housing is proposed to ensure that affordable housing is provided

Effects Assessment

SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of the population overall and reduce health inequalities 2 To maintain and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. improve levels of education and skills in the population overall 3 To reduce crime and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. anti-social activity 4 To reduce poverty and Local ST- Perm High + ++ ++ ++ The policy seeks the None identified. social exclusion LT development of affordable housing as an integral part of qualifying new development, which offers the potential to make a significant contribution to tackling poverty and social exclusion through the development of mixed communities.

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5 To improve access to Local ST- Perm High + ++ ++ ++ The policy allows the LPA to None identified. key services for all LT ensure that affordable housing sectors of the provision is directed to locations population that offer the greatest accessibility to education, employment, recreation, countryside health, community services and cultural facilities for a wider proportion of the population, particularly those without access to a car as greatest proportion of affordable housing will be provided in Bury St. Edmunds and Haverhill 6 To offer everybody the Local ST- Perm High 0 0 0 0 No obvious effects. None identified. - LT opportunity for rewarding and satisfying employment 7 To meet the housing Local ST- Perm High ++ ++ ++ ++ This is the aim of the policy None identified. requirements of the LT therefore permanent positive whole community significant effects are predicted. 8 To improve the quality - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of where people live and to encourage community participation 9 To improve water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. air quality 10 To conserve soil - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. resources and quality 11 To use water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. mineral resources efficiently, and re-use and recycle where possible 12 To reduce waste - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. 13 To reduce the effects - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of traffic on the environment 14 To reduce - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. contributions to climate change 15 To reduce - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. vulnerability to climatic events

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16 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance biodiversity and geodiversity 17 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. where appropriate enhance areas of historical and archaeological importance 18 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance the quality and local distinctiveness of landscapes and townscapes 19 To achieve - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. sustainable levels of prosperity and economic growth throughout the plan area 20 To revitalise town Local ST- Perm Low + + ++ ++ In order to create vibrant towns None identified. centres LT and villages, it is important that local people can remain within their communities – the provision of affordable housing should help to maintain a mixed population, with likely benefits against the objective. 21 To encourage efficient - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. patterns of movement in support of economic growth 22 To encourage and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. accommodate both indigenous and inward investment

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Table D.7 - Policy CS7: Gypsy and Travellers Accommodation Policy CS7: Gypsy and Travellers Accommodation In the countryside, proposals for gypsy sites and travelling show people will be permitted where:

a) the site has been identified in the DPD, or in the interim, where satisfactory evidence supporting a need for the accommodation is provided; b) the use of the site would not have an adverse impact upon the amenities of nearby occupiers; c) the proposal would not detract from the undeveloped open and rural character and appearance of the countryside; and d) adequate landscaping measures are included.

A condition or legal agreement to control the future use of sites for gypsies and travelling show people may be imposed, as appropriate.

Where the proven need is short term the development will be limited by a temporary permission.

Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve - Local LT Perm Low 0 0 0 0 No obvious effects. None the health of identified. the population overall and reduce health inequalities 2 To maintain - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. and improve levels of education and skills in the population overall 3 To reduce Local ST- Temp Low + + + + By providing formalised provision for gypsies and travellers, this None identified. crime and LT group will not anti-social be susceptible to inadvertent criminal activity such as activity trespassing thus there may be some positive effects.

4 To reduce Local ST- Perm Med + + + + In seeking to accommodate the gypsy and traveller population as None identified. poverty and LT opposed to excluding them, the preferred option should make a social contribution to the objective. exclusion 5 To improve - Local LT Perm Low + + + + Improvements in accessibility for this group of the population None identified. access to key through the provision of permanent encampments. services for all

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sectors of the population

6 To offer - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. everybody the opportunity for rewarding and satisfying employment 7 To meet the Local ST- Perm Med + + + + St.Edmundsbury is required to provide up to 20 pitches for None identified. housing LT gypsies and travellers by 2012 (the number of authorised pitches requirements in 2006 were 2) therefore this provision should meet the of the whole requirements of the gypsy and traveller community. community

8 To improve Local ST- Temp Med ++ ++ ++ ++ By identifying specific sites for encampments, the risk that sites None identified. the quality of LT will result in damage to the countryside or loss of recreational where people space for the wider population is reduced. In addition, it gives live and to certainty of residence for gypsies and travellers improving their encourage quality of life. community participation

9 To improve - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. water and air quality 10 To conserve MT- Perm High ------Sites for gypsies and travellers are likely to be in the countryside Recommend a criteria-based soil resources LT and therefore there will be permanent negative effects on soil policy for selecting suitable sites and quality resources as this policy wording currently stands there is no based on criteria outlined in reference to site selection criteria other than 'proposals would not Policy CS2 or alternatively cross- detract from the undeveloped and rural character and reference to policy CS2 should appearance of the countryside'. Stronger wording is required to be made to ensure sites are protect the natural environment. considered against biodiversity, landscape and heritage designations, soil quality, flood risk etc.

11 To use water - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. and mineral resources efficiently, and re-use and recycle where possible

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12 To reduce - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. waste 13 To reduce the - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. effects of traffic on the environment 14 To reduce - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. contributions to climate change 15 To reduce - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. vulnerability to climatic events 16 To conserve Local MT- Perm High ------Sites for gypsies and travellers are likely to be in the countryside Recommend a criteria-based and enhance LT and therefore there will be permanent negative effects on local policy for selecting suitable sites biodiversity biodiversity as this policy wording currently stands. There is no based on criteria outlined in and reference to site selection criteria other than 'proposals would not Policy CS2 or alternatively cross- geodiversity detract from the undeveloped and rural character and reference to Policy CS2 should appearance of the countryside'. Stronger wording is required to be made to ensure sites are protect the natural environment. considered against biodiversity, landscape and heritage designations, soil quality, flood risk etc.

17 To conserve Local MT- Perm High - - - - Negative effects are likely as sites are likely to be in the Recommend a criteria-based and where LT countryside. policy for selecting suitable sites appropriate based on criteria outlined in enhance Policy CS2 or alternatively cross- areas of reference to Policy CS2 should historical and be made to ensure sites are archaeological considered against biodiversity, importance landscape and heritage designations, soil quality, flood risk etc.

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18 To conserve ? Local ST- Perm Low +/- - - - The policy does include a criterion seeking to avoid insensitive Recommend a criteria-based and enhance LT location in respect of neighbouring uses. This offers the policy for selecting suitable sites the quality and opportunity to minimise adverse effects against the objective; based on criteria outlined in CS2 local although encampments may be considered to detract from the or alternatively cross-reference to distinctiveness quality of the countryside and wider landscape through visual CS2 should be made to ensure of landscapes intrusion. The requirement for landscaping measures may offset sites are considered against and these negative effects to a certain degree. biodiversity, landscape and townscapes heritage designations, soil quality, flood risk etc.

19 To achieve - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. sustainable levels of prosperity and economic growth throughout the plan area 20 To revitalise - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. town centres 21 To encourage - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. efficient patterns of movement in support of economic growth 22 To encourage - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. and accommodate both indigenous and inward investment

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Table D.8 - Policy CS8: Sustainable Transport Policy CS8: Sustainable Transport The council will develop and promote a high quality and sustainable transport system across the borough and reduce the need for travel through spatial planning and design.

All proposals for development will be required to provide for travel by a range of means of transport other than the private car in accordance with the following hierarchy:

• Walking • Cycling • Public Transport (including taxis) • Commercial vehicles • Cars

All development proposals will be required to be accessible to people of all abilities including those with mobility impairments.

Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health of Local ST- Temp Med + + + + The promotion of walking and None identified. the population overall LT cycling should result in some and reduce health indirect positive effects in inequalities improving health. 2 To maintain and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. improve levels of education and skills in the population overall 3 To reduce crime and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. anti-social activity 4 To reduce poverty and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social exclusion 5 To improve access to Local ST- Perm High ++ ++ ++ ++ This policy requires that all None identified. key services for all LT development proposals will be sectors of the accessible to people of all population abilities including those mobility impaired which should result in permanent positive and significant effects.

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6 To offer everybody the - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. opportunity for rewarding and satisfying employment 7 To meet the housing - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. requirements of the whole community 8 To improve the quality - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of where people live and to encourage community participation 9 To improve water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. air quality 10 To conserve soil - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. resources and quality 11 To use water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. mineral resources efficiently, and re-use and recycle where possible 12 To reduce waste - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. 13 To reduce the effects of Local ST- Perm Med +/- +/- +/- +/- This sustainable transport See assessment of CS1 and CS2. traffic on the LT hierarchy promoting non- environment motorised users could contribute to reducing car emissions and effects of traffic on the environment. The implementation of travels plans for new commercial development should also achieve positive effects. However, new development will inevitably increase traffic volumes, as housing is built over the plan period resulting in negative effects on the environment. 14 To reduce contributions Local ST- Perm Med +/- +/- +/- +/- As above. As above to climate change LT 15 To reduce vulnerability - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. to climatic events

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16 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance biodiversity and geodiversity 17 To conserve and where - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. appropriate enhance areas of historical and archaeological importance 18 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance the quality and local distinctiveness of landscapes and townscapes

19 To achieve sustainable - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. levels of prosperity and economic growth throughout the plan area 20 To revitalise town Local LT Perm Low + + + + The promotion of alternatives to None identified. centres the car is likely to have an indirect positive effect on the viability and vitality of town centres by making town centres more accessible to a wider cross-section of the population. Effects are likely to be long term, although not significant. 21 To encourage efficient - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. patterns of movement in support of economic growth 22 To encourage and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. accommodate both indigenous and inward investment

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Table D.9 - Policy CS9: Strategic Transport Improvements Policy CS9: Strategic Transport Improvements The council will continue to work with relevant partners, including Suffolk County Council and the Highways Agency, and developers, to secure the necessary transport infrastructure to achieve improvements to:

Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health of - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. the population overall and reduce health inequalities 2 To maintain and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. improve levels of education and skills in the population overall 3 To reduce crime and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. anti-social activity 4 To reduce poverty and Local MT- Perm Med + + + + Improvements in the transport None identified. social exclusion LT network could improve currently inaccessible areas reducing social exclusion. 5 To improve access to Local LT Temp High + + ++ ++ Improvements to all transport None identified. key services for all network modes should have sectors of the significant long term positive population effects on improving accessibility to key services particularly in the towns of Bury St.Edmunds and Haverhill. 6 To offer everybody the - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. opportunity for rewarding and satisfying employment

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7 To meet the housing - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. requirements of the whole community 8 To improve the quality - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of where people live and to encourage community participation

9 To improve water and ? Local ST- Perm Med +/- +/- +/- +/- This policy results in a See assessment of Policy CS2. air quality LT contradictory mix of positive and negative effects. Effective implementation of CS2 should ensure negative effects are minimised. 10 To conserve soil ? Local ST- Perm Med +/- +/- +/- +/- This policy results in a See assessment of Policy CS2. resources and quality LT contradictory mix of positive and negative effects. Effective implementation of CS2 should ensure negative effects are minimised. 11 To use water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. mineral resources efficiently, and re-use and recycle where possible 12 To reduce waste - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. 13 To reduce the effects of ? Local LT Temp High +/- +/- +/- +/- This policy aims to relieve the This policy results in a contradictory mix traffic on the adverse impacts of traffic in of positive and negative effects. environment Bury St Edmunds, Haverhill and those villages which have identified transport issues resulting in positive effects. Road infrastructure improvements conversely will result in negative effects. 14 To reduce contributions Sub- LT Temp High ------Strategic transport This policy results in a contradictory mix to climate change Reg improvements are likely to have of positive and negative effects. significant negative effects and contribute to further climate change. 15 To reduce vulnerability Sub- LT Temp High ------Improvements to Junctions 42 This policy results in a contradictory mix to climatic events Reg and 44 of the A14 are likely to of positive and negative effects. have an affect on floodplain Strategic transport improvements will zone 2. be subject to an EIA.

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16 To conserve and ? Local ST- Perm Med +/- +/- +/- +/- This policy results in a See assessment of Policy CS2. enhance biodiversity LT contradictory mix of positive and geodiversity and negative effects. Effective implementation of CS2 should ensure negative effects are minimised. 17 To conserve and where ? Local ST- Perm Med +/- +/- +/- +/- This policy results in a See assessment of Policy CS2. appropriate enhance LT contradictory mix of positive areas of historical and and negative effects. Effective archaeological implementation of CS2 should importance ensure negative effects are minimised. 18 To conserve and ? Local ST- Perm Med +/- +/- +/- +/- This policy results in a See assessment of Policy CS2. enhance the quality and LT contradictory mix of positive local distinctiveness of and negative effects. Effective landscapes and implementation of CS2 should townscapes ensure negative effects are minimised. 19 To achieve sustainable Local LT Temp High + + ++ ++ Improvements to all transport None identified. levels of prosperity and network modes should have economic growth significant long term positive throughout the plan effects on strengthening the area economy. 20 To revitalise town - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. centres 21 To encourage efficient Local LT Temp High + + ++ ++ Improvements to all transport None identified. patterns of movement in network modes should have support of economic significant long term positive growth effects on strengthening the economy. 22 To encourage and Local LT Temp High + + ++ ++ Improvements to all transport None identified. accommodate both network modes should have indigenous and inward significant long term positive investment effects on strengthening the economy through improved access and in attracting inward investment.

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Table D.10 - Policy CS10: Employment and the Local Economy Policy CS10: Employment and the Local Economy Employment land will be allocated in sustainable locations in the towns of Bury St Edmunds and Haverhill. Existing General Employment Areas in or near Key Service Centres or Local Service Centres will continue to be protected and promoted for employment uses.

Existing employment areas will continue to meet local and sub-regional needs at Clare, Great Wratting, Chedburgh, Barnham, Saxham and Stanton/Hepworth (Shepherd’s Grove).

Proposals for growth in Key Service Centres and Local Service Centres will be expected to include provision for employment land and premises to meet local needs and encourage sustainable communities.

Policies in Local Development Documents will set criteria for the continued encouragement of sustainable employment development and tourism development opportunities (including conversion of suitable buildings) in villages and rural areas.

Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health of - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. the population overall and reduce health inequalities 2 To maintain and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. improve levels of education and skills in the population overall 3 To reduce crime and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. anti-social activity 4 To reduce poverty and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social exclusion 5 To improve access to Sub- ST- Perm High ++ ++ ++ ++ By concentrating employment in None identified. key services for all Reg LT the towns of Bury St.Edmunds sectors of the population and Haverhill and in existing general employment areas in or near key service centres or local service centres should result in significant positive effects in improving access to employment.

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6 To offer everybody the Sub- ST- Perm High ++ ++ ++ ++ By concentrating employment in None identified. opportunity for Reg LT the towns of Bury St.Edmunds rewarding and satisfying and Haverhill and in existing employment general employment areas in or near key service centres or local service centres should ensure readily available opportunities for employment. Proposals for growth in Key Service Centres and Local Service Centres will meet local needs and encourage sustainable communities. 7 To meet the housing - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. requirements of the whole community 8 To improve the quality - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of where people live and to encourage community participation 9 To improve water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. air quality 10 To conserve soil - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. resources and quality 11 To use water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. mineral resources efficiently, and re-use and recycle where possible 12 To reduce waste - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. 13 To reduce the effects of Sub- ST- Perm High + + + + Possible reduction in car use Positive effects would be maximised traffic on the Reg LT and the need to travel due to through the effective implementation of environment provision of employment land in CS8 in ensuring travel plans are in accessible locations resulting in place for any new commercial minor positive effect on development. reducing greenhouse gas emissions in the long term. 14 To reduce contributions Sub- ST- Perm High + + + + Possible reduction in car use Positive effects would be maximised to climate change Reg LT and the need to travel due to through the effective implementation of provision of employment land in CS8 in ensuring travel plans are in accessible locations resulting in place for any new commercial minor positive effect on development. reducing greenhouse gas emissions in the long term.

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15 To reduce vulnerability - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. to climatic events 16 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance biodiversity and geodiversity 17 To conserve and where - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. appropriate enhance areas of historical and archaeological importance 18 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance the quality and local distinctiveness of landscapes and townscapes

19 To achieve sustainable Sub- ST- Perm High ++ ++ ++ ++ By protecting existing None identified. levels of prosperity and Reg LT employment land in sustainable economic growth locations and promoting quality throughout the plan area employment development at the Suffolk Business Park, will continue to meet the local employment needs in the Greater Cambridge area resulting in positive significant effects for the local and sub- region. 20 To revitalise town Local ST- Perm High ++ ++ ++ ++ By focusing development in LT centres existing towns and key service centres would help the vitality of the retail facilities in these areas and could create opportunities their improvement through economies of scale and investment. 21 To encourage efficient - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. patterns of movement in support of economic growth

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22 To encourage and Sub- ST- Perm High ++ ++ ++ ++ Proposals for growth in Key None identified. accommodate both Reg LT Service Centres and Local indigenous and inward Service Centres will encourage investment and accommodate investment into the region resulting in positive significant effects.

Table D.11 - Policy CS11: Retail, Leisure and Office Development Policy CS11: Retail, Leisure and Office Development The town centres of Bury St Edmunds and Haverhill will continue to be the focus for new retail, leisure and office development, taking into account;

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5 To improve access to Local ST- Perm High ++ ++ ++ ++ By concentrating retail in the See assessment of CS8. If the aim of key services for all LT towns of Bury St.Edmunds and the policy is to encourage cultural sectors of the Haverhill should result in facilities alongside retail and leisure population significant positive effects in opportunities, it is suggested that the improving access to retail and title of the policy be changed to leisure facilities. It will ensure encompass a broader spectrum. that shopping facilities are accessible by a range of modes particularly with the effective implementation of the sustainable transport hierarchy. 6 To offer everybody the Local ST- Perm High ++ ++ ++ ++ By concentrating retail in the Recommend removal of 'office opportunity for LT towns of Bury St.Edmunds and development' from this policy title as rewarding and satisfying Haverhill should ensure readily employment is dealt with in CS10. employment available opportunities for employment. 7 To meet the housing - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. requirements of the whole community 8 To improve the quality - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of where people live and to encourage community participation 9 To improve water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. air quality 10 To conserve soil - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. resources and quality 11 To use water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. mineral resources efficiently, and re-use and recycle where possible 12 To reduce waste - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. 13 To reduce the effects of Sub- ST- Perm High + + + + Possible reduction in car use Positive effects would be maximised traffic on the Reg LT and the need to travel due to through the effective implementation of environment promotion of retail and leisure CS8. facilities in accessible locations resulting in minor positive effects on reducing greenhouse gas emissions in the long term.

