Dear [Click and Type Name]

Date: 24th May 2018 Enquiries to: Robert Feakes Tel: 01473 260454 Email: robert.feakes@suffolk.gov.uk

Waveney District Council Riverside 4 Canning Road Lowestoft Suffolk NR33 0EQ

Dear Sir/Madam,

Re: Waveney Local Plan, Final Draft Plan (Regulation 19) – Suffolk County Council Response

Thank you for consulting Suffolk County Council on the submission version of the Waveney Local Plan. The County Council welcomes Waveney District Council’s efforts to promote sustainable growth in the District.

The following comments cover matters of soundness, insofar as they relate to Suffolk County Council’s service responsibilities and policy objectives.

All parts of the Plan are considered to meet legal and procedural requirements, and the District and County Councils have made extensive efforts to cooperate under s.110 of the Localism Act 2011.

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Policy WLP1.4 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This Part of the Plan is unsound because it is not effective.

Policy WLP1.4 sets out that, generally, on site infrastructure will be funded through Section 106 and off site infrastructure through the Community Infrastructure Levy (CIL). This is not necessarily incorrect, but the supporting text should set out what the policy means by ‘generally’.

In broad terms, Section 106 functions best as a means of mitigating site-specific impacts, and CIL as a means of mitigating cumulative, area-wide impacts. The Government has recently confirmed this in its consultation paper on reforming developer contributions, stating that Section 106 agreements are made on a site-by-site basis and that CIL ‘is used to address the cumulative impact of development in an area’.1

1 See ‘Supporting housing delivery through developer contributions’, page 8 (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/691182/Developer_Contributi ons_Consultation.pdf)

Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX www.suffolk.gov.uk Site-specific impacts are frequently off-site, for example junction improvements. This is exemplified by the reference, in Appendix 1, to ‘Road improvements as outlined in Transport Assessments on sites above 80 dwellings’, which may be provided through Section 106 and Section 278 agreements.

Paragraph 1.43 should set out that the on-site/off-site distinction between CIL and Section 106 is not absolute, and will be regulated by the District Council’s Regulation 123 List. Suggested additional text is set out below.

Whilst the distinction between on and off-site infrastructure will not be absolute, it is envisaged that infrastructure directly related to development will be funded through Section 106 agreements, and mitigation for cumulative infrastructure impacts funded through CIL. The specific distinction will be regulated by the District Council’s Regulation 123 List.

Adult Social Care

Policy WLP8.31 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This Part of the Plan is unsound because it is not effective, it is not justified by evidence and is not positively prepared to meet objectively assessed development requirements.

The County Council welcomes the District Council’s efforts to meet the needs of the ageing population – through a policy which seeks to support the development of accessible/adaptable housing and to shape the design of the built environment around new residential development.

However, it is not clear why the requirement to consider dementia friendly design principles only applies to residential development. The policy should be amended to ensure that these principles also apply to other forms of development effecting the public realm.

‘Proposals for retail, leisure, public realm, open space and housing developments of 10 or more dwellings…

Furthermore, the policy should be amended to increase the proportion of dwellings which are to be built to the M4(2) standard, up from 40%. The SHMA identifies the significant demographic changes which are predicted in the Waveney Housing Market Area, and the need to meet the housing requirements of an increasing number of older people and people with physical disabilities.

The Plan identifies, in paragraph 8.183, that the cost of achieving the M4(2) standard is not excessive and has a marginal impact on viability only. Whilst there may be a 40% increase in the number of households in which at least one resident is over 65, and the SHMA may indicate that 40% of all households have at least one resident with a disability, it must be acknowledged that the dwellings coming forward under this document will only make a relatively small contribution to the overall housing stock by the end of the plan period.

Based on CLG’s 2014 household projections, the number of households in Waveney will increase from 51,388 to 57,996. The 6,214 new homes planned for by this Local Plan will only make up a small proportion of the total number of households in Waveney. In order to get closer to meeting the needs of older and disabled households, the percentage of homes built to M4(2) standard should be increased. Arguably, the proportion should be increased to 100%.

