Suffolk Coastal First Draft Local Plan Summer 2018

Kettleburgh Parish Council’s Summary of the implications for (and beyond) Coastal First draft Local Plan

• District Council (SCDC) has published a First Draft Local Plan for public consultation. The Suffolk Coastal Local Plan is a framework document which will outline how the council sees the district developing over the next couple of decades. This First Draft Local Plan covers the period to 2036 and contains the suggested planning policies, which will be used to determine planning applications in the area in the future. It also sets out the level of growth which needs to be planned for and identifies where that growth could be located and how it should be delivered. • This Draft Local Plan proposes, among other things, changes to the ‘Settlement Hierarchy’ and how Kettleburgh fits into that; the immediate consequence of that change is the proposal to build 16 houses on the north side of The Street. • If this draft plan, as presented, were to become reality then Kettleburgh would undergo significant change in the future. Suffolk Coastal First draft Local Plan

Settlement Hierarchy

In 2009 SCDC’s Local Development Framework (LDF) established a Settlement Hierarchy as a policy tool for identifying a range of possible spatial development options that would provide for the scales of development required to meet the regional targets for development (particularly housing and employment).

The following table was the result of this.

Suffolk Coastal First draft Local Plan

Current Hierarchy From the LDF Suffolk Coastal First draft Local Plan

Other Villages (as Kettleburgh is classed as currently in the LDF) Other Villages are the settlements scattered across the District that do not have any, or have a minimal possession of facilities and services, relying totally on the higher order settlements to meet their day-to-day needs. They will not have physical limits boundaries drawn and to a considerable extent are considered as forming part of the countryside, contributing significantly to the overall character of the rural parts of the district. Small Villages (as proposed in the Suffolk Coastal First Draft Local Plan) Small Villages are identified due to their modest range of service provision, which will generally serve the needs of residents within the village but will cater for a smaller catchment than the Large Villages. As with the Large Villages, development of new housing in such settlements can help to support existing local services as well as contributing towards the mix of housing available in these villages. The form and character of Small Villages varies across the District and the impact upon these will be a key consideration in determining planning applications. Settlement Boundaries have been defined for Small Villages which identify the area within which the principle of development will be supported in accordance with Policy SCLP5.2 (see slide below).

Suffolk Coastal First draft Local Plan

Strategic Policy SP28 – Other Villages (as currently) New housing will firstly and primarily be directed to and integrated within the settlements for which physical limits boundaries have been defined. The strategy for new housing in Other Villages is that it be strictly controlled and limited to: (a) replacement dwellings on a one to one basis where they are no more prominent or visually intrusive in the countryside than the building to be replaced; (b) the sub-division of an existing larger dwelling where this would meet a local need; (c) conversion of an existing building subject to certain controls. New housing might be permitted in order to address local needs but only in exceptional circumstances where there is demonstrated community support e.g. through a community plan. Such circumstances might be: i) small developments of a scale appropriate to the size, location and characteristics of the particular community; or ii) in the form of the infilling of a plot within the physical core of the settlement by one or two dwellings for affordable housing. The cumulative impact on the character of the settlement through the development of a number of sites over time will be taken into account. Proposed Policy SCLP5.2: Housing Development in Small Villages Residential development will be permitted within defined Settlement Boundaries where it is: a) A small group of dwellings of a scale appropriate to the size, location and character of the village; or b) Infill development (in accordance with Policy SCLP5.7). Residential development will be permitted on Exception Sites adjacent or well related to defined Settlement Boundaries in accordance with policy SCP5.11.

Suffolk Coastal First draft Local Plan

Current LDF Policy SP28 for Other Villages

Proposed Policy Approach for Small Villages

(Physical Limits introduced) Development within existing Protection of local shops New housing allocations (Section employment areas (Policy (SCLP4.13) 12) SCLP4.1) Small groups of new housing and Development of employment infill within Settlement Boundaries uses appropriate to the scale of (SCLP5.2) the settlement (Policy SCLP4.2 and Policy SCLP4.5) Suffolk Coastal First draft Local Plan

Proposed Hierarchy • Policy SCLP3.3: Settlement Hierarchy • The Settlement Hierarchy enables the Council to achieve its vision for the District, meeting the scale of development required and enhancing the quality of the built, natural, historic, social and cultural environments whilst sustaining the vitality of communities. • The development requirements for Major Centres, Market Towns, Large Villages and Small Villages will be delivered through site allocations in the Local Plan or in Neighbourhood Plans, plus through windfall development in accordance with other policies in this Local Plan. • The development requirements in the Countryside will come forward through Neighbourhood Plans and windfall sites in accordance with other policies in this Local Plan.