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14 To reduce contributions Sub- ST- Perm High + + + + Possible reduction in car use Positive effects would be maximised to climate change Reg LT and the need to travel due to through the effective implementation of promotion of retail and leisure CS8. facilities in accessible locations resulting in minor positive effects on reducing greenhouse gas emissions in the long term. 15 To reduce vulnerability - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. to climatic events 16 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance biodiversity and geodiversity 17 To conserve and where - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. appropriate enhance areas of historical and archaeological importance 18 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance the quality and local distinctiveness of landscapes and townscapes

19 To achieve sustainable Sub- ST- Perm High + + + + The promotion of retail and None identified. levels of prosperity and Reg LT leisure facilities in Bury economic growth St.Edmunds and Haverhill throughout the plan should help to strengthen the area local economy. 20 To revitalise town Local ST- Perm High ++ ++ ++ ++ This is the key aim of this None identified. LT centres policy. 21 To encourage efficient - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. patterns of movement in support of economic growth

22 To encourage and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. accommodate both indigenous and inward investment

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Table D.12 - Policy CS12:Bury St Edmunds Strategic Growth Policy CS12:Bury St Edmunds Strategic Growth Limited growth to the north-west: § around 900 homes § local employment provision § additional education, community and leisure facilities § maintaining identity and segregation of Fornham All Saints § new strategic public open space and recreation facilities § providing traffic relief § improved links to town centre

Limited growth to the west: § around 450 homes § maintaining identity and segregation of Westley § providing traffic relief § new sub-regional health campus (West Suffolk Hospital)

Further growth at Moreton Hall: § Around xxx homes § Completion of Eastern Relief Road § Other transport improvements § Secondary school § Community and recreation facilities

Long term strategic growth - north-east Bury St Edmunds: § Around 1,250 homes § Local employment provision § Improved connections to existing built-up area, including strategic employment sites, A14 and town centre § Country park § Education, social and community facilities § Maintaining identity and segregation of Great Barton

Long term strategic growth – south-east Bury St Edmunds: § Upto 3,500 homes beyond 2031 § Local employment provision § Improved connections to existing built-up area, including strategic employment sites and town centre § River valley open space corridor § Education, social and community facilities § South-eastern relief road

In each case, the actual amount of development will be determined by environmental and infrastructure considerations and the preparation of detailed masterplans in which the local community and other stakeholders have been fully engaged.

Note: For the assessment purposes, it has been considered that strategic sites identified in the Preferred Options Report relate to the identified locations for growth in Policy CS12 as follows: See Core Strategy and assessment of strategic sites: Limited growth to the north -west (strategic sites 1 and 2)

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Limited growth to the west (strategic site 3) Further growth at Moreton Hall (strategic site 5) Long term strategic growth - north east Bury St.Edmunds (strategic site 6) Long term strategic growth - south east Bury St.Edmunds (strategic sites 4 and 4a).

Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health of Local MT- Perm High 0 + + + Positive but not significant An area action plan for Bury St.Edmunds the population overall and LT indirect effects on is proposed. Also see assessment of reduce health inequalities improving health identified strategic sites. as provision of recreation facilities and public open space in the strategic expansion of Bury St.Edmunds may provide increased opportunity for recreation. 2 To maintain and improve Local MT- Perm High 0 ++ ++ ++ The strategic growth As above. levels of education and LT around Bury St.Edmunds skills in the population with the provision of overall additional education facilities to serve the local population will have positive significant effects on improving education opportunities and hence skills over the long term. 3 To reduce crime and anti- - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social activity 4 To reduce poverty and - Local LT Perm Low + + + + The policy should benefit None identified. social exclusion the objective by providing new housing, including a proportion of affordable housing, and new facilities and improving accessibility to the existing facilities.

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5 To improve access to key Sub- MT- Perm High 0 ++ ++ ++ The growth of Bury An area action plan for Bury St.Edmunds services for all sectors of Reg LT St.Edmunds with its is proposed. Also see assessment of the population strategic location on the strategic sites. A14 and the improvements in infrastructure as a result of new development will improve accessibility resulting in positive significant effects. 6 To offer everybody the Sub- MT- Perm High 0 ++ ++ ++ The strategic growth As above. opportunity for rewarding Reg LT around Bury St.Edmunds and satisfying with the provision of local employment employment to serve the local population will have positive significant effects on improving employment opportunities. 7 To meet the housing Local MT- Perm High 0 ++ ++ ++ The strategic growth As above. requirements of the whole LT around Bury St.Edmunds community with the provision of approx 6,100 new homes spread around Bury St.Edmunds will contribute to meeting the housing requirements in the medium and longer term. 8 To improve the quality of Local MT- Perm Low + ++ ++ ++ The provision of Positive effects would be maximised where people live and to LT improvements in open particularly through the effective encourage community space provision and implementation of CS3 in improving participation recreation facilities may public realm. have indirect positive effects on improving the quality of where people live.

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9 To improve water and air Sub- MT- Perm Med 0 - - - The strategic expansion of Effective implementation of CS Policy 2 quality Reg LT Bury St.Edmunds, like any should ensure that any new development new development, is likely incorporates measures to improve water to have negative effects on and local air quality to a certain extent. water resources and local air quality. Increasingly over time, the development of more housing will give rise to increases in population, which is likely in turn to increase traffic movement and generate additional building and transport related emissions, contributing to localised degradation in air quality and added pressure on water resources. These effects will be minimised to some extent through the promotion of sustainable transport modes, a mixed- use nature of the sites and design measures. 10 To conserve soil Local MT- Perm Med 0 - -- - The strategic expansion of Effective implementation of CS Policy 2 resources and quality LT Bury St.Edmunds is likely should ensure that efficient use of land . to be on greenfield sites in No indication of housing densities is the medium to longer term provided. which will have negative effects on this objective. 11 To use water and mineral Local MT- Perm Med 0 - -- - The development of more Effective implementation of CS Policy 2 resources efficiently, and LT housing will give rise to should ensure that any new development re-use and recycle where increases in population incorporates measures to make efficient possible resulting in pressure on use of water however, no reference to re- water resources. These use and recycle of minerals and waste effects will be minimised to resources. See assessment of CS2. some extent through high quality building design. 12 To reduce waste Local MT- Perm Med 0 - - - More housing is likely to See assessment of CS2. LT result in additional waste. These effects are likely to be minimised, as the nature of new development (i.e. urban extensions) should make implementation of recycling schemes viable.

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13 To reduce the effects of Local MT- Perm Med 0 - -- - New development will See assessment of CS8: Sustainable traffic on the environment LT result in more traffic and Transport - effective implementation of negative effects on the the sustainable transport hierarchy which environment, the promotes walking and cycling above the significance increases in use of the car in all new development the long term due to the should offset these negative effects. cumulative effect. These effects will be minimised to some extent through the promotion of sustainable transport modes and a mixed-use nature of the sites. 14 To reduce contributions to Reg/Nat MT- Perm High ------More housing, increasing No specific reference to climate change climate change LT over the plan period, will in the Core Strategy policies. Suggest continue to contribute to reference should be made in Policy CS2: climate change through Sustainable development. greenhouse gas emissions from development and increased traffic flows. These effects will be minimised to some extent through the promotion of sustainable transport modes and design measures. 15 To reduce vulnerability to Reg/Nat MT- Perm High 0 +/- +/- +/- New development will See comment above for SA Objective 14. climatic events LT increase amount of impermeable surfaces and may increase flood risk.

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16 To conserve and enhance Local MT- Perm Med 0 - - - Expansion in and around Effective implementation of CS Policy 2 biodiversity and LT Bury St.Edmunds is likely should ensure that any new development geodiversity to be on greenfield sites incorporates measures to protect and resulting in negative enhance biodiversity, wildlife and effects. geodiversity therefore offsetting these Some of the sites are negative effects to a certain degree. located in proximity to The expansion of Bury St Edmunds will national and local be subject to a detailed planning designations. Their application and EIA, which could mitigate development may negative effects and provide potentially affect these opportunities for habitat enhancement. sites. See assessment of Potential effects identified in the detailed strategic sites for specific assessment for the strategic sites need effects on local to be carefully addressed through biodiversity. appropriate mitigation measures.

17 To conserve and where Local MT- Perm Med ------Bury St.Edmunds is a See assessment of CS4 as effective appropriate enhance LT historic market town with implementation of this policy aimed to areas of historical and the medieval core of the create high quality developments may archaeological town being of exceptional offset these negative effects. Cross- importance value. This policy aims to referencing is recommended. ensure development does Potential effects against this objective not have a detrimental identified in the detailed assessment for impact on the unique the strategic sites need to be carefully fabric. New development addressed through appropriate mitigation may impact on the settings measures. of historical assets or affect unknown archaeological remains. 18 To conserve and enhance Local MT- Perm Med - - - - Greenfield development See assessment of CS4 as effective the quality and local LT may have negative effects implementation of this policy aimed to distinctiveness of in the local landscape. create high quality developments may landscapes and offset these negative effects. Cross- townscapes referencing is recommended.

19 To achieve sustainable Sub- MT- Perm High 0 ++ ++ ++ The strategic expansion of An area action plan for Bury St.Edmunds levels of prosperity and Reg LT Bury St.Edmunds should is proposed. Also see assessment of economic growth contribute to economic strategic sites. throughout the plan area growth for the Borough.

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20 To revitalise town centres Local MT- Perm High 0 ++ ++ ++ The growth of Bury An area action plan for Bury St.Edmunds LT St.Edmunds will have is proposed. Also see assessment of significant positive strategic sites. effects on the vitality and viability of the town centre through increased demand for local facilities and the provision of more facilities as a result of the increased demand. 21 To encourage efficient Sub- MT- Perm High 0 ++ ++ ++ Bury St.Edmunds is a key An area action plan for Bury St.Edmunds patterns of movement in Reg LT centre for development is proposed. Also see assessment of support of economic and change and due to its strategic sites. growth strategic location between the Cambridge Growth Area and the Haven Gateway growth point will have positive significant effects. 22 To encourage and Sub- MT- Perm High 0 ++ ++ ++ Strategic growth of Bury An area action plan for Bury St.Edmunds accommodate both Reg LT St.Edmunds is likely to is proposed. Also see assessment of indigenous and inward result in attracting inward strategic sites. investment investment.

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Table D.13 - Policy CS13:Haverhill Strategic Growth Policy CS13:Haverhill Strategic Growth

Land on the north-eastern edge of Haverhill will accommodate the future long term strategic growth for the town and will provide; • At least 2,200 homes • Improved connections to the existing built up area with a network of foot and cycle links to the town centre and employment areas • Protection so that the ridge and the visual boundary with Kedington is not breached • Protection for the Scheduled Ancient Monument at Wilsey Farm • New strategic public open space and recreation facilities • Education, social and recreational facilities • Local employment facilities • Opportunities for renewable energy generation and efficient use of resources • An opportunity to explore the potential for a North-eastern relief road

Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health of Local LT Perm Med 0 0 + + Positive but not significant None identified. the population overall and indirect effects on reduce health inequalities improving health identified as provision of recreational areas facilities in the expansion of Haverhill may provide increased opportunity for passive recreation 2 To maintain and improve Local LT Perm Med + + ++ ++ The expansion on the None identified. levels of education and north-eastern edge of skills in the population Haverhill will provide overall education facilities as part of the provision of 2,200 homes which will have positive significant effects on improving education opportunities and hence skills over the long term. 3 To reduce crime and anti- - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social activity

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4 To reduce poverty and - Local LT Perm Low + + + + The policy should benefit None identified. social exclusion the objective by providing new housing, including a proportion of affordable housing, and new facilities and improving accessibility to the existing facilities. 5 To improve access to key Local LT Perm Med 0 0 ++ + The potential north-eastern A master plan for Haverhill extension is services for all sectors of relief road could improve likely to be prepared in accordance with the population access for the population CS4 which will assess potential transport of Haverhill. Additional improvements for the area which would education, social and confirm these positive effects. recreational facilities within an already accessible area and improved local connections will have positive effects in terms of improved accessibility. 6 To offer everybody the Local LT Perm High + + + + The policy refers to the Recommend reference to level opportunity for rewarding provision of local employment provision if relevant for the and satisfying employment facilities which strategic growth of Haverhill. employment should result in positive effects. 7 To meet the housing Local LT Perm High ++ ++ ++ ++ The provision of 2,200 Effective implementation of CS6 should requirements of the whole homes will contribute to ensure a proportion of affordable housing community meeting the medium and in the expansion of Haverhill. long term housing requirements of the borough. 8 To improve the quality of Local MT- Perm Low + ++ + ++ The provision of Positive effects would be maximised - LT where people live and to improvements in open particularly through the effective encourage community space provision and implementation of CS3 in improving participation recreation facilities may public realm. have indirect positive effects on improving the quality of where people live.

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9 To improve water and air Sub- LT Perm Med 0 0 -- - The development of All proposals for growth in Haverhill quality Reg housing will give rise to should be in accordance with CS2. increases in population, Recommend referring to this in the policy which is likely in turn to wording to strength the protection of the increase traffic movement natural and built environment through and generate additional this policy. In accordance with CS4 a building and transport master plan for the extension of Haverhill related emissions, will be prepared together with transport contributing to localised and environmental assessments. degradation in air quality and added pressure on water quality. 10 To conserve soil Local MT- Perm Med 0 0 -- - Greenfield expansion will Effective implementation of CS Policy 2 resources and quality LT have negative effects on should ensure that efficient use of land . this objective. No indication of housing densities is provided.

11 To use water and mineral Local LT Perm Low 0 - - - The development of more Effective implementation of CS Policy 2 resources efficiently, and housing will give rise to should ensure that any new development re-use and recycle where increases in population incorporates measures to make efficient possible resulting in pressure on use of water however, no reference to re- water resources. These use and recycle of minerals and waste effects will be minimised to resources. See assessment of CS2. some extent through high quality building design. 12 To reduce waste Local LT Perm Med 0 - - - More housing is likely to See assessment of CS2. Cross- result in additional waste. referencing to Policy CS2 is These effects are likely to recommended. be minimised, as the nature of new development (i.e. urban extensions) should make implementation of recycling schemes viable. 13 To reduce the effects of Local LT Perm Med 0 0 +/- +/- Although the sequential As above. traffic on the environment approach should help reduce the need to travel, traffic volumes are likely to increase, as housing is built over the plan period. This will result in negative effects on the environment, the significance increases in the long term due to the cumulative effect.

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14 To reduce contributions to Reg/Nat LT Perm High 0 0 -- - The expansion of Haverhill No specific reference to climate change climate change would contribute to climate in the Core Strategy policies. Suggest change through reference should be made in Policy CS2: greenhouse gas emissions Sustainable development. from development and increased traffic flows. 15 To reduce vulnerability to Reg/Nat LT Perm High + 0 - +/- The north eastern edge of See comment above for SA Objective 14. climatic events Haverhill is not located within the floodplain however development will increase amount of impermeable surfaces and may increase flood risk. 16 To conserve and enhance Local LT Perm Med 0 0 -- - Expansion around The expansion of Haverhill will be subject biodiversity and Haverhill is likely to be on to a detailed planning application and geodiversity greenfield sites resulting in EIA which could mitigate negative effects negative effects. No and provide opportunities for habitat reference is made in the enhancement. policy to protect important Potential effects identified in the detailed habitats and species which assessment for the strategic sites need may have colonised the to be carefully addressed through greenfield site. appropriate mitigation measures. Some of the sites are located in proximity to national and local designations. Their development may potentially affect these sites. See assessment of strategic sites for specific effects on local biodiversity. 17 To conserve and where Local LT Perm Med 0 0 + + The policy specifically None identified. appropriate enhance refers to protecting the areas of historical and SAM at Wilsey Farm and archaeological ensuring that the ridge and importance the visual boundary with Kedington are not breached resulting in positive but not significant effects.

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18 To conserve and enhance Local LT Perm Med 0 0 ++ + The policy specifically None identified. the quality and local refers to protecting the distinctiveness of SAM at Wilsey Farm and landscapes and ensuring that the ridge and townscapes the visual boundary with Kedington are not breached resulting in positive significant effects. 19 To achieve sustainable Local LT Perm Med 0 0 ++ + The strategic expansion of None identified. levels of prosperity and Haverhill should contribute economic growth to economic growth for the throughout the plan area Borough.

20 To revitalise town centres Local LT Perm High 0 0 ++ + The growth of Haverhill None identified. will have significant positive effects on the vitality and viability of Haverhill town centre through increased demand for local facilities and the provision of more facilities as a result of the increased demand. 21 To encourage efficient - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. patterns of movement in support of economic growth

22 To encourage and Local LT Perm Med 0 0 ++ + Strategic growth of None identified. accommodate both Haverhill is likely to result indigenous and inward in attracting inward investment investment.

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Table D.14 - Policy CS14: Phasing Policy CS14: Phasing

In accordance with the spatial strategy, the Council will promote the re-use of previously developed land within housing settlement boundaries ahead of releasing greenfield sites for new neighbourhoods. The need to release land for new neighbourhoods will be assessed against the release of potential release of sites within the existing urban areas of the towns concerned. Matters to be considered in making such an assessment will include:

Effects Assessment SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of the population overall and reduce health inequalities 2 To maintain and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. improve levels of education and skills in the population overall 3 To reduce crime and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. anti-social activity 4 To reduce poverty and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social exclusion 5 To improve access to Local MT- Perm Med + ++ ++ ++ A phased programme for housing in None identified. key services for all LT Bury St.Edmunds is likely to ensure the sectors of the delivery of sustainable communities population ensuring that infrastructure (in combination with CS15) is in place to reduce the burden on existing facilities which is likely to occur with the pressure of new housing development. Positive effects are likely to be permanent and increase over the plan period. 6 To offer everybody the - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. opportunity for rewarding and satisfying employment

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7 To meet the housing Sub- MT- Perm Med + ++ ++ ++ A phased programme for housing is None identified. requirements of the Reg LT likely to meet the short, medium and whole community long term requirements for housing in the borough to meet the regional housing targets resulting in positive permanent effects. 8 To improve the quality - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of where people live and to encourage community participation 9 To improve water and Sub- MT- Perm Med ------The policy sets out a sequential See assessment of Policy CS1. air quality Reg LT approach to the siting of development, prioritising PDL within housing settlement boundaries ahead of releasing greenfield sites for new neighbourhoods. However, any new development is likely to have negative effects on this objective. 10 To conserve soil Local MT- Perm Med 0 - -- - As above. See assessment of Policy CS1. resources and quality LT 11 To use water and Local MT- Perm Med ------Any new development is likely to have See assessment of Policy CS1. mineral resources LT negative effects on this objective. efficiently, and re-use and recycle where possible 12 To reduce waste Local MT- Perm Med ------Any new development is likely to have See assessment of Policy CS1. LT negative effects on this objective. 13 To reduce the effects of Local MT- Perm Med 0 - -- - As above. See assessment of Policies CS1 and traffic on the LT CS8. environment 14 To reduce contributions Reg/Nat MT- Perm High ------Any new development is likely to have See assessment of Policy CS1. to climate change LT negative effects on this objective. 15 To reduce vulnerability Reg/Nat MT- Perm High - - - - Any new development is likely to have See assessment of Policy CS1. to climatic events LT negative effects on this objective. 16 To conserve and Local MT- Perm Med 0 - -- - The policy sets out a sequential See assessment of Policy CS1. enhance biodiversity LT approach to the siting of development, and geodiversity prioritising PDL within housing settlement boundaries ahead of releasing greenfield sites for new neighbourhoods. In the long term therefore negative effects are predicted.