Policy WLP8.2 – Support

Parts of this policy regarding sheltered and extra-care housing meet the tests of soundness and are supported by the County Council.

The County Council welcomes the requirement that sheltered and extra-care housing be included as affordable units where needed and where practical. However, it should be noted that, in practice, extra-care housing schemes often require a proportion of the units to be sold or let on a market basis in order that the overall scheme be financially viable. The policy does not prevent this.

Policies WLP2.4, 2.13, 2.16 and 3.1 – Support

Parts of these policies regarding specialist housing for older people meet the tests of soundness and are supported by the County Council.

The County Council welcomes the commitment to make provision for specialist housing for older people. The SHMA (Part 2) sets out the estimated overall need for different types of housing with care. It also, in paragraph 6.12, notes that ‘The actual numbers and type of specialist accommodation needed may depend on changes in patterns of demand and expectations and it is also recognised that Suffolk County Council are developing further accommodation typologies to best respond to future care needs, and it is therefore appropriate to consider this level of need with the acknowledgement that the form of accommodation delivered should not be too prescriptive.’

The County Council will work with the District Council, developers and housing associations to determine the specific housing requirements to meet the ‘retirement community’ responsibility in this policy.

Archaeology

Paragraph 4.45 – Amendment Proposed

This part of the plan does not meet the test of soundness. This part of the plan is not sound because it is ineffective

The first sentence of this paragraph explains that a planning application for the site described in policy WLP4.6 must be accompanied by an archaeological evaluation. However, the second sentence could imply that archaeology could be dealt with by condition, which is contradictory.

In order to make this text sound the following sentence should be deleted: “There is potential for archaeology to be found on the site and any planning application will be subject to a condition requiring a programme of archaeological work.”

It should be noted that it may still be appropriate to impose conditions on development with grant of planning permission following pre-determination archaeological assessment.

Paragraph 7.57

This part of the plan does not meet the test of soundness. This part of the plan is not sound because it is not effective.

A significant archaeological feature covering a large proportion of the site is a constraint at this site. The extent of the constraint, and measures for managing it, will be determined by the archaeological investigations required by policy WLP7.6.

To make this part of the plan sound the following text, adding description of the archaeological feature, should be inserted into paragraph 7.57:

The site contains two ring ditches in the north east of the site, recorded from aerial photography, which are likely to be prehistoric burial monuments, possibly with associated later burials.

Paragraph 7.79/ Policy WLP7.8

This part of the plan does not meet the test of soundness. This part of the plan is not sound because it is not consistent with national policy.

In paragraph 7.79 it is stated that for site WLP7.8 an archaeological condition will be required to support a planning application. This is based on County Council advice provided in response to the issues and options consultation, however at this stage the site was smaller. The current extent of the site now includes more topographically sensitive land and an up-front archaeological assessment will be required.

To make this part of the plan sound it is recommended that paragraph 7.79 is replaced with “The site has potential for archaeology and any planning application must be supported by the results of a programme of archaeological evaluation.”

This requirement should also be included in policy WLP7.8, with the following wording added to mirror other policies:

“Any planning application should include the results of a programme of archaeological evaluation, including appropriate fieldwork, and should demonstrate the impacts of development on archaeological remains and proposals for managing those impacts.”

Policy WLP8.40 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This part of the Plan is not sound because it is not effective and it is not consistent with national policy.

These comments follow those made at Preferred Options stage.

The policy is disproportionate, by requiring full archaeological assessment in respect of any proposal affecting archaeological remains. Paragraph 141 of the NPPF sets out that developers should be required to ‘record and advance understanding of the significance of heritage assets…in a manner proportionate to their importance…and to make this evidence (and any archive generated) publicly accessible.’ The supporting text, in paragraph 8.229, sets out the ways in which archaeological assessment can be carried out in a proportionate manner – this could legitimately be included within the policy.