Suffolk Coastal First draft Local Plan

Major Centre –

Felixstowe East of - , Heath, Brightwell Lakes, , (excluding village)

Market Towns –

Aldeburgh Woodbridge

Suffolk Coastal First draft Local Plan

Large Villages –

Bramfield Otley Snape Trimley St Mary Martlesham (village) Melton (village) Orford

Suffolk Coastal First draft Local Plan

Small Villages (43 in number) –

Alderton Tuddenham Tunstal Kettleburgh Ufford Kirton (including part of ) Middleton Clopton (with part of ) Rushmere St. Andrew (village) Easton Sutton

Suffolk Coastal First draft Local Plan

Countryside (53 in number) – Is “All other settlements” which are

Blaxhall Leatheringham Stratford St. A Boyton Brightwell Falkenham Swefling Farnham Melton Park Foxhall Monewdon Butley Parham Playford Walpole Cookley Hoo Sibton Huntingfield

Suffolk Coastal First draft Local Plan

The proposed Policy Approach for the Settlement Hierarchy is as follows

Small Villages Employment Development within existing employment areas (Policy SCLP4.1) Development of employment uses appropriate to the scale of the settlement (Policy SCLP4.2 and Policy SCLP4.5)

Retail Protection of local shops (SCLP4.13)

Housing New housing allocations (Section 12) Small groups of new housing and infill within Settlement Boundaries (SCLP5.2)

Suffolk Coastal First draft Local Plan

Countryside Employment Conversion and replacement of rural buildings for employment uses (Policy SCLP4.6) Farm diversification (Policy SCLP4.7) Development within existing employment areas (Policy SCLP4.1) New employment uses where need is demonstrated (Policy SCLP4.2)

Retail Protection of local shops (SCLP4.13)

Housing New housing within clusters of existing dwellings (SCLP5.4) Affordable housing on exception sites (SCLP5.11) Conversions of agricultural buildings / replacement dwellings (SCLP5.3)

Rural worker’s dwellings (SCLP5.6)

Suffolk Coastal First draft Local Plan

So what could this all mean for Kettleburgh?

Suffolk Coastal First draft Local Plan Suffolk Coastal First draft Local Plan Suffolk Coastal First draft Local Plan Suffolk Coastal First draft Local Plan Suffolk Coastal First draft Local Plan

Only site currently proposed in Kettleburgh within the SCLP –

Suffolk Coastal First draft Local Plan

Sites considered in Appendix B of the SCLP – Alternative Sites:

Suffolk Coastal First draft Local Plan

Sites considered in Appendix B of the SCLP – Alternative Sites: (Cont.) [SHELAA stands for “Strategic Housing and Economic Land Availability Assessment”] Suffolk Coastal First draft Local Plan Suffolk Coastal First draft Local Plan

However the KPC comments to the Issues and Options Consultation in 2017 were Suffolk Coastal First draft Local Plan

However the KPC comments to the Issues and Options Consultation in 2017 (Cont.) Suffolk Coastal First draft Local Plan

This is taken from Note that the proposals in 2009. red line did not not include the current site proposed (544).

Site 546 is now The red line known as 74 was removed when Kettleburgh became an Site 734 is now ‘Other Village’. known as 198 Suffolk Coastal First draft Local Plan Suffolk Coastal First draft Local Plan

Kettleburgh Suffolk Coastal First draft Local Plan Suffolk Coastal First draft Local Plan Suffolk Coastal First draft Local Plan

Policy SCLP5.11: Affordable Housing on Exception Sites

Proposals for the development of affordable housing in the countryside will be permitted where: • It is demonstrated there is an identified local need for affordable housing and this cannot be met through existing housing allocations in the Local Plan or relevant Neighbourhood Plan, or through development within the Settlement Boundary; • The scheme is adjacent to an identified Settlement Boundary or a cluster of houses in the countryside (as defined in Policy SCLP5.4); • The scheme incorporates a range of dwelling sizes, types and tenures appropriate to the identified local need; and • The location, scale and design standard of a scheme will retain or enhance the character and setting of the settlement or cluster and not lead to settlement coalescence. A limited amount of market housing will be permitted as part of affordable housing development in the countryside where it is required to cross-subsidise the affordable housing. Where market housing is to be provided on site this will be subsidiary to the affordable housing element of the proposal and the amount of market housing required will need to be demonstrated through a viability assessment. The amount of market housing on the site should be no more than one third of the dwellings on the site.

Where Starter Homes are proposed, these should form part of a mix of tenures on the site.

Where sites for affordable housing in the countryside are brought forward with an element of market housing, both housing tenures should be built to the same design standards and contribute towards the character of the area.