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17 To conserve and where Local ST- Perm Med +/- +/- - - The policy sets out a sequential See assessment of Policy CS1. appropriate enhance LT approach to the siting of development, areas of historical and prioritising PDL within housing archaeological settlement boundaries ahead of importance releasing greenfield sites for new neighbourhoods. Focusing development in existing settlements may have negative effects on historic buildings. Some housing is likely to be on greenfield sites in the medium to longer term which will have negative effects on this objective. Increased traffic levels can also have negative effects on the setting of historic buildings. 18 To conserve and Local MT- Perm Med +/- +/- - - The policy sets out a sequential See assessment of CS1. Recommend - LT enhance the quality and approach to the siting of development, that this policy cross refers to Policy local distinctiveness of prioritising PDL within housing CS2. landscapes and settlement boundaries ahead of townscapes releasing greenfield sites for new neighbourhoods. In the long term therefore negative effects are predicted as greenfield land is released to meet housing targets. 19 To achieve sustainable Local ST- Perm Med + + + + The sequential approach to the siting of See assessment of CS1. levels of prosperity and LT development could provide a local economic growth supply of workers required by new and throughout the plan existing businesses. area 20 To revitalise town Local ST- Perm High ++ ++ ++ ++ The towns of Bury St Edmunds and See assessment of CS1. centres LT Haverhill will be the main focus for the location of new development, supported by appropriate levels of development in Key Service Centres, Local Service Centres and Infill Villages. This approach should ensure positive significant permanent effects in revitalising existing centres. 21 To encourage efficient Local ST- Perm Med + + + + Sequential approach to siting new See assessment of CS8 as this policy patterns of movement in LT development may help reduce the need states that all development proposals support of economic to travel, particularly by private car. will be required to follow the growth sustainable transport hierarchy resulting in permanent positive cumulative effects if these two policies are effectively implemented.

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22 To encourage and - Local LT Perm Low 0 0 0 0 No obvious effects. accommodate both indigenous and inward investment

Table D.15 - Policy CS15: Infrastructure Policy CS15: Infrastructure

All new proposals for development will be required to demonstrate that the necessary on and off-site infrastructure capacity required to support the development and to mitigate the impact of it on existing community facilitie exists or will exist prior to that development being occupied.

In circumstances where the provision or improvement of infrastructure or other works or facilities is necessary, both within and beyond the borough boundary, to address community or environmental needs associated with development or to mitigate the impact of development on the environment or existing communities, standard charges and/or standard formulae will be imposed for the payment of financial contributions towards such infrastructure, works or facilities to ensure that all such development makes an appropriate and reasonable contribution to the costs of provision.

The provision of infrastructure will be linked directly to phasing of development on land throughout the borough to ensure that there is no detrimental impact on existing infrastructure, the environment or residential amenity. will be coordinated and delivered in partnership with other authorities and agencies such as the local highways authority, local education authority, the environment agency, primary car trusts, utility companies and other pri and public sector partners.

Effects Assessment

SA Objective Mag Scale Dur T/P Cert ST MT LT Sm Summary of Effects Recommendation/Mitigation 1 To improve the health of Local MT- Temp Low + + + + Provision of facilities and services Should this policy be titled 'infrastructure capacity a the population overall LT such as doctors' surgeries or tariffs'? The scale and effects of this policy is likely and reduce health recreational facilities may contribute be monitored through the development control proc inequalities indirectly to improving health. However, effects are uncertain and will depend on identified need. 2 To maintain and Local MT- Temp Low + + + + This policy offers the opportunity to The scale and effects of this policy is likely to be improve levels of LT ensure financial contributions are monitored through the development control process education and skills in sought which could be use to fund the population overall educational provision however, will depend on identified need and scale of development. Minor positive effects are likely in the medium and long term but not significant. 3 To reduce crime and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. anti-social activity

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4 To reduce poverty and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. social exclusion 5 To improve access to Local MT- Temp Low + + + + This policy offers the opportunity to The scale and effects of this policy is likely to be key services for all LT ensure financial contributions are monitored through the development control process sectors of the population sought which could be use to fund improvements in accessibility however, will depend on identified need and scale of development. Minor positive effects are likely in the medium and long term. 6 To offer everybody the - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. opportunity for rewarding and satisfying employment 7 To meet the housing - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. requirements of the whole community 8 To improve the quality - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. of where people live and to encourage community participation 9 To improve water and Local ST- Perm Med +/- +/- +/- +/- Provision of facilities through Effective implementation of measures in Policy CS2 air quality LT infrastructure provision may include should ensure that negative effects are minimised. water quality and capacity CEMP for any new development should also ensure improvements however, this is negative effects are minimised. The scale and effec required as part of CS2 and intrinsic of this policy is likely to be monitored through the to any planning permission therefore development control process. effects may be positive but uncertain. Construction and operation of any development may cause pollution of watercourses and negative effects on local air quality. 10 To conserve soil - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. resources and quality 11 To use water and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. mineral resources efficiently, and re-use and recycle where possible 12 To reduce waste - Local LT Perm Low 0 0 0 0 No obvious effects. None identified.

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13 To reduce the effects of Local MT- Temp Low + + + + Provision of infrastructure through Cumulative positive effects likely if effective traffic on the LT developer contributions may implementation of Policy CS8. The scale and effects environment generate sufficient funding to this policy is likely to be monitored through the enhance sustainable transport development control process. options in combination with CS8. However, positive effects will depend on the nature of obligations sought and therefore effects are uncertain. 14 To reduce contributions - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. to climate change 15 To reduce vulnerability - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. to climatic events 16 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance biodiversity and geodiversity 17 To conserve and where - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. appropriate enhance areas of historical and archaeological importance 18 To conserve and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. enhance the quality and local distinctiveness of landscapes and townscapes

19 To achieve sustainable Local MT- Temp Low + ++ ++ ++ Infrastructure provision through None identified. levels of prosperity and LT developer contributions has the economic growth potential for significant positive throughout the plan area effects through the provision of a range of community facilities and infrastructure improvements to support economic growth. Effects are likely to be permanent and long term. 20 To revitalise town Local MT- Temp Low + ++ ++ ++ This policy aims to protect the The scale and effects of this policy is likely to be centres LT vitality and viability of existing monitored through the development control process facilities but also promotes the provision of enhanced infrastructure where a need has been identified. This policy should contribute to revitalising town centres based on need.

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21 To encourage efficient - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. patterns of movement in support of economic growth

22 To encourage and - Local LT Perm Low 0 0 0 0 No obvious effects. None identified. accommodate both indigenous and inward investment

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Appendix E - Consultation Comments on Scoping Report

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Table E.1 - Summary of Comments Made by Consultees on Scoping Report and how they have been incorporated into the SA Process

Date Consultees Report Summary of Consultees Comments (includes proposed changes) Response to the Section Comment 14.11.06 Davina Howes, General Changes to text with regard to 'easy reading', grammar and spelling. Appropriate amendments SEBC Strategic Several amendments throughout text, including replacing unnecessary will be made. Performance capital letters, writing SEBC in full, replacing '&' with 'and', minor spelling and factual mistakes, grammatical errors and removal / replacement of words in order to improve readability. 14.11.06 Davina Howes, Chapter 1, Include further detail. Add 'e.g. population change' to end of sentence These are just summary SEBC Strategic Para 1.12, 'assess the broad Env., social…' statements and therefore Performance point 2 do not require further detail

14.11.06 Davina Howes, Chapter 2, Need to include more relevant documents. Under 'local authorities Documents were included SEBC Strategic Table 3 corporate plans and strategies' include SEBC Equality Framework (2005) in the review of relevant Performance and SEBC Disability Equality Scheme 06-09 (Oct 2006). Plans and Programmes. 14.11.06 Davina Howes, Chapter 2, SEBC health and wellbeing strategy 2004 repeated twice. Delete duplicate. SEBC Strategic Table 3 Performance

14.11.06 Davina Howes, Chapter 2, Far more community cohesion documents exist that could be included Scoping Report is SEBC Strategic Table 3 under 'social inclusion'. considered to have Performance included key documents that have a spatial impact. 14.11.06 Davina Howes, Chapter 3, Gender, faith and disability are not addressed in this chapter. This data has been added SEBC Strategic General to the baseline data table. Performance 14.11.06 Davina Howes, Chapter 3, 'white' is too broad. Should clearly identify 'white British' and an ever Comment noted and SEBC Strategic Table 12 increasing 'white other'. addressed in the relevant Performance baseline table.

14.11.06 Davina Howes, Chapter 3, No mention of migrant workers. Might be worth adding a sentence for No data were found to be SEBC Strategic General migrant workers and their impact on the economy. NI registration figures available only for the Performance are available. Government office

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regions; not at the borough level. 14.11.06 Davina Howes, Chapter 3, 'How good or bad' is a difficult criterion to use. Consider changing. Comment noted. SEBC Strategic Para 3.1 Performance

14.11.06 Davina Howes, Chapter 3, No mention of access to info for disabled, those speaking a different Comment noted and the SEBC Strategic Para 3.4 language, etc. May want to add a paragraph covering other types of access relevant additional Performance to services, e.g. physical access for disabled, alternative formats (?), information has been language. included in the baseline section.

14.11.06 Davina Howes, Chapter 3, Add 'and composting' behind '…terms of recycling'. Appears twice in Paragraph 3.67 has been SEBC Strategic Para 3.67 paragraph. amended. Performance

14.11.06 Davina Howes, Chapter 4, Add some equality indicators, e.g. - BVPI Indicators on equality standards Disagree. While the LDF SEBC Strategic Table 25 and duty to promote race equality should promote equality in Performance its policies, the BVPI indicators relate to the Council as an organisation and not the land use planning system. However, ethnicity data is now included in the baseline data tables.

15.11.06 Richard Chapter 2, The Updating and Screening Assessment of Air Quality in St Edmundsbury Updating and Screening Whitehead, Table 3 is no longer a draft. An annual update of the local air quality will be carried Assessment (2006) and SEBC Env. out in 2007 and 2008 and a further Updating and Screening in 2009. Progress Report (2007) Health have been included in the review of relevant plans and programmes. 15.11.06 Richard Chapter 3, Indicator 25 only refers to complaints made between neighbours. It omits Indicator has been Whitehead, Table 5 commercial noise complaints. With the likely increase in amended in the Final SEBC Env. industrial/commercial noise complaints as a result of economic Report to include Health growth/development, perhaps it would be appropriate to include commercial commercial noise

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noise complaints. complaints.

15.11.06 Richard Chapter 3, Incorrect figures. Indicator 25. Domestic complaints are actually Comment noted and Whitehead, Table 5 increasing. Indicator 25, table 5 should probably be in table 7. appropriate amendments SEBC Env. were made. Health

15.11.06 Richard App. 1, Figures in App. 1 differ greatly form our records. Figures in App. 1, pg 36, This data has been Whitehead, Indicator 25 should be changed: amended in the baseline SEBC Env. delete - 2002 - 563; 2003 - 426; 2004 - 486; 2005/6 - 403 data table. Health replace with - 2002/3 - 411; 2003/4 - 483; 2004/5 - 419; 2005/6 - 465

15.11.06 Richard Chapter 3, Indicator 47, number of unfit homes per 1,000 dwellings, is essentially The Final Report has been Whitehead, Table 8 redundant due to recent changes in legislation and a new assessment amended to include SEBC Env. system. An alternative indicator could be the percentage of vulnerable relevant indicators related Health persons living in non-decent homes. to the new Housing Health and Safety Rating System. Comment addressed through the inclusion of the suggested indicator under Objective 7 of the SA Framework.

15.11.06 Richard Chapter 3, Replace '□greenfield' with 'greenfield' Comment noted and Whitehead, Para 3.65 addressed. SEBC Env. Health

20.11.06 Nick Vass- General It appears…that the SR has been produced for a number of LDDs. If so - The Scoping Report sets Bowen, Go SR needs to provide adequate information on the scope and level of detail the baseline indicators East in each LDD. This might be achieved by producing two SRs or somehow which will guide the splitting the content to relate to all LDD matters and those that relate to detailed assessment of individual LDDs. The first would be a general section, setting out common individual LDD's. elements. The second would outline additional/specific details for individual LDDs. 24.11.06 Jane Chance, App. 1, Discrepancy in figures. May want to use Department for Education stats. The data is provided by SEBC Indicator the Suffolk Observatory Community 17-20 which uses Department for

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Development Education data as a source. 24.11.06 Jane Chance, Chapter 2, The Western Suffolk Community Strategy has been listed as a draft but has Suffolk’s Community SEBC Table 3 now been approved and is final. Strategy (Transforming Community Suffolk 2008-2028) has Development been added to the reviews of the relevant plans and programmes.

24.11.06 Jane Chance, App. 1, Issues relating to open space and volunteering are covered in the Local This has been researched SEBC Indicators Area Agreement. SCC partnership team should be able provide some data. further but not provided Community 12-4 and 54 Contact SCC for data? data. Work will continue to Development try and source meaningful data relating to these indicators.

24.11.06 Jane Chance, Chapter 3, There are a number of active community/resident groups, some with Comment noted and SEBC Para 3.5 funding and officer support. appropriate amendments Community were made. Development

24.11.06 Jane Chance, Chapter 4, Whilst we agree that cancer and heart disease are priorities…obesity, Comment noted. The SA SEBC Para 4.1 exercise and healthy eating are of key significance. Perhaps these are Framework was amended Community worth highlighting in their own right. to reflect the levels of Development obesity in the population. A new indicator on sport and active recreation has been added to SA Objective 1. Healthy eating is deemed as not appropriate indicator for the LDF.

27.11.06 Susan Heinrich, General Concerned that scoping reports don't address sustainable economic It is considered that the EEDA development and regeneration sufficiently. Where appropriate, consider: relevant and appropriate provision for businesses (particularly based in science and technology, indicators have been research and innovation) including the supply of high quality business included in the Scoping premises in sustainable locations; Report and the policies of

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improving the region’s skills base and human capital (and especially to the RES and RSS will address skills gaps and shortages); provide the context for the tackling deprivation and social exclusion, equality and diversity (giving development of policies communities improved opportunities to participate fully in the regional and proposals in the LDF. economy); improving provision of port, airport and transport infrastructure so as to enable corridors of economic activity, and deliver growth and sustainable communities; promoting sustainable development, urban renaissance and rural vitality, including the supply of high quality and affordable housing/ residential environments, balanced with provision for employment; managing growth and development sensitively and effectively; complementing and enhancing the position of London as a world city; and protecting and enhancing the region’s landscapes and environmental assets.

27.11.06 Susan Heinrich, General Concerned that scoping reports don't address sustainable economic It is considered that the EEDA development and regeneration sufficiently. Consider the Sub-regional relevant and appropriate policies contained in the RES for the Thetford area (see pg 99 of RES indicators have been report): included in the Scoping building on Thetford’s role as a key service and economic centre on the Report and the policies of A11 corridor the RES and RSS will provide the context for the facilitating regeneration of the town centre, while protecting its historic core development of policies and natural setting and proposals in the LDF. developing the economic potential of the rural hinterland through workspace creation and re-use developing links to foster the emerging cluster of motorsport/auto engineering industries focused on the A11 corridor.

05.12.06 Donna Wagers App. 1, General needs housing completions do not match our records. Affordable housing figures Indicator 42 Delete: 2004/5 - 28; 2003/4 - 27; 2002/3 - 62; 2001/2 - 49 were obtained from the Replace with : 2004/5 - 20; 2003/4 - 19; 2002/3 - 75; 2001/2 - 40 Annual Monitoring Review. This data has been changed in the baseline

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tables.

05.12.06 Donna Wagers App. 1 Under ‘issues identified and action required' the comment is that there is a Noted. Indicator 43 low level of completions for special needs housing in the Borough. Whilst comment is true, it’s important to understand that Council is guided by the Housing Corporation who set sub-regional themes that we work towards. Sub-regional funding for special need/supported housing has been very low but this is determined by the Housing Corporation. A further factor is the Supporting People Suffolk body who manage revenue funding for supported housing, and they have not had sufficient revenue funds to support schemes. 07.12.06 Peter Gudde, Chapter 1, Why is the list of SDPs restricted to two – affordable housing and section The Council's agreed SEBC Env. Para 1.6 106 developer contributions? Issues such as sustainable construction, Local Development Health climate change, biodiversity and water seem equally of value. If the two Scheme lists the proposed proposed SPDs are to form part of a family which will be developed with SPD's. The most recent time then an explanation of the process of topic selection and publication LDS, March 2007, still has should be provided. not been approved. It is awaiting confirmation from GO-East. It no longer proposes any SPD to be prepared in the period 2007 - 2010. 07.12.06 Peter Gudde, App. 1, The BC no longer owns social housing. This indicator should be withdrawn. Agree. This Indicator was SEBC Env. Indicator 83 deleted. Health

07.12.06 Peter Gudde, Chapter 3, The selection of over 140 indicators will allow detailed analysis of specific The Scoping Report and SEBC Env. General components but may make measuring overall performance of the LDF SA has been prepared to Health difficult. It will not be possible to make an objective comparison between an agreed format that is Env., social and economic sustainability. A separate but complementary adopted across Suffolk. It way of measuring overall success could be provided by ecological foot is not appropriate at this printing.. (as) it allows unrelated areas of policy to be compared in an time to incorporate the objective manner. The currency of measurement is the global hectare, the suggested methodology. equivalent amount of land required to sustain the level of consumption for the area under consideration. ... Associated with this method is the measurement of carbon and material flow ands arising from production and consumption behaviours caused but the policy decision or activity being

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assessed. ... Work to measure carbon emission in Suffolk ... is underway with the intention of developing a carbon footprint of Suffolk and LAs. This work along with the SEI methodology could form the basis for measuring the overall performance of the LDF and making relative comparisons of policy decisions. 07.12.06 Peter Gudde, Chapter 3, This section disregards the critical importance of water in the future Both issues of strained SEBC Env. Para 3.61 development of the Eastern Region. Rainfall in the East of England is less water resources and the Health than 65% of that for England and Wales and there is increasing competition need to adapt to the for scarce water resources. Availability of water resources is likely to expected climate changes restrict the long term economic and social growth of the Eastern region with have been included in the a changing climate. There is no mention of the need to adapt communities Issues table. and the Borough’s infrastructure (e.g. the road and rail networks) to severe weather events including drought, heat and fluvial/groundwater flooding likely with a changing climate.

07.12.06 Peter Gudde, Chapter 3, This section deals only with the quality of under-developed urban land. This An over-arching objective SEBC Env. Para 3.64 ignores the state of land under agricultural productivity and soil resources in of the SA is to maintain Health semi-natural environments. There is no consideration for example of soil and enhance soil quality. types, their intrinsic characteristics or the impact of human activity on However, this can only be quality, organic matter content, moisture balance or erosion rates. Soils are achieved within the a finite resource vital to economic activity in terms of agricultural production, parameters of the planning to landscape quality and biodiversity as well as having value in themselves, system. for example the soils of the Brecks.

07.12.06 Peter Gudde, Chapter 3, Municipal waste accounts for only 14% of total waste arising in the East of This chapter only notes SEBC Env. Para 3.66 England. This section deals only with municipal waste neglecting the other the current situation in Health waste streams, particularly from the commercial and industrial sectors. respect of the key Redevelopment generates wastes which contribute both to the cost of the indicators. It cannot set build and also to the degradation of the local environment. This section out objectives for future needs refocusing to reflect the need to develop a more sustainable LDD's. approach to resource efficiency.

07.12.06 Peter Gudde, Chapter 3, The ability for the domestic and commercial sectors to implement micro- This chapter only notes SEBC Env. Para 3.67 renewable energy generation must not be overlooked. There also exists a the current situation in Health lack of skilled installers of such technologies. With the potential for demand respect of the key to increase significantly, driven by several factors including increasing indicators. It cannot set fossil-fuel energy prices, there is an opportunity for stimulating local out objectives for future employment in this service sector in addition to spin-offs for local LDD's.

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manufacture of the installations.