The policy should also be clear that the purpose of archaeological assessments that accompany applications is to identify the significance of remains, which will determine how these remains will be preserved and whether archaeological planning conditions or obligations will need to be imposed.

The policy should be amended as follows, in order to make it sound.

A full An archaeological assessment must be included with any planning application affecting areas of known or suspected archaeological importance, to identify the significance of remains and to ensure that provision is made for the preservation of important archaeological remains, particularly those that may be demonstrably of national importance.

Development should preserve and record archaeological remains. Where proposals affect archaeological sites, preference will be given to preservation in situ appropriate to the significance of the remains unless it can be shown that recording of remains, assessment, analysis report, reporting, dissemination and deposition of archive for access and curation is more appropriate.

Archaeological conditions or planning obligations will be imposed on consents as appropriate. Measures to disseminate and promote information about archaeological assets to the public will be supported.

Early Education

In respect of provision of Early Education places, the Plan is not sound as drafted. The Plan is not sound because it is not effective and not deliverable.

The County Council has a legal duty to ensure a sufficiency of places for pre-school pupils. All 3- and 4-year olds are eligible for 15 hours free provision per week, (from September 2017) the 3- and 4- year old children of working parents are eligible for 30 hours free provision per week. Eligible 2-year olds can access 15 hours per week. Whilst the impact of recent changes is yet to be fully understood, the estimates of need have been based on current forecasts of demand and the best information available on the take up of 30-hour places.

The NPPF, in paragraph 70, requires planning policies take a positive approach to community facilities. The Planning Practice Guidance (ref: 21b-028-20150901) further requires that the planning system takes children’s ‘best interests’ into account in considering any relevant matter.

The strategy for providing places is set out in Appendix 1. The following amendments are required to the Plan to complete this strategy:

Policies WLP2.14 and WLP2.15

The scale of growth from these two sites, in an area with an existing deficit of 61 places within Oulton ward, means that the establishment of a new Early Education setting is the optimum solution for delivering sustainable growth. However, despite discussion since the previous consultation stage, our authorities have not identified a location where provision could be made.

Without an indicative strategy, identifying a location for a new setting, the Plan is not sound as it is not positively prepared, consistent with national policy or effective. The best way to rectify this issue would be to include a requirement that one of these sites includes a reservation of land for a new early years setting. Site WLP2.14 may be preferable given the opportunity to provide direct access from the B1375 (Parkhill).

The County Council will seek the opportunity to discuss this further with the District Council, prior to examination hearings.

Policy WLP3.2

As set out in Appendix 1, the scale of growth in Beccles is such that three early education settings may be required to mitigate the impacts of growth. As identified in the Infrastructure and Delivery Plan, Site WLP3.1 will provide two settings. The County Council’s intention is to seek provision of a third setting at the existing Beccles Primary School, but this is dependent on the agreement of the academy provider at that school. Should this agreement not be forthcoming, provision will need to be made on this site. As such, the County Council requests that this policy be amended to include reservation of land for a new early education setting:

• The site should make provision for a new early education setting

Supporting text, potentially as a new paragraph 3.26, should explain the need.

This site is large enough to justify the provision of a new early years setting. If provision cannot be made at a primary school, provision will need to be made on this site.

Education (primary, secondary and sixth form)

In respect of provision of primary and secondary school places, the Plan is not sound as drafted. The Plan is not sound because it is not effective, not deliverable and not consistent with national policy.

The NPPF, in paragraph 72, sets out the need to give great weight to the need to create, expand or alter schools, and to work with education providers to resolve issues before applications are submitted. The Plan needs to be based on a strategy which implements this requirement and provides school places in accessible locations (in line with the intent of paragraph 38). The strategy for providing school places is set out in an appendix to this letter.