Suffolk Coastal First draft Local Plan

Background to Suffolk Coastal Proposed Strategy for the Rural Areas (Page 31)

“Rural Areas” comprise ‘Large Villages’, ‘Small Villages’ & ‘Countryside’ Policy SCLP12.29;, Strategy for the rural areas is shown on the next slide. What does the NPPF say about Rural housing? How will Suffolk Coastal respond to the latest (July 2018) NPPF? Answer; nobody knows yet.

Suffolk Coastal First draft Local Plan Suffolk Coastal First draft Local Plan

Other Issues to be Considered: 1. Water Treatment No mention is made about expansion of the Framlingham Sewage Treatment Works; [although there is mention of improvements to the Gedgrave Works {for Orford}; the limiting factor provided by the Rendlesham Water Re-cycling Centre (sewage treatment works) to proposals there; Sewage Treatment facilities required for Parham (for Policy SCLP13.24); Sewage Treatment facilities required for Debach (for Policy SCLP12.31); improvements potentially required to the Trimley St Martin Water Recycling Centre for growth in the area and upgrades to the waste water treatment (foul sewerage) network for proposals for Brightwell lakes]

[I was told at the SCDC ‘drop in’ event that SCDC are in conversation with Anglian Water in regard to the Framlingham Works.] Suffolk Coastal First draft Local Plan

Other Issues to be Considered: 2. The Kettleburgh Pumping Station As you may, or may not, be aware a few years ago Anglian Water sought permission to change their discharge licence for the Kettleburgh Transfer Pumping Station by removing the ‘emergency/exceptional circumstances’ associated with an overflow outlet from the collecting tank into the stream that leads to the River Deben. This is a long story but the Environment Agency refused any changes and this was upheld following an appeal from AW. Anglian Water then installed a separate rising main from the pumping station in Brandeston to the Framlingham Water Treatment Works which meant that the Kettleburgh pumping station only now has to accept discharges from Kettleburgh. However tankers have still had to be used occasionally (usually following heavy rainfall). So if 16 houses were to be built then there would be a greater risk of overflow discharges. Suffolk Coastal First draft Local Plan

Other Issues to be Considered: 3. Surface Water Drainage

One ‘service’ that has often been overlooked is surface water drainage. Rainwater should never knowingly be directed to the foul sewer. As this results in unnecessary flows going to water treatment works (indeed our pumping station suffers from this but mainly from inadvertent leakage of rainwater into the local foul sewer network). Suffolk Coastal First draft Local Plan

Other Issues to be Considered: 4. Magnitude of Additional Services Required As you are probably aware there are a number of properties within Kettleburgh that are ‘weekend’ homes. Such properties can become occupied on a full time basis at any time in the future by either the current owners moving in full time or selling up and moving on. Such changes are possible and the potential change of use can skew Suffolk Coastal’s calculations of what level of services are required (Suffolk Coastal in fact state that there are 2,500 second homes in the District). The issue, as I see it, is that if Suffolk Coastal’s predictions for the increased need for services is based upon both current housing stock number and the increased stock ‘demanded’ by the Local Plan then such service providers may get a bit of a wake up call if weekender homes become full time homes because those providers only know what they provide currently and what the predicted demand is whereas there is this ‘hidden’ demand just waiting to become a reality. For instance there are 112 properties in Kettleburgh if, say there were 4* properties (roughly 4%) in part time use then the demand on services would be approximately 96% of what would be expected from the current housing stock. Suffolk Coastal First draft Local Plan

Other Issues to be Considered: 5. Traffic Potential for greater traffic flow from Earl Soham through to the A12 or Framlingham due to further developments in – Earl Soham 25 (Neighbourhood Plan) O/A Contribution 37 Brandeston 30 O/A Contribution 31 Kettleburgh 16 O/A Contribution 20 Charsfield 20 O/A Contribution 42 Easton 10 (Neighbourhood Plan) O/A Contribution 34

Suffolk Coastal First draft Local Plan

Other Issues to be Considered: 6. Neighbourhood Plans

Previously I stated that out of 122 settlements 68 had ‘settlement boundaries’ and thus could attract housing allocations and so the total of 18 Neighbourhood Plans only represents about a quarter of settlements affected or potentially affected. Suffolk Coastal First draft Local Plan

Summing Up and the Vote The issues that I have raised during the presentation are 1. Change or no change? 2. The proposed new ‘Settlement Hierarchy.’ 3. The proposed allocation of 16 houses. 4. The proposed strategy for rural areas. 5/6. Kettleburgh as a ‘Small Village’ or ‘Countryside’. 7. Concerns over flooding. 8. Concerns over traffic. 9. Neighbourhood Plan? Others?