07.12.06 Peter Gudde, Chapter 3, The challenge lies in developing new renewable energy generating stations This chapter only notes SEBC Env. Para 3.8 with the support of the local community in which they are to be based. the current situation in Health respect of the key indicators. It cannot set out objectives for future LDD's. 07.12.06 Peter Gudde, Chapter 4, The following issues have been omitted and should be included: Comment noted and the SEBC Env. Para 4.1 water resources; outline issues have been Health included in the Issues adapting to changing climate including coping with heat waves, storm table. events and flooding; resource efficiency and waste 07.12.06 Peter Gudde, Chapter 5, Compatibility of sustainability appraisal objectives – see comment for Noted. The Compatibility SEBC Env. Para 5.6 Section 3, General above. Assessment has been Health reviewed in the Final SAR.

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Appendix F - Consultation Comments on Initial Sustainability Appraisal (Issues and Options Report)

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Table F.1 - Consultation comments on St Edmundsbury Core Strategy Issues and Options Initial SAR

Consultee Summary of Consultees Comments Response to the Comment Mrs Joanne Ince, Oustden Parish Council Q1. Do you agree with the proposal Yes Comment noted. indicators?

Q2. Are there any further indicators which Yes Comment noted but unable to take specific could be used to monitor the sustainability action pertaining to this comment without impacts of the plan more accurately? further information regarding the indicators that this consultee considers should be included.

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects Yes Comment noted but unable to take specific which have not been identified? action pertaining to this comment without further information regarding the adverse effects that this consultee considers should be included.

Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No Comment noted. to cause adverse impacts which have not been identified?

Mrs D Haycock, Coney Weston Parish Council Q1. Do you agree with the proposal Yes Comment noted. indicators? Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

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Consultee Summary of Consultees Comments Response to the Comment Q3. Do you agree with the assessment of the No comment spatial objectives set out in Appendix A? Q4. Are there any possible adverse effects Re-cycling points e.g. bottle banks can be Comment noted. However, given the high, which have not been identified? very unpopular with nearby residents. strategic level of assessment of the compatibility of the Core Strategy objectives with the SA objectives, potential conflicts between recycling points and local residents cannot be reflected within the compatibility assessment.

Q5. Do you agree with the initial assessment No comment of spatial options consultation questions set out in Appendix B? Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified?

Mr Gordon Mussett, Haverhill Town Council Q1. Do you agree with the proposal Yes Comment noted. indicators? Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects Housing density levels can result in Addressed in the revised compatibility which have not been identified? development which contributes to poor health assessment. factors. Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

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Consultee Summary of Consultees Comments Response to the Comment Q6. Do any of the options have the potential Not known Comment noted. to cause adverse impacts which have not been identified?

Ms N Bertoya, Stoke-by-Clare Parish Council Q1. Do you agree with the proposal No - Indicator of water quality is insufficient SA Framework has been amended to indicators? here include two indicators on water quality under SA Objective 9.

Q2. Are there any further indicators which Criteria used by EA and Defra to classify the Comment noted. The SA Framework now could be used to monitor the sustainability status of rivers in line with the ‘Directive includes an indicator on water quality in impacts of the plan more accurately? 2000/60/EC of the European Parliament and rivers. of the Council establishing a framework for the Community action in the filed of water policy. (EU Water Framework Directive ) should be used. Close contact should be maintained by the Council with the relevant basin management authorities to participate in the planning processes Q3. Do you agree with the assessment of the No comment spatial objectives set out in Appendix A? Q4. Are there any possible adverse effects No comment which have not been identified?

Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified? Jayne Brock, Great Wratting Parish Council Q1. Do you agree with the proposal No - Not at all sure at this stage. Comment noted but it cannot be addressed

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Consultee Summary of Consultees Comments Response to the Comment indicators? because of the lack of specific recommendations.

Q2. Are there any further indicators which Not sure, other than balance developments Comment noted. Balancing development could be used to monitor the sustainability with the surroundings and services. with the surroundings and services formed impacts of the plan more accurately? part of considerations in the development of the Core strategy Policies and their assessment.

Q3. Do you agree with the assessment of the No - not sure Comment noted but unable to take specific spatial objectives set out in Appendix A? action pertaining to this comment without further information regarding the inadequacies that this consultee considers are in the assessment.

Q4. Are there any possible adverse effects Pollution Issues of pollution are addressed through which have not been identified? SA objectives 1 (population health), 9 (water and air quality), 13 (effects of traffic on the environment) and 14 (contributions to climate change), and are therefore integrated within the SA framework. Q5. Do you agree with the initial assessment Yes - In part Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential Not sure Comment noted. to cause adverse impacts which have not been identified? R Mills, A V Mills & Sons Q1. Do you agree with the proposal Yes Comment noted. indicators?

Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

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Consultee Summary of Consultees Comments Response to the Comment Q3. Do you agree with the assessment of the Yes - broadly yes Comment noted. spatial objectives set out in Appendix A? Q4. Are there any possible adverse effects Risk to small communities by not permitting Comment noted. The Core Strategy does which have not been identified? controlled growth not seek to prevent controlled growth and as such this adverse effect is not considered likely to occur.

Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B? Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified?

Mrs Linda Harley, Gt Barton Parish Council Q1. Do you agree with the proposal Yes Comment noted. indicators? Q2. Are there any further indicators which We don’t believe so Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects Not assessed Comment noted but unable to take specific which have not been identified? action pertaining to this comment without further information regarding the inadequacies that this consultee considers in the assessment.

Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

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Consultee Summary of Consultees Comments Response to the Comment Q6. Do any of the options have the potential Not assessed Comment noted but unable to take specific to cause adverse impacts which have not action pertaining to this comment without been identified? further information regarding the inadequacies that this consultee considers are in the assessment. Cllr Christopher Spicer, St Edmundsbury Borough Council

Q1. Do you agree with the proposal Yes Comment noted. indicators?

Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately? Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A? Q4. Are there any possible adverse effects No Comment noted. which have not been identified? Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential Option 4 - the growth of Bury St Edmunds Comment noted. Preserving settlements’ to cause adverse impacts which have not must not allow the absorption of surrounding identity and not allowing coalescence of been identified? villages - Great Barton, Fornhams, Westley, the towns with nearby villages was a Roughhm and Thurston. material consideration in developing the Core Strategy Polices and their assessment, as well as in the detailed assessment of strategic sites.

The Risby Trust, Brown and Scarlett Q1. Do you agree with the proposal No comment indicators?

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Consultee Summary of Consultees Comments Response to the Comment Q2. Are there any further indicators which No comment could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the No comment spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects These comments should be read in relation to Comment noted and appreciated. Positive which have not been identified? question 10, 1 1, 12 and question 4 in the as well negative effects of new Sustainability Appraisal. In common with development in rural areas have been some other Agents in the town we are considered as part of the strategic options concerned that there is an over emphasis on assessment. The need for certain level of housing in what is perceived to be the development in the rural area is recognised sustainable major centres such as Bury St and is recommended to be a consideration Edmunds and Haverhill. This can lead to a in the development of the preferred option. virtual stagnation of the vast majority of the The Core Strategy Policy 1 (Spatial network of villages which form the backbone Strategy) directs a proportion of new of rural Suffolk life. The Local Development development to the rural areas. Framework professes to serve the whole of the community but it’s over reliance on development in the major centres across the projected Plan period will leave our existing villages as little more than museum pieces. Option 4, the option which we are supporting in our submission would allow for development in keyservice centres and rural services centres. This will clearly allow for those existing village facilities to be maintained. We read daily of local pubs, shops, schools and post offices under threat and to fail to locate development in the village setting will lead to the inevitable demise of what are universally acknowledged as being vital facilities and ones which provide and secure the sustainable nature of many villages across the county.

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Consultee Summary of Consultees Comments Response to the Comment If we continue to limit village development to a very few centres, allowing only exception sites being allowed for social housing in the rest, we will create a polarising of the housing market within these settlements where either the very rich or the very poor can live but with nothing for the ordinary family in between. We believe that the existing village network, including those beyond the existing rural service centre status should continue to have an allocation for either infill, where possible, or minor expansion and these could be allocated with design briefs to ensure an appropriate mix and house size. Q5. Do you agree with the initial assessment No comment of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified? Mr Michael Surridge Q1. Do you agree with the proposal Yes Comment noted. indicators?

Q2. Are there any further indicators which No comment could be used to monitor the sustainability impacts of the plan more accurately? Q3. Do you agree with the assessment of the No comment spatial objectives set out in Appendix A? Q4. Are there any possible adverse effects No comment which have not been identified?

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Consultee Summary of Consultees Comments Response to the Comment Q5. Do you agree with the initial assessment No comment of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential to cause adverse impacts which have not been identified?

Mrs Susan Hindry, Bury St Edmunds Town Council Q1. Do you agree with the proposal Yes Comment noted. indicators?

Q2. Are there any further indicators which Constant reviews Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects No Comment noted. which have not been identified?

Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B? Q6. Do any of the options have the potential No Comment noted. to cause adverse impacts which have not been identified?

Mrs Barbara Surridge Q1. Do you agree with the proposal Yes Comment noted. indicators?

Q2. Are there any further indicators which The number of large trucks that are routed SA Framework includes an indicator on could be used to monitor the sustainability down unsuitable, narrow lanes (Presumably Traffic volumes in key locations. impacts of the plan more accurately? directed by Sat Nav)

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Consultee Summary of Consultees Comments Response to the Comment Q3. Do you agree with the assessment of the Yes - written descriptions more easy to Comment noted. spatial objectives set out in Appendix A? understand than face icons Q4. Are there any possible adverse effects Status quo of small hamlets without service Comment noted. which have not been identified? guaranteed in all five options. Yet implementation of any of the options could negate this statement this statement by just swallowing them up. Q5. Do you agree with the initial assessment Status quo of small hamlets without service Comment noted. of spatial options consultation questions set guaranteed in all five options. Yet out in Appendix B? implementation of any of the options could negate this statement this statement by just swallowing them up. Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified?

Mr John Pelling Q1. Do you agree with the proposal Yes Comment noted. indicators? Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects No Comment noted. which have not been identified?

Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

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Consultee Summary of Consultees Comments Response to the Comment Q6. Do any of the options have the potential No Comment noted. to cause adverse impacts which have not been identified?

Linda Bevan Q1. Do you agree with the proposal Yes Comment noted. indicators? Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects No Comment noted. which have not been identified?

Q5. Do you agree with the initial assessment Yes Comment noted of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No Comment noted to cause adverse impacts which have not been identified? BypassFarmPartnership, Bidwells Q1. Do you agree with the proposal Yes - Allocating land for new housing and Comment noted indicators? employment development at the most appropriate scale in the right location will help to achieve the council's objectives in tables 1(a) and 1(c) Q2. Are there any further indicators which No comment could be used to monitor the sustainability impacts of the plan more accurately?

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Consultee Summary of Consultees Comments Response to the Comment Q3. Do you agree with the assessment of the No - Assessing likely impact on people and Comment noted. However, a compatibility spatial objectives set out in Appendix A? environment can only be undertaken at the assessment of the Core Strategy local scale and in site specific terms. objectives with the SA framework is a Notwithstanding the statutory requirement that statutory requirement when undertaking an the council needs to undertake such an SA. exercise in a policy context.

Q4. Are there any possible adverse effects As per question 3. Comment noted. which have not been identified?

Q5. Do you agree with the initial assessment No comment of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified? S W Cross and Sons, Bidwells

Q1. Do you agree with the proposal Yes - allocating land for new housing and Comment noted. indicators? employment development at the most appropriate scale in the right location will help to achieve the Council's objectives in tables 1 (a) to 1(c) Q2. Are there any further indicators which No comment could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the No - assessing likely impact on people and Comment noted. However, a compatibility spatial objectives set out in Appendix A? environment can only be undertaken at the assessment of the Core Strategy local scale and in Site Specific terms. objectives with the SA framework is a Notwithstanding the statutory requirement that statutory requirement when undertaking an the Council needs to undertake such an SA. exercise in a policy context.

Q4. Are there any possible adverse effects Assessing likely impact on people and Comment noted. However, a compatibility

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Consultee Summary of Consultees Comments Response to the Comment which have not been identified? environment can only be undertaken at the assessment of the Core Strategy local scale and in Site Specific terms. objectives with the SA framework is a Notwithstanding the statutory requirement that statutory requirement when undertaking an the Council needs to undertake such an SA. exercise in a policy context.

Dr Simone Bullion, Suffolk Wildlife Trust Q1. Do you agree with the proposal Yes - with regard to biodiversity Comment noted. indicators? Q2. Are there any further indicators which No comment could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the No - there are too many crosses 'objective Assessment updated in the revised spatial objectives set out in Appendix A? does not apply'. This should be re-evaluated compatibility assessment. with a more realistic assessment. For example under biodiversity Objective 'A' is likely to be a negative effect, but 'B' should be a positive effect. D and E are probably neutral, but F is positive.

Q4. Are there any possible adverse effects No comment which have not been identified?

Q5. Do you agree with the initial assessment No comment of spatial options consultation questions set out in Appendix B?

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Consultee Summary of Consultees Comments Response to the Comment Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified?

Mrs C Wiseman, Withersfield Parish Council Q1. Do you agree with the proposal No comment indicators? Q2. Are there any further indicators which Not sure - other than balanced developments Comment noted. Balancing development could be used to monitor the sustainability with the surroundings and services. with the surroundings and services formed impacts of the plan more accurately? part of considerations in the development of the Core strategy Policies and their assessment. Q3. Do you agree with the assessment of the No comment spatial objectives set out in Appendix A? Q4. Are there any possible adverse effects Not sure Comment noted. which have not been identified? Q5. Do you agree with the initial assessment No comment of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified? Mr Roger Davison, Lacy Scott & Knight Q1. Do you agree with the proposal Yes Comment noted. indicators?

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Consultee Summary of Consultees Comments Response to the Comment spatial objectives set out in Appendix A? Q4. Are there any possible adverse effects Risk to small communities by not permitting Comment noted. The Core Strategy does which have not been identified? controlled growth. not seek to prevent controlled growth and as such this adverse effect is not considered likely to occur. Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential Not sure Comment noted. to cause adverse impacts which have not been identified?

Alan Robinson Q1. Do you agree with the proposal Yes Comment noted. indicators?

Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects No Comment noted. which have not been identified? Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No Comment noted. to cause adverse impacts which have not been identified?

Mrs Joan Garrett, Whepstead Parish Council

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Consultee Summary of Consultees Comments Response to the Comment Q1. Do you agree with the proposal Yes Comment noted. indicators? Q2. Are there any further indicators which No comment could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects No comment which have not been identified?

Q5. Do you agree with the initial assessment No comment of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified? Mr Keith Ringrose Q1. Do you agree with the proposal No - There are probably too many and I would Comment noted. However, the structure of indicators? suggest selecting about fifteen key indicators the SA Framework will be retained, as it and making the rest secondary indicators. follows the Suffolk SA Framework structure.

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Consultee Summary of Consultees Comments Response to the Comment of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified? Mr Nick Laughton, Ixworth and Ixworth Thorpe Parish Council

Q1. Do you agree with the proposal Yes Comment noted. indicators?

Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately? Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A? Q4. Are there any possible adverse effects No comment which have not been identified? Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified? Doctor Brian Keeble, Suffolk Primary Care Trust

Q1. Do you agree with the proposal Yes - The health indicator should include a Comment noted. SA Objective 1 has been indicators? commitment to reduce health inequalities as it amended to address this comment. is quite possible to improve overall health but see the health of the worst off decline.

Q2. Are there any further indicators which No comment could be used to monitor the sustainability

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Consultee Summary of Consultees Comments Response to the Comment impacts of the plan more accurately? Q3. Do you agree with the assessment of the No - I think you need to recognise the Assessment updated in the revised spatial objectives set out in Appendix A? potential on health and wellbeing of A, B, C, compatibility assessment. E, F, G, and H as well as D and I.

Q4. Are there any possible adverse effects Yes Comment noted but unable to take specific which have not been identified? action pertaining to this comment without further information regarding the inadequacies that this consultee considers are in the assessment.

Ruth Hood, Market Weston Parish Council Q1. Do you agree with the proposal Yes Comment noted. indicators? Q2. Are there any further indicators which No comment could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the No comment spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects No comment which have not been identified?

Q5. Do you agree with the initial assessment No comment of spatial options consultation questions set out in Appendix B?

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Consultee Summary of Consultees Comments Response to the Comment Q6. Do any of the options have the potential No comment to cause adverse impacts which have not been identified?

Mr Ronald Knight Q1. Do you agree with the proposal Yes Comment noted. indicators? Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects No Comment noted. which have not been identified?

Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No Comment noted. to cause adverse impacts which have not been identified? Mr M Reed Q1. Do you agree with the proposal Yes Comment noted. indicators? Q2. Are there any further indicators which Not that I know of Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

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Consultee Summary of Consultees Comments Response to the Comment Q4. Are there any possible adverse effects No Comment noted. which have not been identified? Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential No Comment noted. to cause adverse impacts which have not been identified?

Cllr Mrs Anne Gower, St Edmundsbury Borough Council Q1. Do you agree with the proposal Yes Comment noted. indicators?

Q2. Are there any further indicators which No Comment noted. could be used to monitor the sustainability impacts of the plan more accurately?

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects Possibly the effects of housing density levels Comment noted. which have not been identified? on the communities.

Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B?

Q6. Do any of the options have the potential Not that I can see Comment noted. to cause adverse impacts which have not been identified?

Cornell, Access 1307 Q1. Do you agree with the proposal Yes Comment noted. indicators?

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Consultee Summary of Consultees Comments Response to the Comment Q2. Are there any further indicators which Transport infrastructure Comment noted. It is believed that relevant could be used to monitor the sustainability indicators are included under SA impacts of the plan more accurately? Objectives 5 (Access to Key Services) and 13 (Traffic effects).

Q3. Do you agree with the assessment of the Yes Comment noted. spatial objectives set out in Appendix A?

Q4. Are there any possible adverse effects No comment which have not been identified?

Q5. Do you agree with the initial assessment Yes Comment noted. of spatial options consultation questions set out in Appendix B? Q6. Do any of the options have the potential Impact on the growth of Haverhill on the Comment noted. Preserving settlements’ to cause adverse impacts which have not residents of villagers either side of the A1307 identity and not allowing coalescence of been identified? the towns with nearby villages was a material consideration in developing the Core Strategy Polices and their assessment, as well as in the detailed assessment of strategic sites.

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Appendix G - Consultation Comments on Preferred Options and Strategic Sites Issues and Options SAR

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Table G.1 – Consultation comments on St Edmundsbury Core Strategy Preferred Options and Strategic Sites Issues and Options SAR

Date Consultee Report Section Summary of Consultees Comments (includes proposed How the comment was dealt with changes) 05.01.09 Michael 10. The Spatial Some amendments are suggested for paragraphs 10.7 and The assessment of strategic spatial Wilks, Vision - Preferred 10.12 and Appendix D. It should be clear that Table 1 options has been reviewed in order to Suffolk Option presents the Options as scored in the Initial Sustainability improve clarity and consistency of its County Appraisal and that the Appendix B referred to is in this report. results. The full assessment table is Council The scoring in the Initial Sustainability Appraisal is done included in the Appendices and the differently from the current Sustainability Appraisal and this summary results are presented and means the results cannot be directly transcribed. Initially only discussed in the relevant section of the five categories were used (BSE, HAV, KSC, Other Villages & SAR. Countryside) – this then expanded to six (BSE, HAV, KSC, SC, Infill Villages & Countryside).

Secondly there is some inconsistency in the anticipated impact of ostensibly the same policy. For example ‘To Use Water & Mineral Resources Efficiently…’ was scored negatively in the Initial Sustainability Appraisal for BSE, but positively when judged in the current Sustainability Appraisal.