Whilst the Plan sets out a positive approach, for which the County Council is very grateful to the Waveney District Council, the following policies require amendment. The justification is set out in the appended table. Consequential minor amendments may be required to the Infrastructure and Delivery Framework. The County Council has previously sent updates in respect of the secondary school figures and new primary school forecasts are expected to be published within a month. The County Council will provide an update to the District Council when new forecasts are produced.

WLP2.4

• 1.5 2 form entry primary school 2.2ha primary school site including a pre-school setting

WLP2.16

• 2 form entry primary school including a pre-school setting (2.2 hectares);

WLP3.1

• 2 form entry primary school including a pre-school setting (2.2 hectares);

WLP5.2

Land west of St John’s Road, Bungay (21 hectares) as identified on the Policies Map is allocated for a comprehensive development of 400 dwellings, 3 hectares of employment land, a pre-school setting and open space. Phasing of the site and the housing mix will need to be evaluated to consider the provision of sufficient school places.

[…]

An extension to the school playing field of 2.75 hectares should be provided

Flood Risk

Paragraph 2.108 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This Part of the Plan is unsound because it is not effective.

The County Council as Lead Local Flood Authority welcomes the reference to the Lowestoft Flood Risk Management Strategy. Figure 11 shows the indicative layout of the site, including the approximate route for the main access road. The emerging outputs of the Lowestoft Flood Risk Management Project suggests a need for diversion of the Kirkley Stream, following approximately the same route as the main access road. It is possible to incorporate both the access road and the diverted watercourse but, given the need for the watercourse to be located within an 8m wide corridor free of other development (to enable access for maintenance), it would be helpful if supporting text could highlight the need to consider this issue early.

The following additional text would help to guide the delivery of this site:

The developer should, at the earliest practical opportunity, discuss the means of integrating the flood mitigation requirements into the development layout and design with the relevant agencies.

Policy WLP2.16 – Support

This part of the Plan is considered to meet the legal and procedural requirements.

This part of the Plan does meet the tests of soundness.

The County Council welcomes and supports the requirement that the northern part of the site be developed in line with the Lowestoft Flood Risk Management Project. Please note separate comments on supporting text (paragraph 2.108).

Paragraphs 8.136 – 8.137 –Amendment Proposed

This part of the Plan is considered to meet the legal and procedural requirements.

This part of the Plan does not meet the tests of soundness. This Part of the Plan is unsound because it is not effective.

These paragraphs helpfully set out some of the key issues when considering the design of drainage systems. Suffolk County Council, as Lead Local Flood Authority, has published detailed guidance on the provision and maintenance of sustainable drainage systems. To aid and guide the implementation of policies WLP8.24, WLP8.28 and WLP8.29, the Plan could helpfully make reference to this Guidance.

The following should be added to the end of Paragraph 8.37:

Guidance for surface water drainage and management and the provision of SuDS on new developments can be found in the Suffolk Flood Risk Management Strategy, specifically Appendix A. Early consideration of requirements and constraints in developing site layouts is encouraged in order to realise the benefits of full integration of land uses.

Policy WLP5.1 – Support

Parts of this Policy meet the tests of soundness and are supported by the County Council.

The County Council as Lead Local Flood Authority supports the flood risk provisions of this policy.

Appendix 1 – Infrastructure and Delivery Framework – Coastal Protection and Flooding

This section of the Plan should make reference to the partnership project being developed and led by the Water Management Alliance (on behalf of Waveney, Lower Yare and Lothingland Internal Drainage Board), involving Suffolk County Council, Waveney District Council, Kessingland Parish Council, Environment Agency, Natural England and local landowners and businesses that has the objective to reduce future flood risk to homes, businesses and farmland in the Hundred River valley, as well as the A12 at Kessingland Levels (the stretch of the A12 immediately south of Kessingland).

