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Section Two: Your Representation Tinklers Meadow Green Team Response to the Mid Suffolk Joint Local Plan Consultation Section Two: Your Representation For Official use only:: JOINT LOCAL PLAN CONSULTATION JULY 2019 Date Acknowledged: Reference: Respondent Name / Organisation: Community Group – Keep Tinklers Meadow Green Team Please be specific what document / part your comment below relates to: Joint Local Plan Preferred Options Document. Section / option / question / site: Please indicate the nature of your comment: (mark ‘x’) All responses are o bjections Please enter your comment below: (Continue on a separate sheet if necessary) 01 Introduction (page 5) 1.1 – We object to the omission of key aspects of the Stowmarket Area Action Plan (SAAP) 2013 which has the weight of an adopted policy until 2027 – the JLP fails to give sufficient attention to the SAAP 2013 1.2, 1.3, 1.4 The opportunity to be involved in this JLP consultation is welcomed, however we object to the consultation process which has been self-limiting and general public responses. BMSDC have not established an effective process for people to engage with and respond to the consultation process. For example, an executive summary document of the Draft JLP made widely available through town and parish councils would have provided a higher level of support to local groups. Improving awareness and understanding about planning processes, terminology and preferred options. Engagement with the general public is essential to empower people, increase confidence and understanding in order for individuals to feel their response is valued. Otherwise the consultation process is flawed. The style and layout of the online public response form is off putting and cumbersome to use, limiting public engagement Our response continues below with attached documents to support our response Background to our community group Tinkers Meadow Green Team As a local community group, we have made a strong, active and positive effort to support this JLP public consultation process. Tinklers Meadow Green Team was established early in 2018 following a speculative development outline planning proposal on land south of Finborough Road (DC/18/01217 followed by DC/18/05570) this land is historically known as Tinklers Meadow (Apportionment Document) field number 255 (1842 Tithe Map). This is a cherished small tract of land outside the settlement boundary, in open countryside, in a flood plain, on best and most versatile agricultural land, adjacent to County Wildlife Sites, at the head of a SAAP designated Special landscape Area and the only undeveloped meadow acting as a ‘green buffer or Strategic gap’ to prevent potential coalescence with the neighbouring village of Onehouse. This site is rated ‘red’ and has been excluded from the Local Plan after several ‘call for site’ submissions due to its poor relationship to services and facilities. Yet it continues to remain vulnerable to speculative development. At the time of the first application BMSDC did not have a secure 5-yr housing supply. The efforts of the local community have been tremendous to save this field at the scenic gateway into Stowmarket from development with 100 objectors to the first application of 56 dwellings and 146 objectors so far to the present application for 4 houses. This site location is protected by clear statements 2 Tinklers Meadow Green Team Response to the Mid Suffolk Joint Local Plan Consultation and a sound rationale within various sections of the Stowmarket Area Action Plan (SAAP). As MSDC has currently secured a 5+-yr. housing supply this adds a layer of protection. There is a lack of substantive, strong statements within this Draft JLP regarding protecting, preserving and enhancing cherished landscapes, historic settings, green wildlife corridors, river valleys and strategic gaps. This is difficult to understand especially when BMSDC have declared a climate change emergency and feels like ‘the ground remains very shaky beneath our feet’ in terms of a JLP with clarity of purpose fitting for the next decades. Our group support moving the BMSDC Draft JLP forward towards adoption but the document we are responding to now in our view falls short of our expectations particularly in the JLP areas below. Key Evidence Documents (page 109) Object – Stowmarket Area Action Plan 2013 is excluded – SAAP is a comprehensive ‘Vision and Objectives’ document effective until 2027 and an adopted planning policy document. Yet several other documents with end dates before 2027 are included such as Dedham Vale AONB & Stour valley Project management Plan 2016-2021 Object – 15.16 We commend the inclusion of The Babergh Green Infrastructure Strategy 2012. We strongly object to the exclusion of the Stowmarket Area Action Plan 2013 from the list of Key Evidence Documents. The SAAP provides robust statements weak or non- existent in the JLP relating to the Stowmarket Area Object to the BMSDC Open Space Assessment May 2019 definition of ‘Open Space’ which