In light of the above comments, it may not be appropriate to state in Paragraph 10.12 that the preferred option has been ‘demonstrated’ as being the most sustainable as the other options have not been evaluated in the same way. It is suggested for purposes of completeness that Appendix D is supplemented with a Sustainability Appraisal of all the options. Only then can one option be ‘demonstrated’ as being the most sustainable. As the Sustainability Appraisal is being used to give a comparative indication of sustainability of different growth options, Appendix D only evaluating one option is not currently conducive to this.

05.01.09 Michael Appendix B - SA Cambs now have adopted Core Strategies which should be Comment noted and appreciated. Wilks, Framework similarly consulted. Suffolk Objectives and In light of the recommendations made on the Core Strategy County All the suggested indicators are now

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Council Indicators Objectives, the Sustainability Appraisal would have to be covered by the SA Framework. amended accordingly to align with this. Likewise the Objectives of the Sustainability Appraisal cannot be achieved if they are not represented in the Core Strategy – absence of Additional baseline data on the level of reference to the Historic Environment, for example. The CO2 emissions in the borough have Indicators identified in Appendix B remain fit for purpose, been added to the baseline tables. although some modification is suggested in order to evaluate progress made against a revised Objective H (Sustainable Construction) and J (Climate Change). The suggestion is that the following indicators may be appropriate: a. Percentage of buildings achieving desired rating against national building standards such as CSH or BREEAM b. Proportion of people travelling by sustainable modes of transport to their place of work c. Percentage of new development which sources a percentage of energy from low carbon or renewable sources: i. Onsite ii. Offsite d. Number of properties receiving grants to increase energy efficiency in their homes (e.g. from CERT or Warm Front) These indicators, in addition to those already referred to, will provide evidence as to progress being made in the Borough in reducing green house gas emissions through increasing energy efficiency in both new and old development, decreasing dependence on fossil fuels and reducing transport emissions. The lack of baseline data should not preclude the adoption of certain indicators. For ‘contemporary’ planning issues such as climate change, there will, by definition, be an absence of data. As stated in the Scoping Opinion SEBC is committed to gathering data on new issues as they emerge, subject to temporal and fiscal constraints. SCC hopes that baseline data on indicators that would demonstrate a commitment to combating climate change would be a priority.

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05.01.09 Michael 1. Non-Technical SCC recognises the rapid evolution of planning policy, but Comment noted. The suggested Wilks, Summary would like to point out several documents which it believes documents have been reviewed and Suffolk should be of a material consideration in assessing both the included in Table 4.1 – Relevant Plans County sustainability of the Core Strategy and its alignment with and Programmes. Council National Policy. These publications were not in circulation at the time of the Initial Scoping Report, but play a key role in sustainable planning at the current time and recognition of their importance would contribute to the soundness of the document. a. PPS1 Supplement Climate Change b. Building a Greener Future (Policy Statement) c. Homes for the Future: More Affordable, More Sustainable (Housing Green Paper) d. Government Strategy on Sustainable Construction e. Energy White Paper f. Building Sustainable Transport in to New Developments (Specifically designed for designated Growth Points) g. Manual for Streets

It is also worth pointing out that two neighbouring districts (Mid Suffolk & South Cambs) now have adopted Core Strategies which should be similarly consulted.

http://www.communities.gov.uk/publications/planningandbuildi ng/ppsclimatechange http://www.communities.gov.uk/archived/publications/planning andbuilding/buildinggreener http://www.communities.gov.uk/documents/housing/pdf/43998 6.pdf http://www.berr.gov.uk/files/file46535.pdf http://www.berr.gov.uk/files/file39387.pdf http://www.dft.gov.uk/pgr/sustainable/sustainabletransnew.pdf

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http://www.dft.gov.uk/pgr/sustainable/manforstreets/pdfmanfor streets.pdf 05.01.09 Michael 13. Conclusion Aside from an earlier comment we question whether this is Comment noted but unable to take Underwood and Next Steps correct. specific action pertaining to this comment without further information regarding the reservations of this consultee. 05.01.09 Michael 11. Core Strategy Aside from an earlier comment we question whether this is Comment noted. The Core Strategy Underwood Policies correct. Policies have been significantly revised and re-appraised in this SAR.

05.01.09 Michael 10. The Spatial Aside from an earlier comment we question whether this is Assessment of spatial options has Underwood Vision - Preferred correct. been reviewed in order to improve its Option clarity and consistency.

05.01.09 Michael 9. The We do not believe that the scoring system is correctly Comment noted. The assessment Underwood Sustainability balanced. scale has been aligned with SA best Appraisal Scoring practice. System

05.01.09 Michael 8. Core Strategy We believe that some items are excluded from this which Comment noted but unable to take Underwood Objectives should be included and vice versa. specific action pertaining to this comment in the absence of more specific comments/recommendations. However, it should be noted that SA Framework included in this SAR has been revised.

05.01.09 Michael 7. The We believe this is incomplete. Comment noted but unable to take Underwood Sustainability specific action pertaining to this Appraisal comment in the absence of more Framework specific comments/recommendations. However, it should be noted that SA Framework included in this SAR has been revised. 05.01.09 Mr. Tim Appendix F - Should include the revised set of SA Objectives established by Comment noted. Assessment of Core Holt-Wilson, Sustainability the SSAG in 2007. Strategy Policies was undertaken

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GeoSuffolk Appraisal of against the revised SA Framework. Development Control Policies

05.01.09 Mr. Tim Appendix E - Should include the revised set of SA Objectives established by Comment noted. Assessment of Core Holt-Wilson, Sustainability the SSAG in 2007. Strategy Policies was undertaken GeoSuffolk Appraisal of Core against the revised SA Framework. Strategy Policies 05.01.09 Mr. Tim Appendix D - Should include the revised set of SA Objectives established by Comment noted. Assessment of Core Holt-Wilson, Sustainability the SSAG in 2007. Strategy Policies was undertaken GeoSuffolk Appraisal of the against the revised SA Framework. Preferred Option

05.01.09 Mr. Tim Appendix B - SA Appendix B. Comment noted. SA Framework Holt-Wilson, Framework SA Framework Objectives and Indicators included in this SAR has been revised. GeoSuffolk Objectives and Indicators Table 1(b) Should include the revised set of Objectives and Indicators established by the SSAG in 2007.

05.01.09 Mr. Tim 9. The The revised objectives should be ‘To conserve and enhance SA Objective 16 has been amended in Holt-Wilson, Sustainability biodiversity and geodiversity’. light of this comment. GeoSuffolk Appraisal Scoring System 05.01.09 Mr. Tim 7. The As a result of the policy direction of PPS9, in 2007 the Suffolk SA Objective 16 has been amended in Holt-Wilson, Sustainability Sustainability Appraisal Group (SSAG) revised and updated light of this comment. Additional GeoSuffolk Appraisal the Objectives and Indicators to include Geodiversity. baseline information regarding geology Framework and geodiversity has also been added.

05.01.09 Mr. Tim 1. Non-Technical As stated in PPS9, ‘Development plan policies and planning Comment noted. The baseline Holt-Wilson, Summary decisions should be based upon up to date information about includes information regarding sites GeoSuffolk the environmental characteristics of their areas. These internationally, nationally and locally characteristics should include the relevant biodiversity and designated for their ecological or geological sources of the area’ (Key Principles 1i). geological value.

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05.01.09 Mr. John 13. Conclusion It is important that the Sustainability Appraisal continues to be Comment noted. The SA process has Cahill, and Next Steps an iterative process with policies being reviewed during its been and will continue be an iterative Kedington progress. process. Parish Council

05.01.09 Mr. John 11. Core Strategy New policy CS4 should stand as it provides protection for the The revised Core Strategy Policy 5 Cahill, Policies quality and distinctiveness of existing settlements. (Settlement Hierarchy and Identity) Kedington aims to deliver this objective. Parish Council

05.01.09 Mr. John 10. The Spatial 10.13 More work needs to be done in identifying suitable Comment has been taken in account in Cahill, Vision - Preferred villages as Key Service Centres. Size is not necessarily the development of the revised Core Kedington Option important - it is the number of suitable facilities available and a Strategy Policy 5 (Settlement Hierarchy Parish robust infrastructure that count also. At present, the Kedington and Identity). Council Parish Council doubts whether the village sufficiently meets the proposed criteria.

05.01.09 Mr. John 8. Core Strategy The Core Strategy Objectives should stand. Comment noted. The set of Core Cahill, Objectives Strategy objectives have been slightly Kedington amended to improve their clarity and to Parish address other comments received. Council 05.01.09 Mr. John 5. The Establishing an accurate picture of economic, social and Comment noted. Existing trends have Cahill, Sustainability environment trends within the borough is essential, as is been established in the baseline data Kedington Appraisal involving the public and authorities with the appropriate table and the likely future trends have Parish Process responsibilities in the assessment process. been set out in Table 7.2 – SA Current Council and Predicted Future Baseline Data Trends. The second part of the comment is addressed through undertaking a number of rounds of public consultations throughout the SA process.

05.01.09 Mr. John 5. The Policy CS4 is vital for conserving the context, character and Comment has been taken in account in Cahill, Sustainability setting of settlements and maintaining the quality of existing the development of the revised Core

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Kedington Appraisal settlements. Strategy Policy 5 (Settlement Hierarchy Parish Process and Identity). Council

05.01.09 Mr. John 1. Non-Technical It is important that 'Baseline Data' is reviewed regularly as Comment noted. This SAR includes Cahill, Summary things have changed and will continue to change since the the updated baseline data. Kedington original data was collected. Parish Council

05.01.09 Hewett 10. The Spatial Development should be focussed on Bury St Edmunds and Comment. These considerations have Vision - Preferred Haverhill with little or no development of any of the villages been taken on board in the revised Option other than limited infill. strategic options assessment and in The reality of the Rural Service Centres is that they have little the development of the preferred or no scope for employment as a matter of practical economic option. reality. Existing services for education and healthcare are limited and used to capacity. Retail facilities are useful but limited. Major shopping is undertaken by car. The villages are essentially rural and scope for development of previously used land is limited or non existent. Realistically any development would have to be on greenfield land which is unsustainable The majority of residents of these villages commutes to Bury St Edmunds or further afield using the A14. Adding to the housing in the villages will simply add to the number of vehicle movements. In addition, the essential rural quality of the villages which is part of the unique heritage of Suffolk will be destroyed. Many are already little more than dormitory villages for commuters. Increased development will only speed the process of destruction of the rural community.

04.01.09 Cllr David 1. Non-Technical I find it surprising that the positive impact of the internet on Comment noted. It is considered that Ray, St. Summary sustainability receives no mention at all in this document, access to the internet is partially Edmundsbu either using its current or potential capabilities. The internet covered by the SA indicator on Number ry Borough can now allow people to work from home, to shop from home, / percentage of people working from Council and to access information and services from home, thus home as main place of work. No more making a significant contribution to reducing the need to detailed data (i.e. Percentage of

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travel. households with broadband internet connection) is currently available at the borough level.

31.12.08 Mr. John 11. Core Strategy New Policy CS4 must be adhered to in order to protect Comment has been taken in account in Cahill Policies Settlement Identity and prevent coalescence of urban the development of the revised Core extensions with nearby villages. The historical context, Strategy Policy 5 (Settlement Hierarchy character and setting of existing settlements must be and Identity) and its assessment as preserved. well as in the detailed assessment of strategic sites.

31.12.08 Mr. John 10. The Spatial It is vital that new development for Haverhill and Bury St Comment has been taken in account in Cahill Vision - Preferred Edmunds is not allowed to destroy the identity and the development of the revised Core Option individuality of nearby villages. It is also necessary to regularly Strategy Policy 5 (Settlement Hierarchy review facilities that exist in the proposed Key Service and Identity). Centres. That which is present today may not be in months to come so the suitability of the villages proposed may be irrelevant.

31.12.08 Mr. John 5. The It is imperative that a proper Sustainability Appraisal is Infrastructure and Environmental Cahill Sustainability conducted as there is no current baseline on the infrastructure Capacity Appraisal Study prepared in Appraisal of villages such as Kedington. Facilities, amenities, drainage, parallel with the SA has informed both Process sewerage and liability of flooding must all be considered the development of the Core Strategy properly. None of these things have been addressed for Policies and their appraisal. previous one-off developments. 31.12.08 Mr. Stephen 1. Non-Technical My comments relate to various chapters and I shall address Comment noted. It is believed that Spencer Summary them fully in a letter. undertaken public consultations were 3.3 The consultation has been undertaken in a way which wide in scope and met the demonstrates poor governance. requirements of the SEA Regulations. 5.2 The process and its timing has sought to minimise public Avoiding further reliance on the private involvement. car was a key consideration in the sustainability appraisal of the Core 6.4 29 responses cannot be said to be the majority of 800 strategy Options and Policies. residents. 8.2.F The scheme will further promote car dependency 9.1 The scheme will increase environmental damage by cars

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29.12.08 Mr. Peter 5. The The baseline data (some of which is quite old) will have The baseline has been updated with Chrisp Sustainability changed as a result of the massive global economic upheaval more recent data where it is available. Appraisal of the last year and they should be updated and the plan Process reworked. 29.12.08 Mr. Peter 1. Non-Technical Considerable economic change has occurred since October The baseline has been updated with Chrisp Summary 2006 when baseline data was summarised. This should be more recent data where it is available. revisited to adjust for any significant changes relation to the Borough. 1.7 does not take account of trends and opportunities in the industries in the Borough e.g. agriculture.

24.12.08 Ms. 1. Non-Technical Having reviewed your document, I confirm that we have no Comment noted. Rachael Summary specific comments to make on this document at this stage. Bust, The Coal Authority

24.12.08 Dr. Alison Appendix B - SA We agree with all of the indicative measurements listed under Comment noted. A new indicator on Collins, Framework Objective Section "To conserve and enhance biodiversity" but condition of County Wildlife Sites has Natural Objectives and again we have to question what these will be measured been added to the revised SA England – Indicators against if no baseline figure has been set out. In addition, the Framework. More baseline data on Norfolk & new National Indicator (NI)197 – condition of County Wildlife ecological designations have included Suffolk Sites – needs to be specified as an indicator against which the in the revised SAR. Government Councils performance will in future be measured. Team

24.12.08 Dr. Alison 1. Non-Technical We raised concerns over the baseline information contained in Comment noted. Information on Collins, Summary the consultation draft Sustainability Appraisal Scoping report designated sites (including the Natural in December 2006, when we said of the landscape and condition of SSSI), BAP habitats and England – biodiversity content of the Profile of St Edmundsbury “This is species and landscape character has Norfolk & an inadequate description – even as a brief summary! There is been added to the baseline tables and Suffolk no biodiversity content at all.” We were unable to find baseline section. Government evidence that the environmental baseline has been improved Team since the draft Scoping Report was published, as a revised, post-consultation Scoping Report did not appear on the website. There is again no evidence base with the Sustainability Appraisal published with the current consultation.

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The evidence base should include statutory and non-statutory sites designated for their biodiversity and/or geodiversity interests, ancient woodlands, ecological networks, BAP habitats and species and wildlife audits of Bury St Edmunds and Haverhill. Landscape character assessment also needs to be included in the evidence base. The lack of information on the landscape and biodiversity of the Borough is unacceptable. It still appears to be the case that the only hard „evidence‟ for data presented in the SA regarding landscape and biodiversity is the single comment in Appendix A – "data would appear to indicate that most SSSI in the borough are in an unfavourable or mixed condition" There is no indication what this "data" consists of, or from where it has been obtained. 22.12.08 Rose 8. Core Strategy We note Objective D To maintain and develop leisure, culture, Comment noted. Consistency in Freeman, Objectives educational and community facilities to meet the needs of wording of Core strategy Objectives in The residents and visitors but for consistency please note that the the Core Strategy and the SAR will be Theatres word ‘culture’ is written as ‘cultural’ in the Core Strategy ensured. Trust Preferred Options document and we recommend that this word be amended so that it appears the same in both documents. The revised SA Framework includes new indicators under Objective 8: The East of England RSS Topic Report 4 Community and Participation in sport and active Wellbeing states that ‘Increased and sustainable participation recreation (National Indicator 8) and in sport, recreation and cultural activity should be encouraged Percentage of adults who have either by local authorities, public agencies and their partners through attended an arts event or participated Local Development Documents and other measures to in an arts activity at least three times in improve the overall standard of fitness, enhance cultural the past 12 months (NI 11 Engagement diversity and enrich the overall quality of life.’ in the arts) to address the comment. The Theatres Trust would like to ensure that cultural matters are taken into account in this document because protection of cultural facilities contributes to the Government’s programme of creating sustainable communities and we believe that theatres are therefore essential for inclusion in Planning for Sustainable Development. The cultural industries promote popular local and environmental activities as a way to engage socially excluded young people and then raise awareness

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about other opportunities for healthy lifestyles, community safety, education and skills. We would therefore expect that the development of sustainable cultural activities should be included in this Sustainability Appraisal and the Core Strategy Preferred Options.

05.11.08 Mr. Ralph Appendix D - p.49 No negative impacts on the countryside - this is not true. Comment noted. This issue was Carpenter Sustainability Increased concentration of people in urban areas ignores the considered in the assessment of the Appraisal of the fact that rural populations become increasingly pushed onto strategic options and in the Preferred Option the fringes with a greater sense of isolation, and resulting development and the assessment of poverty of opportunity. the Core Strategy Policies.

05.11.08 Mr. Ralph Appendix B - SA p.41 Travel - this is suspect - Suffolk Acre has shown that Comment noted. It is agreed that Carpenter Framework travel distances are greater amongst urban dwellers, than movement patterns may be also Objectives and rural dwellers. The underlying basis for deciding that people shaped by more subtle influences. SA Indicators living in the countryside travel for key services assume that Objective 13 includes a number of they are unable to provide for their own needs within their indicators to capture the effects arising communities. This is increasingly NOT the case. The cocktail from the implementation of the Core effect of suggests that patterns of behaviour are affected by strategy Policies on the levels of traffic. more subtle and un-measurable influences, and ultimately car Indicators under SA Objective 14 have journeys are caused by this cocktail effect. been revised to address this comment. p.41 No mention of OIL consumption - obviously more difficulty to measure as it travels in, BUT there is a need to push for conversion from oil to natural energy sources such as biomass, particularly for heating in the rural stock. Need to be clear that generating capacity includes energy for heating and not just electricity.

05.11.08 Mr. Ralph 9. The p.24 Bullet point 6 Comment noted and appreciated. The Carpenter Sustainability The wording on climate change needs to be reconsidered in revised Core Strategy objective J Appraisal Scoring view of the commitment by the current sec of state (Ed includes commitment to carbon System Milliband) to reduce carbon emissions significantly further. St emissions reduction, which should be Eds therefore needs to push for DRAMATIC reductions in delivered through the implementation carbon emissions from all development of the Core Strategy Policies in the sustainable design and transport. The need to reduce GHG emissions was a

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key consideration in the sustainability appraisal of the strategic options and sites and the Core Strategy Policies.