A project is being worked up to be delivered in the short term, with funding currently being sought from Suffolk County Council, Waveney District Council, the Internal Drainage Board, Flood Grant in Aid and Local Levy via the Regional Flood and Coast Committee, Natural England, local landowners/businesses and potential from the LEP.

It appears that there are a number of ways of delivering the necessary protection for the homes, businesses and A12, and the funding gap is not excessive. It is, therefore, not seen as a significant risk to the delivery of the Plan. However, the ‘do nothing’ option could result in regular and repeated closure of the A12 due to tidal flooding. The Plan should recognise this issue and the fact that a project is coming forward to resolve it. The following text is proposed as additional information for the Appendix.

to Fill Gap toFill

Project Priority Provider Lead Cost Approximate Sources Funding Funding Potential Amount Developer Required Contribution Developer of Type Contribution Remaining Potential Gap Funding Funding Potential Sources Timescale/Progress

erprise erprise

ent Agency, Agency, ent

3 years. 3

–

12m

RFCC, Natural England, Local Ent Local England, Natural RFCC,

Benacre/Kessingland Flood Risk Project Risk Flood Benacre/Kessingland Essential of behalf (on Alliance Management Water Lead: IDB); Lothingland and Yare Lower Waveney, Council, County Suffolk include: partners supporting Environm Council, District Waveney Anglian Council, Parish Kessingland natural England, Committee. Coastal and Flood Regional (Eastern) £10 Council, District Waveney Council, Suffolk County Agency Environment landowners/businesses, Local via Partnership TBC TBC CIL TBC sources’ ‘funding See term Short

Minerals Policy

The County Council is responding as the Minerals and Waste Planning Authority in reference to the currently adopted Minerals Core Strategy (MCS) and Waste Core Strategy (WCS) and also in reference to the emerging Suffolk Minerals and Waste Local Plan (SMWLP). The submission draft of the SMWLP was completed as of April 2018 and consultation on this draft will take place in June and July 2018. The Preferred Options draft of the SMWLP was completed and consulted on after the Preferred Options consultation of the Waveney Local Plan, meaning the County Council will be raising new issues it could not raise in the previous consultation.

One issue relates to the new Minerals Consultation Area, as set out in the submission version of the new Minerals and Waste Local Plan. The emerging SMWLP contains a new Minerals Consultation Area, identifying potentially exploitable minerals resource, which is more extensive than the Consultation Area in the currently adopted MCS. The following sites were previously identified as being within the Minerals Consultation Area, based on the adopted MCS:

- Site WLP2.16, Land South of the Street, Carlton Colville - Site WLP4.2, Land adjacent to Chediston Street, Halesworth

The new Minerals Consultation Area, in the submission version Suffolk Minerals and Waste Local Plan (April 2018), includes the following Waveney Local Plan allocations which were not previously identified for their potential as a source of minerals (sand and gravel).

- Site WLP5.2, Land West of St John’s Road, Bungay - Site WLP6.1, Land West of Copperwheat Avenue, Reydon - Site WLP2.3, Peto Square - Site WLP2.4, Kirkley Waterfront and Sustainable Urban Neighbourhood

Policy 5 of the extant adopted Minerals Core Strategy states:

‘The Mineral Planning Authority will safeguard... Those areas identified on Map B [the Minerals Consultation Area] from proposed development in excess of one hectare which is not in accordance with a Local Development Document. The MPA will, when consulted by the LPA, object to such development unless it can be shown that the sand and gravel present is not of economic value, or that the mineral will be worked before the development takes place;’

Policy 10 of the draft (submission version) Suffolk Minerals and Waste Local Plan states:

‘The County Council will safeguard… those Minerals Safeguarding Areas located within the Minerals Consultation Areas identified on the Proposals Map from proposed development in excess of five hectares which is not in accordance with the Development Plan. The County Council will, when consulted by the Local Planning Authority, object to such development unless it can be shown that the sand and gravel present is not of economic value, or not practically or environmentally feasible to extract, or that the mineral will be worked before the development takes place’

The policy assumes that the minerals extraction requirements of allocated sites is considered through the Local Plan. Given their size, location relative to other sensitive development and accessibility to the lorry route network, the County Council’s view is that the sites should be treated as follows:

- Site WLP2.16, Land South of the Street, Carlton Colville: require that the development tests the quality of the resource, to consider prior extraction of the mineral resource. - Site WLP4.2, Land adjacent to Chediston Street, Halesworth: require that the development tests the quality of the resource, to consider requiring use of the resource on site, during construction.