results in the exclusion of natural open spaces as defined in the NPPF paragraph 99 which states: “The designation of land as Local Green Space through local and neighbourhood plans allows communities to identify and protect green areas of particular importance to them.” A new evidence base is required relating to the designation of land within a Local Green Space policy. Object – to the exclusion of the Suffolk Nature Strategy referred to in LP17 Biodiversity (page 86) 15.16 Suffolk Nature Strategy is referenced with examples of landscape features of principal importance – This document underpins BMSD landscape and nature protection, preservation and enhancement. It is a well written and clear document of specific relevance to the current acknowledged climate change emergency Object – to the exclusion of the 25 Year Environment Plan – This plan sets out a comprehensive and long- term approach to protecting and enhancing a variety of natural landscapes and habitats for improving the environment. Its goals are simple: cleaner air and water; plants and animals which are thriving; and a greener country for us all. Object – to the exclusion of The Government’s Clean Growth Strategy – which sets out how we will deliver clean, green growth to combat global warming Part 1 - Objectives And Strategic Policies 03 Vision and Objectives – Healthy Communities and Infrastructure 3.3 vii. (page 10) 1. Object to the exclusion of a Local Green Space policy and process which is fair and consistent for all communities to seek designation of highly valued Local Green Spaces within the emerging Joint Local Plan subject to meeting the NPPF criteria. This Draft JLP does not give communities an equal opportunity, discriminating against neighbourhoods with no adopted Neighbourhood Development Plan 3 Tinklers Meadow Green Team Response to the Mid Suffolk Joint Local Plan Consultation Part 1 - Objectives And Strategic Policies 03 Vision and Objectives – Healthy Communities and Infrastructure 3.3 ix. Vision and Strategy for Stowmarket (page 10) 1. Object to the lack of clarity regarding this statement – what, when, how, who? Will a new taskforce be set up to consider the development of vision and strategy for Stowmarket? Will this build on the SAAP? 2. Object to the lack of ‘joined up policies’ to enable public understanding - How does the statement in 3.3ix. relate to the document Delivering a Vision for Prosperity in Stowmarket (DFP)? This VFP 5- year Action Plan states ‘Stowmarket is the main town and key driver of growth and prosperity in Mid Suffolk, with a large sphere of influence as the major social and economic hub for the district. “We have used the Delivering a Vision for Prosperity (VFP) initiative to seek the views of local people about the future of the town and we have listened to what they have told us. There are many different opinions to consider in mapping out the future of the town and our starting point has been to discuss and understand the views of the local community, so that we can move forward together, on the basis of a consensus about what matters most”. The JLP is unclear about alignment with VFP – Why? Who is involved and impact of VFP on JLP is unclear. Part 1 - Objectives And Strategic Policies 03 Vision and Objectives – Key Environmental Issues ii. Heritage Assets (page 13) refer also to Part 2 Local Policies LP20 – The Historic Environment Object – JLP omits landscape as a heritage asset in this point. Part 1 - Objectives And Strategic Policies 11 Infrastructure (page 50-51) Object – JLP Infrastructure is not sufficiently robust in recognition of current difficulties and needs. Stowmarket is a fast-growing community with an infrastructure now not fit for purpose. JLP does not provide reassurance through Policy SP08 Infrastructure provision to enable the increased population to access the services they need now and into the future. Such as access to GP’s, schools, waste facilities. Not enough attention is given to sustainable transport or green infrastructure at an early enough in the planning process. Currently traffic congestion in and around Stowmarket leads to increased levels of pollution with a negative and harmful impact on the BMSDC declared climate change emergency. Part 1 - Objectives And Strategic Policies 12 Protection And Management of the Environment (page 53-56) Policy SP09 lacks substance – We object to the omission of locally important sites (designated in SAAP) and County Wildlife Sites within this policy Object to 12.1 -to 12.12. which also lack substance. Given the MSDC declaration of a climate change emergency (July 2019)– not enough attention is given to identify the wide range of issues relating to climate change and how the JLP can effectively address these issues through strategic planning and Development Management Policies. We understand a task group has been set up to consider climate change and green wildlife corridors, but it remains unclear how the task group findings will impact of the next JLP.
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