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244

St Edmundsbury Borough Council

St Edmundsbury Core Strategy: Submission Draft

Habitats Regulations Assessment: Screening

July 2009

St Edmundsbury Borough Council

St Edmundsbury Core Strategy: Submission Draft

Habitats Regulations Assessment: Screening

Record of Assessment of Likely Significant Effect on a European Site Required by Regulation 48 of the Conservation (Natural Habitats & c.) Regulations 1994

July 2009

Notice This report was produced by Atkins Limited for St Edmundsbury Borough Council in response to their particular instructions. This report may not be used by any person other than St Edmundsbury Borough Council without St Edmundsbury Borough Council’s express permission. In any event, Atkins accepts no liability for any costs, liabilities or losses arising as a result of the use of or reliance upon the contents of this report by any person other than St Edmundsbury Borough Council. No information provided in this report can be considered to be legal advice.

Document History

JOB NUMBER: 5081433 DOCUMENT REF: P:\GBEMB\MandI\Assessment\Project Folders\Sustainability Projects\508 1433 St Edmundsbury CS SAR\AA\40\St Edmundsbury CS AA Screening - Final Draft for Issue to Client.doc

Final with Policy 03 Amendments for Client C Warner - J Wynn C West 21/07/09 Comments

02 Final with Client Comments C Warner K Stanhope J Wynn C West 07/07/09

Final Draft for Client 01 C Warner - J Wynn C West 01/07/09 Comment

Revision Purpose/Description Originated Checked Reviewed Authorised Date

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St Edmundsbury Core Strategy: Submission Draft Habitats Regulations Assessment: Screening

Contents

Section Page

1. Introduction and Background 1 1.1 Background to this Assessment 1 1.2 Background to HRA 1 1.3 Outline of this Report 2 2. Methodology 3 3. The International Sites 7 4. Plan Details 11 4.1 Proposed Plan 11 4.2 Brief Description of Plan 11 4.3 Provisions within the Plan that Protect International Sites 11 5. Other Projects and Plans 14 6. HRA Results: Breckland SAC/SPA 15 7. HRA Results: Waveney and Little Ouse Valley Fens SAC 18 8. Conclusions 21

Tables

Table 3.1: Information about the Breckland SAC/SPA 7 Table 3.2: Information about the Waveney Little Ouse Valley Fens SAC 9 Table 5.1: HRAs carried out due to possible impacts on Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC 14

Appendices

Appendix A: Initial AA Screening Results Table 22 Appendix B: Key Diagram 29

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St Edmundsbury Core Strategy: Submission Draft Habitats Regulations Assessment: Screening

1. Introduction and Background

1.1 Background to this Assessment

This Habitats Regulations Assessment (HRA) screening has been carried out by Atkins Limited (Atkins) on behalf of St Edmundsbury Borough Council for the St Edmundsbury Core Strategy: Submission Draft August 2009 (Draft 1, June 2009). The Core Strategy Development Plan Document (DPD) is referred to as ‘the Plan’ for the purpose of this report. The Plan covers the whole of the administrative area of St Edmundsbury and is a high level strategic document that sets out the long-term spatial planning framework for the development of St Edmundsbury between 2008 and 2031.

1.2 Background to HRA

An HRA is required by Regulation 48 of the Conservation (Natural Habitats & c.) Regulations 1994 (as amended) (the Regulations) for all plans and projects which may have adverse effects on European sites. European sites include Special Areas of Conservation (SAC) and Special Protection Areas (SPA). HRA is also required, as a matter of UK Government policy for potential SPAs (pSPA), candidate SACs (cSAC) and listed Wetlands of International Importance (Ramsar sites) for the purposes of considering plans and projects, which may affect them1. Hereafter all of the above designated nature conservation sites are referred to as ‘international sites’. Local development plans include general policies or proposals (i.e. such as development limits for settlements) that often do not relate to specific development proposals but provide an overall strategy for development which is desirable within the boundary of the Plan (such as the County, District or Unitary boundary). If the policies/proposals do not relate to a specific development proposal then it can be difficult to assess the effects on an international site from the policies. For instance a development limit set around a village will be considered to control the growth of the settlement but will not include specific development proposals. It is not possible to conclude whether the development limit will have a likely significant effect on an international site without knowledge of design, type and location of any development within the newly set development limit. However, the local development plan can be written in such a way that international sites are considered. For instance, the Plan can state that any proposed developments under the Plan must have regard to and consider any adverse effects upon international sites. When a local authority considers a development proposal they must have regard to the whole plan including the introductory text and supporting text to the policies/proposals. Therefore the Plan may include text which states that consideration of international sites must be given in the development control process. This should ensure that developments are not permitted which could have significant adverse impacts on international sites. In these cases, further information will be required at the more detailed planning stage (e.g. preparation of Area Action Plans or other Development Plan Documents, Supplementary Planning Documents) and the development control stage for certain projects / proposals to allow the competent authority (in this case St Edmundsbury Borough Council) to assess whether they are likely to have a significant impact on the international sites, and thus, determine whether a full Appropriate Assessment is needed

1 Planning Policy Statement 9: Biodiversity and Geological Conservation, ODPM (August 2005)

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1.3 Outline of this Report

Following this introduction:

• Section 2 of this report outlines the methodology used for this HRA screening; • Section 3 provides details of the relevant international sites, namely Breckland SPA/SAC and Waveney and Little Ouse Valley Fens SAC (including their Conservation Objectives and site vulnerabilities); • Section 4 outlines details of the Submission Draft of the Plan and provisions within the document to protect the three international sites; • Section 5 details the other plans and projects identified which may lead to in combination effects on the three international sites; • Section 6 details the results of the HRA screening for the Breckland SAC/SPA; • Section 7 details the results of the HRA screening for the Waveney and Little Ouse Valley Fens SAC; and • Section 8 provides the conclusions of the HRA screening.

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2. Methodology

The Plan

The first step of the HRA process is to gather all available information regarding the Plan. This information is pivotal for the analysis of whether the Plan and its impact on the European sites. A summary of the Plan and its contents is given in Section 4.

Determination of the European Sites included in the HRA

The next step is to determine which European sites should be included in the HRA. An initial review of the Plan in light of the Habitats Regulations has been undertaken by Atkins as part of the HRA process. This initial review looked at the geographic extent or zone of influence of any impacts which could arise as a result of the Plan and considered which international sites should be included within the assessment. As a starting point all sites within St Edmundsbury and up to 20 km from the Borough boundary were identified2. There are three international sites within the district: Breckland SPA, Brecklands SAC and Waveney and Little Ouse Valley Fens SAC. Breckland SPA and SAC is an extremely large international site, of which parts falls within St Edmundsbury (along the north-western boundary of the Borough). Waveney and Little Ouse Valley Fens SAC is located at the north- eastern extent of the Borough, near Hopton. There are also seven other European sites within 20 km of the district boundary. These are:

• Redgrave and South Lopham Fens Ramsar site: 1.8 km east of the Borough; • Rex Graham Reserve SAC: Located approximately 5 km north of the Borough; • Norfolk Valley Fens SAC: Located approximately 8 km north of the Borough; • Devils Dyke SAC: Located approximately 9.6 km north-west of the Borough; • Fenland SAC: Located approximately 10.5 km north-west of the Borough; • Chippenham Fen Ramsar site: Located approximately 10.5 km north-west of the Borough (within the extents of Fenland SAC); and • Wicken Fen Ramsar site: Located approximately 17.5 km north-west of the Borough.

The Plan outlines potential sites for where future strategic housing development may take place. The Plan therefore focuses on regeneration and future development within the Borough. As such adverse effects from the Plan are considered unlikely to extend far beyond the Plan boundary. There are unlikely to be significant emissions to air or water which could be generated through developments such as large scale power stations and quarry operations as these types of development are not included in the Plan.

2 The Environment Agency Integrated Pollution Control (IPC) and Pollution Prevention and Control (PPC) guidance notes that a proposal to construct an coal or oil fired power station should consider impacts on European sites up to 15 km away (Page 4 of the Habitats Directive – Work Instruction: Appendix 7 Technical and Procedural Issues Specific to IPC and PPC produced by the Environment Agency in July 2004). The most recent England Leisure Visits report states that people will travel up to 17.3 km to a countryside destination (England Leisure Visits: Summary of the 2005 Leisure Visits Survey, Natural England, 2005). As a precaution an additional 5 km is added to this distance to ensure that all sites that may be impacted by a new development are considered as part of the HRA process.

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The Plan states that any future provision of housing will be concentrated in Bury St Edmunds and Havershill. This will focus development on already built up areas which are surrounded by open areas of green space. As such the Redgrave and South Lopham Fens Ramsar site, Rex Graham Reserve SAC, Norfolk Valley Fens SAC, Devils Dyke SAC, Fenland SAC, Chippenham Fen Ramsar site and Wicken Fen Ramsar site have been eliminated from the HRA process as it is extremely unlikely that there will be any adverse effects on these sites given their distance to these towns:

• Redgrave and South Lopham Fens Ramsar site is located 49 km north-east of Haverhill and 22 km north-east of Bury St Edmunds; • Rex Graham Reserve SAC is located 28 km north of Haverhill and 13 km north-west of Bury St Edmunds; • Norfolk Valley Fens SAC is located 45 km north-east of Haverhill and 22 km north of Bury St Edmunds; • Devils Dyke SAC is located 15.7 km north of Haverhill and 21.8 km west of Bury St Edmunds; • Fenland SAC and Chippenham Fen Ramsar site are located 22.5 km north of Haverhill and 18 km north-west of Bury St Edmunds; and • Wicken Fen Ramsar site is located 25 km north-west of Haverhill and 27 km north-west of Bury St Edmunds.

Given the distance of these international sites from these two towns it is considered highly unlikely that an increased number of dwellings in St Edmundsbury will lead to increased recreational pressure at these sites. Although the Rex Graham Reserve SAC and Devils Dyke SAC are within the 17.3 km of Bury St Edmunds and Haverhill respectively, it considered extremely unlikely that residents from St Edmundsbury will visit these small, relatively unknown sites over and above the green space within the Borough. Furthermore, Redgrave and South Lopham Fens Ramsar site, Fenland SAC, Chippenham Fen Ramsar site and Wicken Fen Ramsar site are all National Nature Reserves. Rex Graham Reserve SAC is also Suffolk Wildlife Trust Reserve. These international sites are all well set up to receive visitors (they actively encourage people to visit the sites) and they are managed accordingly. As such, although it is highly unlikely that the increased number of dwellings in St Edmundsbury would lead to increased recreational pressure at these international sites (due to the distance of these international sites from Bury St Edmunds and Haverhill), should there be an increase in recreational pressure at these locations it is extremely unlikely that there will be any adverse effects on these sites, Therefore this HRA is a record of the assessment of ‘likely significant effects’ from the Plan on three international sites: Breckland SPA/SAC and Waveney and Little Ouse Valley Fens SAC. Further details of these international sites including their location, designation details and conservation objectives are provided in Section 3.

Obtaining Information on European Sites with the Potential to be Affected

The next step is to gather the information on the European sites to be included in the HRA. This includes contacting Natural England for the Conservation Objectives and Favourable Conditions Tables for each international site.

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The Conservation Objectives and Favourable Conditions Tables for the Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC have been obtained from Natural England for the purpose of this assessment3.

Obtaining Information on Other Projects and Plans

In accordance with the Habitat Regulations there is a need to consider the potential for likely significant effects of the Plan ‘in combination’ with other projects and plans. Statutory bodies surrounding, or in close proximity to, the three international sites were contacted for details of any projects or plans that have been subject to HRA in order to determine if there is a cumulative impact on these international sites. The following organisations have been contacted for details of other plans and projects which have the potential for adverse effects upon the three international sites.

• Suffolk County Council; • St Edmundsbury Borough Council; • Mid-Suffolk District Council; • Babergh District Council; • South Cambridgeshire District Council; • East Cambridgeshire District Council; • Forest Heath District Council; • Borough Council of Kings Lynn and West Norfolk; • Breckland Council; • South Norfolk Council; • Natural England; and • Highways Agency.

Assessing the Impacts of the Plan ‘Alone’ and ‘In Combination’

Following the gathering of information on the Plan and the international sites, an assessment was undertaken to predict the likely significant effects of the Plan on the international sites ‘alone’. In order to inform this process, all parts of the Core Strategy were assessed to see if they could result in likely significant effects on the Breckland SPA/SAC and Waveney and Little Ouse Valley Fens SAC. This HRA assesses all 16 policies within the Plan. Each of the policies within the Plan has been examined in detail to see if they will have a significant effect on the three international sites. A brief description of each policy as well as the findings of this assessment is given in Table A-1 in Appendix A. Sections 6 and 7 summarise the findings of the HRA in relation to the Breckland SPA/SAC and Waveney and Little Ouse Valley Fens SAC respectively. The potential for likely significant effects of the Plan ‘in combination’ on these three international sites with other projects and plans has also been considered in this HRA.

3 Conservation Objectives and Favourable Conditions Tables for the Breckland SPA/SAC and Waveney and Little Ouse Valley Fens SAC were received from Natural England on 16/03/09.

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All HRAs that have been completed due to possible impacts on Breckland SPA/SAC and Little Ouse Valley Fens SAC were reviewed in order to determine whether there is the potential for in combination effects (see Section 5). The integrity of an international site is defined as ‘…the coherence of its ecological structure and function, across its whole area, that enables it to sustain the habitat, complex of habitats and/or the levels of populations of the species for which it was classified.’ (Part I, Section B, Paragraph 20 of ODPM Circular 06/2005 accompanying Planning Policy Statement 9: Biodiversity and Geological Conservation). The assessment of integrity is largely based on the conservation objectives of the site. If any plan or project causes the cited interest features of a site to fall into unfavourable condition they can be considered to have had a significant adverse effect upon the integrity of the site. Plans or projects can adversely affect the integrity of a site by:

• Causing delays in progress towards achieving the conservation objectives of the site; • Interrupting progress towards achieving the conservation objectives of the site; • Disrupting those factors that help to maintain the favourable conditions of the site; and • Interfering with the balance, distribution and density of key species that are the indicators of the favourable condition of the site.

HRA is an iterative process. Where necessary, suggestions can be made of how to amend the Plan to avoid likely significant effects on an international site. This iterative approach has been adopted as part of this assessment and recommendations for the final draft of the Core Strategy have been outlined.

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3. The International Sites

This section includes information about Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC, their designation status, the location of the sites, a brief description of the sites and their conservation objectives.

Table 3.1: Information about the Breckland SAC/SPA

Site Designation Status Breckland SAC Breckland SPA

Location of International This is an extremely large site (particularly the SPA designation) and Site part of the SAC and SPA falls into St Edmundsbury (along the north- western border of the Borough). The majority of the SPA/SAC falls into Breckland although sections are located within St Edmundsbury, Forest Heath and King’s Lynn and West Norfolk. The SPA is located in close proximity to a number of rural villages in St Edmundsbury including Lackford, Wordwell and Barnham (with the village limits almost meeting the SPA boundary in these cases). The closest settlement to the SAC in St Edmundsbury is Barnham (located approximately 0.9 km east of the site).

Brief Description of the Breckland SAC qualifies for European protection due to the habitats International Site it supports including:

• inland dunes with open grey hair grass (Corynephorus) and bent (Agrostis) grassland, • natural eutrophic lakes with Magnopotamion or Hydrocharition- type vegetation, • European dry heaths; and • semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia) These are all Annex I habitats which are a primary qualifying feature of the site. Also present but not a qualifying feature of the site are Alluvial forests with alder (Alnus glutinosa) and ash (Fraxinus excelsior) (an Annex 1 habitat) and great crested newts (an Annex II species). This site is considered to be one of the best areas in the UK for these habitats and species. During the breeding season Breckland SPA regularly supports:

• 60.1% of the UK breeding population of stone curlew; • 12.2% of the UK breeding population of European nightjar; and

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• 28.7% of the GB breeding population of woodlark.

Conservation Objectives The Conservation Objectives for the European interests on the SAC of the International Site and SPA are to maintain*, in favourable condition, the:

• European dry heaths; • Alluvial forests with alder (Alnus glutinosa) and ash (Fraxinus excelsior); • Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia); and • Inland dunes with open grey hair grass (Corynephorus) and bent (Agrostis) grasslands.

And: To maintain*, in favourable condition, the habitats for the populations of the Annex 1 species of European importance (stone curlew, woodlark and nightjar) with particular reference to:

• Heathland; • acid grassland; and • chalk grassland and/or inland dune communities.

* maintenance implies restoration if the feature is not currently in favourable condition.

Vulnerabilities of the Breckland SAC is vulnerable to the following: International Site • Nutrient deposition from the atmosphere and adjacent arable land; • invasion by self-sown trees/shrubs; • uncontrolled and inappropriate recreational activities; • cessation of traditional cutting and grazing management (leading to scrub and woodland spreading at the expense of the heathland and chalk grassland vegetation); and • Local ground water abstraction has a deleterious impact on the natural eutrophic lakes, the Breckland meres (subject of active liaison between Natural England and the Environment Agency).

Breckland SPA is vulnerable to the following: • Stone curlew are largely reliant on arable land for nesting and are thus vulnerable to disturbance and nest destruction from agricultural operations; • Stone curlew, nightjar and woodlark are vulnerable to predation from corvids and foxes and to disturbance caused by human activity, including dog-walking; • Breckland heathlands and acid grasslands supporting stone curlew, nightjar and woodlark are fragile in terms of the high background levels of air pollution in the area, particularly high

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nitrogen loads causing undesirable habitat changes; and • Collecting of eggs of stone curlew, and to some extent nightjar and woodlark, is believed to be a serious threat to individual birds and to population size. The loss of eggs to this illegal activity is not known.

Table 3.2: Information about the Waveney Little Ouse Valley Fens SAC

Site Designation Status Waveney and Little Ouse Valley Fens SAC

Location of International The site is located in the north-eastern corner of the Borough of St Site Edmundsbury. It is a small site that is split into three separate sections (two in St Edmundsbury and one in Breckland/Mid Suffolk). The nearest settlement to the SAC in St Edmundsbury is Hopton (located approximately 0.4 km east of the SAC).

Brief Description of the This site supports two Annex I habitats (that are a primary reason for International Site the selection of this site): Purple moor-grass (Molinia) meadows on calcareous, peaty or clayey silt laden soils (Molinion caeruleae) and calcareous fens with great fen-sedge (Cladium mariscus) and species of the Caricion davallianae. This site is considered to be one of the best areas in the UK for both these habitat types.

This site occurs in the East Anglian centre of distribution of calcareous fens and contains very extensive Cladium beds, including managed examples, as well as stands in contact zones between small sedge mire and species-poor Cladium. The habitat type here occurs in a different hydrological situation to the Broads – spring-fed valley fen rather than flood-plain mire.

This site is one of several representing Desmoulin’s whorl snail (Vertigo moulinsiana) in East Anglia. At Weston Fen populations of this snail occur in a valley fen. This is an Annex II species and its present is a primary reason for the selection of this site.

Conservation Objectives The Conservation Objectives for Little Ouse Valley Fens SAC are of the International Site (subject to natural change) to maintain* the following habitats in favourable condition:

• Calcareous fens with great fen-sedge (Cladium mariscus) and the species of the Caricion davallianae; • Purple moor-grass (Molinia) meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae)

And: To maintain*, in favourable condition, the habitats for the population of:

• Desmoulin’s whorl snail (Vertigo moulinsiana)

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* maintenance implies restoration if the feature is not currently in favourable condition.

Vulnerabilities of the Traditionally, peat was cut for fuel, sedge and reed were harvested International Site for thatching, and the fen meadows were mown for hay. This management declined between 1940 and 1960. Water abstraction, over-deepening of local rivers and land drainage have reduced the groundwater inputs while increasing outflows from the fens. Consequently some areas of peat have undergone periods of drying and rotting which has released nutrients into the system and allowed scrub to progressively invade the fens.