- Site WLP5.2, Land West of St John’s Road, Bungay: require that the development tests the quality of the resource, to consider requiring use of the resource on site, during construction. - Site WLP6.1, Land West of Copperwheat Avenue, Reydon: require that the development tests the quality of the resource, to consider requiring use of the resource on site, during construction. - Site WLP2.3, Peto Square: no requirement - Site WLP2.4, Kirkley Waterfront and Sustainable Urban Neighbourhood: no requirement.

Amendments are set out below, in order to put this approach in place, in the Plan.

Paragraph 2.115 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This Part of the Plan is unsound because it is not effective.

The County Council welcomes the intent of this paragraph, in seeking to meet Suffolk Minerals Core Strategy and NPPF policy requirements on protecting finite mineral resources. Paragraph 2.115 takes account of the potential for exploitable sand and gravel resource within the proposed site on Land South of The Street, Carlton Colville/Gisleham site (Policy WLP2.16). However, in order for this to be effective it is recommended the text of paragraph 2.115 is enforced by the text of policy WLP2.16. This is because Policy 5 of the Minerals Core Strategy States:

“The Mineral Planning Authority will safeguard... Those areas identified on Map B [the Minerals Consultation Area] from proposed development in excess of one hectare which is not in accordance with a Local Development Document.”

As the Waveney Local Plan will be a Local Development Document once adopted, site WLP2.16 will not be covered by policy 5 of the MCS, as assumed by paragraph 2.115. The Minerals Core Strategy assumes that the County Council will have already have been consulted regarding site allocations in local plans and come to an agreement with the Local Planning Authority as to whether prior testing and extraction is needed. The emerging SMWLP makes the same assumption. In order for the minerals on this site to be effectively safeguarded the text of paragraph 2.115 should be enforced by policy WLP2.16.

For information, this requirement does not mean that mineral extraction will be required. Rather, the quality of the mineral resource will be tested and prior mineral extraction will only be required if there is a viable resource present and all other requirements (such as protecting the amenity of neighbours) have been considered. Following testing of the resource, it may be preferable to require extraction for use of minerals on site only – reducing the need for extraction elsewhere and reducing traffic associated with the construction of the housing.

Policy WLP2.16 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This Part of the Plan is unsound because it is not effective.

Please see comments on paragraph 2.115.

The Policy should be amended to include a new site-specific criteria:

- The quality of sand and gravel resources on site will be tested, in order to judge whether prior extraction of mineral resources for use on or off site will be required in advance of development.

Paragraph 4.21 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This Part of the Plan is unsound because it is not effective.

The County Council welcomes the intent of this paragraph, in seeking to meet Suffolk Minerals Core Strategy and NPPF policy requirements on protecting finite mineral resources. Paragraph 4.21 takes account of the potential for exploitable sand and gravel resource within the proposed site on Land Adjacent to Chediston Street, Halesworth (WLP4.2). However, in order for this to be effective it is recommended the text of paragraph 4.2 is enforced by policy WLP2.16. This is because Policy 5 of the Minerals Core Strategy States:

As the Waveney Local Plan will be a Local Development Document once adopted, site WLP4.2 will not be covered by policy 5 of the MCS, as assumed by paragraph 4.21. The Minerals Core Strategy assumes that the County Council will already have been consulted regarding site allocations in local plans and come to an agreement with the Local Planning Authority as to whether prior testing and extraction is needed. The emerging SMWLP makes the same assumption. In order for the minerals on this site to be effectively safeguarded the intent of paragraph 4.21 should be enforced by policy WLP4.2.