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4. Plan Details

4.1 Proposed Plan

The St Edmundsbury Core Strategy DPD (the Plan) provides the strategic context that will guide the preparation of subsequent DPDs identified in the Local Development Scheme. None of the proposals within the Plan are directly connected with, or necessary to the nature conservation management of the Breckland SAC/SPA or Waveney and Little Ouse Valley Fen SAC.

4.2 Brief Description of Plan

The Plan includes a vision of how the area will develop in physical, economic, environmental and social ways to meet the needs of residents, businesses and others, strategic objectives to achieve this vision and a spatial strategy which will identify how many settlements and other areas will develop or be preserved. The Plan includes a total of 16 core policies that will be used to establish development principles and broad indications of the location of strategic housing, employment, retail and other development proposals. The Key Diagram shows the broad locations of development proposals for the Borough (see Appendix B).

4.3 Provisions within the Plan that Protect International Sites

When planning applications are determined all of the relevant policies and supporting text in the Plan are taken into account and used as the basis for decision-making. Policy CS1 – St Edmundsbury Spatial Strategy and Policy CS2 - Sustainable Development. These policies aim to protect the environment, and as such seek to protect the three international sites. Policy CS1 states that the protection of the natural and historic environment, the distinctive character of settlements and ability to deliver infrastructure will take priority when determining the location of future development. The recognition of the natural environment in this policy seeks to avoid impacts on the environment and as such helps to protect as the three international sites. Policy CS2 states that development needs to protect and enhance biodiversity and wildlife and avoid impacts on areas of nature conservation interest (such as the three international sites) and that, where appropriate, the ecological features of a development site will be valued and enhanced. Text present within the Section 1 of the Plan entitled ‘Appropriate Assessment’ clearly states that any proposed development that may have an adverse effect on internationally important sites will be subject to an Appropriate Assessment (AA) by the competent authority (see Inset 4.1 below).

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The Plan therefore ensures that the competent authority (in this case St Edmundsbury Borough Council in consultation with Natural England) will give consideration to international sites in order to inform development control decisions. The text states that where it cannot be demonstrated that a development proposal will not have an adverse effect on the integrity of a site of European or international importance to nature conservation, such development is not supported by the Plan and will not be permitted. However, where there are imperative reasons of over-riding public interest and the competent authority is unable to conclude no adverse effect on the integrity of an international site, the authority will notify the Secretary of State and allow them to call in the application for determination. In these situations compensatory measures to protect the European site must be implemented. Therefore, any specific development proposals will need to be in line with the Core Strategy and will need to satisfy St Edmundsbury Borough Council and Natural England that there will either be no likely significant effects from the development on the Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC or that any significant effects can be effectively mitigated/compensated.

Inset 4.1: Text included in the ‘Appropriate Assessment’ Section of the Plan

Under Regulation 48 of the Conservation (Natural Habitats & c.) Regulations 1994 (the Habitats Regulations) an appropriate assessment has been carried out for the St Edmundsbury Core Strategy Submission Draft in order to see whether its proposals could have the potential to result in adverse effects upon an internationally important site. These are sites that have been designated for their international nature conservation interests and include:

• Special Areas of Conservation (SAC) designated under European Council Directive 92/43/EEC(a) on the Conservation of Natural Habitats and of Wild Fauna and Flora (the Habitats Directive);

• Special Protection Areas (SPA) designated under the European Council Directive 79/409/EEC on the Conservation of Wild Birds (the Birds Directive); and,

• The UK Government (in the accompanying circular to Planning Policy Statement 9) as a matter of policy has chosen to apply the appropriate assessment procedures in respect of Wetlands of International Importance (Ramsar sites), candidate SACs (cSACs) and potential SPAs (pSPAs) even though these are not European sites as a matter of law.

Within St Edmundsbury there are three international sites. Those of relevance to the Plan are the Breckland SAC, Breckland SPA and Waveney and Little Ouse Valley Fens SAC.

In accordance with Regulation 48 of the Habitats Regulations an Appropriate Assessment screening has been carried out to determine whether this document is likely, either alone or in combination with other plans and projects, to have a significant effect upon the international sites identified.

The results of the Appropriate Assessment screening show that there are no likely significant effects on the three international sites. The accompanying Appropriate Assessment report shows the outcome of the assessment (copies of these reports and a summary are available on request and can be accessed on the Council’s website).

If a proposed development could have a likely significant effect on an international site, further consideration and assessment will need to be made for these proposals at the development control stage or as part of lower tier development plan documents (including the Bury St Edmunds Area Action Plan, the Haverhill Area Action Plan and the Rural Site Allocations Development Plan Document). This will require a thorough ecological assessment of the potential effects upon the relevant international site(s) so as to allow the Competent Authority (in this case St Edmundsbury Borough Council) the ability to determine whether the development is likely to result in significant adverse impacts on the integrity of the site(s).

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Any development that cannot demonstrate that it would not have a significant adverse effect upon the integrity of a European site, or that impacts can be adequately mitigated, will be refused (and in the case of lower tier development plan documents, these site allocations will not be taken forward in the final plans) . This is in accordance with the precautionary principle enshrined within the Habitats Regulations. Where there are imperative reasons of over-riding public interest and the authority is unable to conclude no adverse effect on the integrity of a site, the authority will notify the Secretary of State and allow them to call in the application for determination. In these situations compensatory measures to protect the European site must be put in place.

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5. Other Projects and Plans

There are three HRAs that have been carried out due to the possibility of likely significant effects on Breckland SAC/SPA and two HRAs that have been carried out due to the possibility of likely significant effects on Waveney and Little Ouse Valley Fens SAC. The details of each HRA and a summary of their findings are given in Table 5.1 below.

Table 5.1: HRAs carried out due to possible impacts on Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC

Statutory Title of HRA Findings of HRA Body

Forest Heath Habitat Regulations Initial assessment of the Core Strategy showed likely District Assessment: Forest significant effects from the Plan on the Breckland SAC/SPA. Council Heath District Council Mitigation has been put in place in the Plan so as to avoid Core Strategy likely significant effects on these two international sites. Development Plan Document (March 2009)

Breckland Habitat Regulations Initial assessment of the Core Strategy showed likely Council Assessment: Breckland significant effects from the Plan on the Breckland SAC/SPA Council Submission Core and Waveney and Little Ouse Valley Fens SAC. Strategy and Mitigation has been put in place in the Plan so as to avoid Development Controls likely significant effects on these three international sites. Policies Document (November 2008)

Mid-Suffolk Habitats Regulations The HRA found no likely significant effects from the Plan on Council Assessment (Appropriate the Breckland SAC/SPA and Waveney and Little Ouse Valley Assessment) (October Fens SAC. 2007)

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6. HRA Results: Breckland SAC/SPA

Site Designation Status Breckland SAC Breckland SPA

Describe the individual None of the sixteen policies within the Plan will lead to likely significant elements of the Plan likely to effects on the Breckland SAC/SPA. give rise to impacts on the International Site One of the sixteen policies seeks solely to protect the natural environment, including biodiversity, and as such protect this international site. This is Policy CS2 - Sustainable Development. The protection of the natural environment is also recognised in Policy CS1 – St Edmundsbury Spatial Strategy.

Eleven of the sixteen policies will not lead directly to development (e.g. they relate to design and other qualitative criteria). There are Policies:

• CS3 - Design and Local Distinctiveness; • CS4 - Settlement Hierarchy and Identity; • CS5 - Affordable Housing; • CS6 - Gypsy and Travellers Accommodation; • CS7 - Sustainable Transport; • CS8 - Strategic Transport Improvements; • CS10 - Retail, Leisure and Cultural Provision; • CS13 – Rural Areas; • CS14 – Sequential Approach to Development of Sites; • CS15 – Community Infrastructure Capacity and Tariffs; and • CS16 - Plan, Monitor and Manage.

Four of the sixteen policies will lead to development in the long term. These are Policies:

• CS1 - St Edmundsbury Spatial Strategy; • CS9 - Employment and the Local Economy; • CS11 - Bury St Edmunds Strategic Growth; and • CS12 - Haverhill Strategic Growth.

There will be no likely significant effects on the International sites due to the proposals for development outlined in Policies CS1, CS9 and CS11 as these elements of the Plan are at a strategic level (e.g. the exact details of where the strategic development sites will be located, their design and/or

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when (or if) these sites will be constructed upon are not known). Lower tier Development Plan Documents (DPDs) will arise from these two Policies including:

• Bury St Edmunds Area Action Plan (AAP); • Haverhill AAP; and • Site Allocations DPD (including Rural Allocation sites and the Gypsy and Travellers sites).

The lower tier Plans will include specific details about the locations of future growth, including the exact location of allocations sites and their proposed land uses.

The Plan seeks to protect international sites (in line with Policy CS2). Furthermore the Plan commits to an HRA being carried out of any future DPDs when they are produced (in accordance with the Appropriate Assessment text in Section 1 of the Plan). As such the HRA of these documents will need to satisfy St Edmundsbury Borough Council (in consultation with Natural England) that there will either be no likely significant effects from any of the proposed allocations sites in these DPDs on Breckland SAC/SPA or that any significant effects can be effectively mitigated or compensated. If this cannot be proven the Council will not include the allocations site which may lead to significant effects on the international site in the lower tier plan.

There are no likely significant effects from Policy CS12. This is because the strategic growth in this town is located 21.5 km south-west of Breckland SPA and 26.5 km south-west of Breckland SAC. Given these distances (all over 20 km from Haverhill) it is extremely unlikely that there will be significant effects on these international sites. Furthermore, as outlined above, the proposals for development outlined in Policy CS12 are at a strategic level. The Haverhill AAP will arise from this policy and this will include specific details about the locations of future growth, including the exact location of allocations sites and their proposed land uses. In accordance with the text above, an HRA will also be undertaken of this document (ensuring that there will be no likely significant effects on the international sites).

The Initial AA Screening Results Table in Appendix A gives a full justification of the conclusions drawn for each of these four policies.

Describe any likely direct, The Plan seeks to protect international sites (in line with Policy CS2). Due indirect or secondary to the high level strategic nature of the Plan only broad details of future impacts of the Plan on the development possibly arising from Policies are given. As such the Plan International Site by virtue commits to HRAs being carried out of any future DPDs when they are of: produced (in accordance with the Appropriate Assessment text in Section 1 of the Plan). Future allocations sites will only be taken forward if it can be • Size and scale; proven through HRA that there will either be no likely significant effects from • Land take; any of the proposed allocations sites in these DPDs on Breckland SAC/SPA

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• Resource requirements or that any significant effects can be effectively mitigated or compensated. (i.e. water extraction etc); • Emissions (disposal to As such there are no likely direct, indirect or secondary impacts of the Plan land, water or air); on the international site. • Excavation requirements; • Duration of construction, operation, decommissioning etc.; and • Other.

Describe any likely changes The Plan seeks to protect international sites (in line with Policy CS2). Due to the site arising as a result to the high level strategic nature of the Plan only broad details of future of: development possibly arising from Policies are given. As such the Plan commits to HRAs being carried out of any future DPDs when they are • Reduction of habitat area; produced (in accordance with the Appropriate Assessment text in Section 1 • Disturbance to key of the Plan). Future allocations sites will only be taken forward if it can be species; proven through HRA that there will either be no likely significant effects from • Habitat or species fragmentation; any of the proposed allocations sites in these DPDs on Breckland SAC/SPA or that any significant effects can be effectively mitigated or compensated. • Reduction in species density; As such there are no likely changes to the international site as a result of • Changes in key indicators of conservation value (e.g. the Plan. water quality); and • Climate change

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7. HRA Results: Waveney and Little Ouse Valley Fens SAC

Site Designation Status Waveney and Little Ouse Valley Fens SAC

Describe the individual None of the sixteen policies within the Plan will lead to likely significant elements of the Plan likely to effects on the Waveney and Little Ouse Valley Fens SAC. give rise to impacts on the International Site One of the sixteen policies seeks solely to protect the natural environment, including biodiversity, and as such protect this international site. This is Policy CS2 - Sustainable Development. The protection of the natural environment is also recognised in Policy CS1 – St Edmundsbury Spatial Strategy.

Eleven of the sixteen policies will not lead directly to development (e.g. they relate to design and other qualitative criteria). There are Policies:

Four of the sixteen policies will lead to development in the long term. These are Policies:

• CS1 - St Edmundsbury Spatial Strategy; • CS9 - Employment and the Local Economy; • CS11 - Bury St Edmunds Strategic Growth; and • CS12 - Haverhill Strategic Growth.

There will be no likely significant effects due to the proposals for development outlined in Policies CS1, CS9 and CS11 as these elements of the Plan are at a strategic level (e.g. the exact details of where the strategic

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development sites will be located, their design and/or when (or if) these sites will be constructed upon are not known). Lower tier Development Plan Documents (DPDs) will arise from these two Policies including:

• Bury St Edmunds Area Action Plan (AAP); • Haverhill AAP; and • Site Allocations DPD (including rural allocations sites and the Gypsy and Travellers sites).

The lower tier Plans will include specific details about the locations of future growth, including the exact location of allocations sites and their proposed land uses.

The Plan seeks to protect international sites (in line with Policy CS2). Furthermore the Plan commits to an HRA being carried out of any future DPDs when they are produced (in accordance with the Appropriate Assessment text in Section 1 of the Plan). As such the HRA of these documents will need to satisfy St Edmundsbury Borough Council (in consultation with Natural England) that there will either be no likely significant effects from any of the proposed allocations sites in these DPDs on Waveney and Little Ouse Valley Fens SAC or that any significant effects can be effectively mitigated or compensated. If this cannot be proven the Council will not include the allocations site which may lead to significant effects on the international site in the lower tier plan.

There are no likely significant effects from Policy CS12. This is because the strategic growth in this town is located 42.5 km south-west of Waveney and Little Ouse Valley Fens SAC. Given this distance it is extremely unlikely that there will be significant effects on this international site. Furthermore, as outlined above, the proposals for development outlined in Policy CS12 are at a strategic level. The Haverhill AAP will arise from this policy and this will include specific details about the locations of future growth, including the exact location of allocations sites and their proposed land uses. In accordance with the text above, an HRA will also be undertaken of this document (ensuring that there will be no likely significant effects on the international site).

The Initial AA Screening Results Table in Appendix A gives a full justification of the conclusions drawn for each of these four policies.

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(i.e. water extraction etc); mitigated or compensated. • Emissions (disposal to land, water or air); As such there are no likely direct, indirect or secondary impacts of the Plan • Excavation requirements; on the international site. • Duration of construction, operation, decommissioning etc.; and • Other.

Describe any likely changes The Plan seeks to protect international sites (in line with Policy CS2). Due to the site arising as a result to the high level strategic nature of the Plan only broad details of future of: development possibly arising from Policies are given. As such the Plan commits to HRAs being carried out of any future DPDs when they are • Reduction of habitat area; produced (in accordance with the Appropriate Assessment text in Section 1 • Disturbance to key of the Plan). Future allocations sites will only be taken forward if it can be species; proven through HRA that there will either be no likely significant effects from • Habitat or species fragmentation; any of the proposed allocations sites in these DPDs on Waveney and Little Ouse Valley Fens SAC or that any significant effects can be effectively • Reduction in species density; mitigated or compensated. • Changes in key indicators of conservation value (e.g. As such there are no likely changes to the international site as a result of water quality); and the Plan. • Climate change

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8. Conclusions

Is the St Edmundsbury Core Strategy Submission Draft likely to have a significant effect ‘alone or in combination’ on the Breckland SAC, Breckland SPA or Waveney and Little Ouse Valley Fens SAC?

Eleven of the sixteen policies will not lead directly to development as they relate to design and other qualitative criteria (Policies CS3, CS4, CS5, CS6, CS7, CS8, CS10, CS13, CS14, CS15 and CS16). One of the sixteen policies seeks to protect the natural environment, including biodiversity (Policy CS2).

Four of the sixteen policies in the Core Strategy will lead to development in the long term. These are Policies CS1 - St Edmundsbury Spatial Strategy, CS9 - Employment and the Local Economy, CS11 - Bury St Edmunds Strategic Growth and CS12 - Haverhill Strategic Growth. These elements of the Plan are at a strategic level as the exact details of where the strategic development sites will be located, their design and/or when (or if) these sites will be constructed upon is not known at this stage.

The Plan seeks to protect international sites through Policy CS2 and is also recognised in Policy CS1. Furthermore, lower tier Development Plan Documents (DPDs) will arise from Policies CS1, CS9, CS11 and CS12 including Bury St Edmunds Area Action Plan (AAP), Haverhill AAP and Site Allocations DPDs (including Rural Allocation Sites and the Gypsy and Travellers sites). The lower tier Plans will include specific details about the locations of future growth, including the exact location of allocations sites and their proposed land uses. The Plan commits to an HRA being carried out at the development control stage/lower tier development plan stage for any development arising out of these policies. If it cannot be proven that there will no significant impacts on the international sites and/or it is not possible to mitigate/compensate for these impacts the development will not be included in the lower tier plans and/or be granted planning permission.

As such there will be no likely significant effects due to the proposals for development outlined in Policies CS1, CS9, CS11 and CS12 or from any of the other policies included in the Plan.

Furthermore, there is no potential for in combination effects as no other current plans or projects that are likely to lead to significant effects on the Breckland SAC/SPA or the Waveney and Little Ouse Valley Fens SAC have been identified, or where impacts have been identified they have been adequately mitigated.

Catherine Warner, Senior Ecologist, Name of assessor/originator: Date: 20/07/09 Atkins

Name of checker: Jules Wynn, Associate, Atkins Date: 21/07/09

Natural England comment on assessment:

Name of NE Officer: Date:

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Appendix A Initial HRA Screening Results Table

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A.1 Initial AA Screening Results Table

This appendix contains Table A-1 (see below) which summarises the features of each of the proposed policies within the Plan and whether each policy is considered to have a likely significant effect on the three international sites. The likely significant effects take into account the measures in the Plan which seek to protect the international sites. Where possible, policies that have been found to have no likely significant effect on a European site have been categorised into four different types:

• Policy Type 1: Policies that will not themselves lead to development (e.g. because they relate to design or other qualitative criteria for development, or they are not a land use planning policy); • Policy Type 2: Policies intended to protect the natural environment, including biodiversity; • Policy Type 3: Policies intended to conserve or enhance the natural, built or historic environment, where enhancement measures will not be likely to have any negative effect on a European site; and • Policy Type 4: Policies that positively steer development away from European sites and associated sensitive areas.

This has been based on The Habitats Regulations Assessment of Regional Spatial Strategies and sub-Regional Strategies (Draft Guidance) produced by Natural England in March 2007.

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Table A.1 – Initial HRA Screening Results

Will Policy have a Likely Significant Policy Number Policy Title Detail of Policy Content Effects on the Justification of finding International Sites?

Framework for Sustainable Development

This policy will lead to development in St Edmundsbury. As such this policy has the potential to lead to likely significant effects on Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC through the following:

• Increased levels of recreational activity possibly leading to higher levels of disturbance to Breckland SPA Annex I Policy states that at least 15,400 new homes (net) will be bird species (stone curlew, nightjar and woodlark) and possible degradation of Annex I habitats within Breckland built in the Borough between 2001 and 2031. To date SAC and Waveney and Little Ouse Valley Fens SAC (e.g. through increased levels of trampling and littering). 6,380 homes have been built or have been given planning This is due to more people living in the Borough and visiting the countryside close to and/or within these permission and around 9,205 are to be built (with around international sites; 5,100 in Bury St Edmunds, 2,740 in Haverhill and 1,365 in the rural area of the Borough). • Increased water abstraction leading to a possible drawdown effect on the water table (due to providing water new houses). Resulting on possible degradation of Annex I habitats within the Breckland SAC and Waveney and Little The exact locations of where these new homes are to be Ouse Valley Fens SAC; provided is not given in this policy. The Key Diagram St Edmundsbury Spatial identifies the broad locations for future strategic growth in • Increased levels of traffic generated air pollution leading affecting sensitive areas features of the Annex I habitats CS1 No Strategy Bury St Edmunds and Haverhill. within the Breckland SAC and Waveney and Little Ouse Valley Fens SAC. This is due to a possible increase in the number of cars in the Borough (associated with an increased number of dwellings in the area). However, it is stated that the Area Action Plans (AAPs) for Bury St Edmunds and Havershill and the Site Allocations However, given the strategic nature of the Plan the exact location and design of the strategic sites are not known at Development Plan Document (DPD) for the rural area will this stage and furthermore it is not known when these strategic sites would be built. As such it is not possible to identify the location and precise boundaries of future undertake an assessment of likely significant effects of this policy with any degree of confidence. For these reasons, development land. the Plan commits to an HRA at the lower tier plan stage (e.g. the AAPs for Bury St Edmunds and Haverhill and the The policy also states that the protection of the natural Site Allocations DPD). This is in accordance with the text in Section 1 of the Plan. The AAP will contain more environment will take priority when determining the location specific details about the strategic growth of Bury St Edmunds. The HRA of the AAP will have to prove that the of future development. proposed allocations sites will not have significant adverse effects on the Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC (or that significant impacts can be adequately mitigated or compensated for). If it cannot be proven that there will no significant adverse impacts on these international sites and/or it is not possible to mitigate/compensate for these impacts the Council will not allow the development to be constructed and it will not be included in the lower tier plans. The Plan therefore seeks to protect the integrity of the international sites.

Policy aims to ensure that a high quality, sustainable environment will be achieved by designing and incorporating measures into any new development. This includes measures such as protecting and enhancing natural resources (including avoiding impacts on areas of Policy Type 3: Policy intended to protect the natural environment (including biodiversity). It also seeks to enhance CS2 Sustainable Development No nature conservation interest) and the sustainable design of the natural environment where possible. the built environment. It also states that a network of designated sites, protected habitats and species, wildlife or green corridors and other green spaces will be identified, protected and conserved.

Policy states that new development must create and Design and Local contribute towards a high quality, sustainable environment Policy Type 1 and Type 3: Policy will not lead to development itself. Furthermore the policy states that it will seek to CS3 No Distinctiveness and that proposals will have to meet a number of criteria protect the natural environment. (including the protection of the natural environment).

Policy outlines the settlement hierarchy in the Borough, Policy Type 1: This policy will not lead directly to development itself but categorises the settlement types in the separating settlements into one of four categories: Towns, Borough. Key Service Centres, Local Service Centres and The supporting text of the policy outlines the development criteria for each settlement type. However the policy gives Settlement Hierarchy and CS4 Countryside. No no specific locations for future development (to be given in the Rural Site AAP). Consideration to the protection and Identity Towns (Bury St Edmunds and Haverhill only) will be the enhancement of internationally important sites will have to be taken into account prior to allocation of land for focus of large sale growth in the Borough. development into these sites (in accordance with Policy CS2). Furthermore any development arising from this policy will also have to take the text in Section 1 of the Plan relating to HRA. As such, due consideration will be paid to the Key Service Centres (Barrow, Clare, Kedlington, international sites during the planning process. Allocation sites in the rural will be specified in the lower tier AAP,

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Will Policy have a Likely Significant Policy Number Policy Title Detail of Policy Content Effects on the Justification of finding International Sites?

Wickhambrook, Stanton and Ixworth only) will be the main meaning the need for an HRA will be highlighted in the screening of that Plan. As such, this Policy is considered to focus for additional homes, jobs and community facilities have no likely significant effects on Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC. outside of Bury St Edmunds and Haverhill. Local Service Centres (12 villages including Bardwell, Cavendish, Hopton and Ingham) will encourage some small scale housing and employment development. Infill Villages (26 villages including Coney Weston, Hawkedon, Whepstead and Troston) where only infill development containing single dwellings or small groups of five homes or less will be permitted. Countryside includes all other settlements not identified in the Towns, Key Service Centres or Local Service Centres lists. The Council consider the construction of new homes or development is unsustainable. The supporting text of the policy states that the locations of new development sites in Key Service Centres and Local Service Centres will be addressed through the Rural Site Allocations DPD.

Policy states that developers will have to provide a certain Policy Type 1: This policy relates to design and other qualitative criteria for development and will not lead directly to CS5 Affordable Housing No amount of affordable housing in any new development. development

Policy Type 1: This policy relates to qualitative criteria that development must meet in order to be permitted and will not lead directly to development.

Policy lists criteria required in order to allow development of However, the supporting text of this policy notes that up to 20 gypsy and traveller sites must be provided by the gypsy and traveller sites in the Borough. Council by 2011 and that a DPD will be produced showing the location of temporary and permanent accommodation. The supporting text of the policy states that a separate DPD Although the policy specifies the need for gypsy and traveller sites no specific locations are given. When planning Gypsy and Travellers CS6 for the allocation of up to 20 gypsy and traveller sites by No applications are determined all the relevant policies in the Plan are taken into account and used as the basis for Accommodation 2011 will be produced by the Council. This text also states decision making. As such consideration to the protection and enhancement of internationally important sites will have that proposals for gypsy and traveller sites must have to be taken into account prior to allocation of land for development into these sites (in accordance with Policy CS2). particular regard to policies that seek to protect the Furthermore any development arising from this policy will also have to take the text in Section 1 of the Plan relating to environment of St Edmundsbury. HRA. As such, due consideration will be paid to the international sites during the planning process. The locations of the gypsy and travellers sites will be specified in the lower tier DPD, meaning the need for an HRA will be highlighted in the screening of that Plan. As such, this Policy is considered to have no likely significant effects on Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC.

Policy states that the Council will seek to develop and promote a high quality and sustainable transport system across the Borough and to reduce the need for travel Policy Type 1: This policy relates to design and other qualitative criteria for development and will not lead directly to CS7 Sustainable Transport through spatial planning and design. No development. The policy states that all proposals for development will have to provide for travel by a range of means other than private car (including walking, cycling and public transport)

Policy Type 1: This policy relates to design and other qualitative criteria for development and will not lead directly to development. Policy states that the Council will work to achieve Although the policy specifies the need for improvements at a number of locations within the Borough (e.g. Junctions improvements at a number of locations (including Junctions 42 and 44 of the A14) it does not states what these improvements are or when they will be undertaken. When Strategic Transport 42 and 44 of the A14 and the A1307) as well as improving CS8 No planning applications are determined all the relevant policies in the Plan are taken into account and used as the basis Improvements rail infrastructure in the Borough and the public transport for decision making. As such consideration to the protection and enhancement of internationally important sites will network in towns and rural areas. The policy also seeks to have to be taken into account prior to any improvement works (in accordance with Policy CS2). Furthermore any improve rights of way in the Borough. development arising from this policy will also have to take the text in Section 1 of the Plan relating to HRA. Due consideration will therefore be paid to the international sites during the planning process (meaning a project specific Appropriate Assessment will be carried out where necessary). As such, this Policy is considered to have no likely

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Will Policy have a Likely Significant Policy Number Policy Title Detail of Policy Content Effects on the Justification of finding International Sites?

significant effects on Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC.

This policy will lead to development in Bury St Edmunds, at an allocation site to the east of Suffolk Business Park. Breckland SPA is located approximately 10 km west of this allocation site. Breckland SAC is located approximately 15 km north-west and Little Ouse Valley Fens SAC is located approximately 16.5 km north-east of this allocation site. As such this policy has the potential to lead to likely significant effects on these international sites through:

• Increased water abstraction leading to a possible drawdown effect on the water table (due to providing water to new businesses) and resulting in possible degradation of Annex I habitats within the Breckland SAC and Waveney and Little Ouse Valley Fens SAC; • Increased levels of traffic generated air pollution leading affecting sensitive areas features of the Annex I habitats within the Breckland SAC and Waveney and Little Ouse Valley Fens SAC. This is due to a possible increase in the number of cars and lorries in the Borough (associated with an increased employment in the area).

The loss of habitat suitable for tone curlew and potentially woodlark to use to feed, roost and possibly breed outside Policy states that employment land will be allocated in of the SPA within the allocation site has been considered (habitats appear to be unsuitable for nightjar to be present). sustainable locations in Bury St Edmunds and Haverhill and However, the use of this site by these birds is considered unlikely due to the distance of the SPA from the allocation two allocations sites are identified (68.28 hectares to extend site (there are large areas of arable land closer to the SPA than the allocation site that birds from the SPA are more the existing Suffolk Business Park at Bury St Edmunds and likely to use) and the presence of Bury St Edmunds, a major urban conurbation, between the SPA and the allocation 12 hectares at Hanchett End in Haverhill). site (birds are unlikely to cross over this town when there are large areas of suitable habitat to closer to the SPA). The location of these sites is shown on the Key Diagram. Furthermore the allocation site is surrounded by development (including the existing Suffolk business park, the A14 No detail of the development to be provided at each of and railway lines) and as such is already quite highly disturbed by human activity, reducing the likelihood of birds from these sites is given in the Policy or the supporting text. the SPA using this site. Employment and the Local CS9 However, the supporting text states that a Bury St Edmunds No Economy Furthermore, it is considered that the allocation site in Bury St Edmunds will lead not to increased levels of Area Action Plan (AAP) and a Haverhill AAP will be recreational activity within Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC. This is due to the produced and that these documents will contain details of site being allocated for employment purposes and the likelihood that people will travel to and from the allocation site employment sites. solely for work purposes. The policy also states that existing employment areas will This policy will also lead to development in Haverhill, at the Hanchett End allocation site. However Breckland SPA is continue to meet needs of local towns and that proposals located approximately 22 km north-east of this allocation site. Breckland SAC is located approximately 27.5 km for growth at Key Service Centres and Local Service north-east and Waveney and Little Ouse Valley Fens is located approximately 45 km north-east of this allocation site. Centres will be expected to include provision for Given these distances (all sites are over 20 km from Haverhill) it is considered highly unlikely that there will be employment land.. significant effects on these three international sites from this part of the policy. Given the strategic nature of the Plan the exact design of the strategic sites are not known at this stage and furthermore it is not known when the two allocations site and other strategic employment sites (locations not yet identified) would be built. As such it is not possible to undertake an assessment of likely significant effects of this policy with any degree of confidence (particularly in relation to water abstraction and air pollution). For these reasons, the Plan commits to an HRA at the AAP stage (as in accordance with the text in Section 1 of the Plan). The AAP will contain more specific details about the strategic growth of Bury St Edmunds and Haverhill (including these two allocations sites). The HRA of the AAPs will have to prove that the proposals for these allocation sites will not have significant adverse effects on the Breckland SAC/SPA and/or Waveney and Little Ouse Valley Fens SAC (or that significant impacts can be adequately mitigated or compensated for). If it cannot be proven that there will no significant adverse impacts on these international sites, appropriate mitigation or compensation will need to be designed into the proposals, otherwise the Council will not allow the proposed development to be constructed. The Plan therefore seeks to protect the international sites and there are no likely significant effects on these three international sites from this Policy.

Policy Type 1: This policy relates to design and other qualitative criteria for development and will not lead directly to Policy states that the town centres in Bury St Edmunds and development. Haverhill will continue to be the focus for new retail, leisure and office development with some retail and leisure activity When planning applications are determined all the relevant policies in the Plan are taken into account and used as Retail, Leisure and Cultural CS10 also to be focused on Key Service and Service Centres No the basis for decision making. Therefore, any planning application arising as a result of this policy would also have to Provision identified in Policies CS4, CS11 and CS12. Criteria that take into account the possibility of likely significant effects on the three international resulting from the proposed works any new development in Bury St Edmunds and Haverhill (through consideration of Policy CS2 and the text relating to HRA in Section 1 of the Plan). The need for an HRA have to meet are also listed. would be identified as a result. As such, this Policy is considered to have no likely significant effects on Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC.

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Will Policy have a Likely Significant Policy Number Policy Title Detail of Policy Content Effects on the Justification of finding International Sites?

Strategy for Bury St Edmunds

This policy will lead to development in Bury St Edmunds. Breckland SPA is located approximately 6 km north-west of this town. Breckland SAC is located approximately 9.2 km north-west of Bury St Edmunds and Waveney and Little Ouse Valley Fens SAC is located approximately 16 km north-east of this town. As such this policy has the potential to lead to likely significant effects on these international sites through:

• Increased levels of recreational activity possibly leading to higher levels of disturbance to Breckland SPA Annex I bird species (stone curlew, nightjar and woodlark) and possible degradation of Annex I habitats within Breckland SAC and Waveney and Little Ouse Valley Fens SAC (e.g. through increased levels of trampling and littering). This is due to more people living in the Borough and visiting the countryside close to and/or within these Policy identifies the broad location for future strategic international sites; growth of the town (together with the Key Diagram). Five • Increased water abstraction leading to a possible drawdown effect on the water table (due to providing water to sites are identified with an outline of the possible number of new houses). Resulting in possible degradation of Annex I habitats within the Breckland SAC and Waveney and houses and land uses for each site. Little Ouse Valley Fens SAC; Bury St Edmunds Strategic CS11 The policy also states that the amount of development will No Growth be determined by environmental considerations. • Increased levels of traffic generated air pollution leading affecting sensitive areas features of the Annex I habitats within the Breckland SAC and Waveney and Little Ouse Valley Fens SAC. This is due to a possible increase in The supporting text states that the Bury St Edmunds AAP the number of cars in the Borough (associated with an increased number of dwellings in the area). will provide more information on site boundaries and the mix of uses at each site. However, given the strategic nature of the Plan the exact location and design of the strategic sites are not known at this stage and furthermore it is not known when these strategic sites would be built. As such it is not possible to undertake an assessment of likely significant effects of this policy with any degree of confidence. For these reasons, the Plan commits to an HRA at the AAP stage (as in accordance with the text in Section 1 of the Plan). The AAP will contain more specific details about the strategic growth of Bury St Edmunds. The HRA of the AAP will have to prove that the proposed allocations sites will not have significant adverse effects on the Breckland SAC/SPA and/or Waveney and Little Ouse Valley Fens SAC (or that significant impacts can be adequately mitigated or compensated for). If it cannot be proven that there will no significant adverse impacts on these international sites and/or it is not possible to mitigate/compensate for these impacts the Council will not allow the development to be constructed and the allocation site will not be included in the AAP. The Plan therefore seeks to protect the international sites and there are no likely significant effects on these three international sites from this Policy.

Strategy for Haverhill

Policy identifies the broad location for future strategic This policy will lead to development in Haverhill. However Breckland SPA is located approximately 21.5 km north- growth along the north-eastern edge of the town (shown on east of the town. Breckland SAC is located approximately 26.5 km north-east of the Haverhill and Waveney and Little the Key Diagram). At least 2,500 homes are to be provided Ouse Valley Fens is located approximately 42.5 km north-east of the town. at this site. Given these distances (all sites are over 20 km from Haverhill) it is considered highly unlikely that there will be The Policy also states that land north-west of Haverhill is significant effects on these three international sites from this Policy. CS12 Haverhill Strategic Growth No allocated with the potential to provide 1,100 homes and other services and facilities. Furthermore, a Haverhill AAP, as outlined for Policy CS9 and CS11 above, the proposals for development outlined in Policy CS12 are at a strategic level. The Haverhill AAP will arise from this policy and this will include specific details The supporting text states that the Haverhill AAP will about the locations of future growth, including the exact location of allocations sites and their proposed land uses. In provide more information on site boundaries and the mix of accordance with the text for Policy CS11 above, an HRA will also be undertaken of this document (ensuring that there uses at each site. will be no likely significant effects on the three international sites).

Strategy for Rural Areas

Policy states that the scale of development in Key Service Policy Type 1: This policy relates to design and other qualitative criteria for development and will not lead directly to Centres and Infill Villages will reflect the need to maintain development. the sustainability of local services, the diversification of the economy and provision of housing for local needs. When planning applications are determined all the relevant policies in the Plan are taken into account and used as CS13 Rural Areas Development outside these three settlement types will be No the basis for decision making. Therefore, any planning application arising as a result of this policy would also have to strictly controlled with a priority on enhancing the take into account the possibility of likely significant effects on the three international resulting from the proposed works biodiversity of the countryside. (through consideration of Policy CS2 and the text relating to HRA in Section 1 of the Plan). The need for an HRA would be identified as a result. As such, this Policy is considered to have no likely significant effects on Breckland It also states that the Rural Sites Allocations DPD will set SAC/SPA and Waveney and Little Ouse Valley Fens SAC. detailed uses which are appropriate in rural areas.

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Will Policy have a Likely Significant Policy Number Policy Title Detail of Policy Content Effects on the Justification of finding International Sites?

Infrastructure, Implementation and Monitoring

Policy states that the Council will promote the use of Sequential Approach to previously developed land within housing settlement Policy Type 1: This policy will not itself lead to development as it relates to the priorities the Council will take when CS14 No Development Sites boundaries ahead of releasing Greenfield sites for new considering where new development should be constructed. neighbourhoods.

Policy states that all new proposals for development will be Policy Type 1: This policy will not itself lead to development as it relates to the design of any new development to be required to demonstrate that the necessary on and off site put in place. infrastructure capacity required to support the development exists or will exist prior to the development being occupied. When planning applications are determined all the relevant policies in the Plan are taken into account and used as Community Infrastructure the basis for decision making. Therefore, any planning application arising as a result of this policy would also have to CS15 The policy lists key infrastructure requirements to deliver No Capacity and Tariffs take into account the possibility of likely significant effects on the three international resulting from the proposed works the aims of the Core Strategy (e.g. new relief roads in Bury (through consideration of Policy CS2 and the text relating to HRA in Section 1 of the Plan). The need for an HRA St Edmunds and Haverhill, additional school place would be identified as a result. As such, this Policy is considered to have no likely significant effects on Breckland provision including new school sites and upgrades to waste SAC/SPA and Waveney and Little Ouse Valley Fens SAC. water works.

Policy Type 1: This policy will not itself lead to development but will lead ensure that policies within the Core Strategy are being adhered to. Policy states that compliance with policies and allocations in the LDF will be monitored throughout the plan period and if When planning applications are determined all the relevant policies in the Plan are taken into account and used as it appears that policies and allocations are not being met a the basis for decision making. Therefore, any planning application arising as a result of the monitoring of the Core CS16 Plan, Monitor and Manage No set of mechanisms will be triggered (including action to Strategy and other LDF documents would also have to take into account the possibility of likely significant effects on bring forward sites for development and action to secure the the three international resulting from the proposed works (through consideration of Policy CS2 and the text relating to timely provision of infrastructure) HRA in Section 1 of the Plan). The need for an HRA would be identified as a result. As such, this Policy is considered to have no likely significant effects on Breckland SAC/SPA and Waveney and Little Ouse Valley Fens SAC.

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St Edmundsbury Core Strategy: Submission Draft Habitats Regulations Assessment: Screening

Appendix B Key Diagram

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