Given the size and location of the site, it is unlikely that mineral extraction will be viable. For that reason, the County Council is not seeking a requirement that prior mineral extraction be considered. Rather, an amendment is proposed requiring the developer to demonstrate that efforts are made to make use of the mineral resource on site, during the construction of the housing. This makes use of the finite resource and potentially reduces construction traffic.

Policies WLP4.2, 5.2 and 6.1 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This Part of the Plan is unsound because it is not effective.

Please see comments on paragraph 4.21.

The Policy should be amended to include a new site specific criteria, to meet the requirements of the Suffolk Minerals Plan:

- The quality of sand and gravel resources on site will be tested, in order to judge whether on-site resources should be used during development.

Public Rights of Way

Policy WLP8.21 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This part of the Plan is unsound because it is not effective and it is not consistent with national policy.

At preferred options stage, the County Council sought a comprehensive policy approach to Public Rights of Way, to help implement the requirements of the NPPF (to protect and enhance the Public Rights of Way network) and the Vision and Objectives set out in the Plan.

Paragraph 75 of the NPPF states ‘Planning policies should protect and enhance public rights of way and access’. While enhancement is supported within Plan policies there is no specific policy provision in the plan for the protection of PRoW.

The policy should be amended to include protection of the Rights of Way network. Supporting text should be added to put the various roles of Rights of Way in context, determining the manner in which development should implement of the NPPF and plan policies.

Policy amendment:

- It is well integrated into, protects and enhances the existing pedestrian routes and the public rights of way network.

New supporting text:

The Public Rights of Way Network play an important role in supporting the development of sustainable communities. In designing and assessing development proposals, the Public Rights of Way Network should be considered as a means of encouraging physical activity, providing access to the natural environment, supporting tourism, reducing travel by vehicular modes, reducing carbon emissions and (where relevant) aiding recreational avoidance of sensitive sites.

Transport

The County Council as Highways Authority has worked with the District Council on the preparation of this Plan and the transport evidence which underpins it. The March 2018 report by WSP – ‘Waveney Local Plan Suffolk County Transport Model (SCTM) – Preferred Option Traffic Forecasting Report’ (‘the Report’) sets out the cumulative impacts of growth, on the transport network.

Based on the Report it is the view of the County Council as Highway Authority that, with mitigation, the level and distribution of growth in this Plan can be delivered without severe impacts on the highway network. The priority must be to minimise the need to travel and maximise the proportion of journeys undertaken by healthy and sustainable modes. Policy WLP8.21 does this.

The Report identifies that mitigation will be required at locations on the highway network. Whilst traffic levels and congestion are likely to increase as a result of this Plan and background growth; highway mitigation, modal shift and the delivery of schemes such as the Lake Lothing Third Crossing and the Beccles Southern Relief Road means that growth can be accommodated.

The following comments refer to site and policy-specific matters.

Policy WLP2.4 – Amendment Proposed

This part of the Plan does not meet the tests of soundness. This part of the Plan is unsound because it is not positively prepared to help meet infrastructure requirements. It is also harms the effectiveness of the Plan.

Suffolk County Council as Highway Authority is promoting the Lake Lothing Third Crossing. The transport evidence which underpins this Plan (WSP 2018) assumes the delivery of the Third Crossing. Paragraph 2.8 of the Plan (Infrastructure needs for the Lowestoft Area) identifies the Lake Lothing Third Crossing as being ‘required’ for delivering and supporting the growth planned for the area. The Infrastructure Delivery Framework in Appendix 1 lists the Third Crossing as being ‘essential’ infrastructure, which means it is considered as being necessary to support and mitigate development, to ensure policy objectives of the Plan are met.

By requiring that land used for employment in the Riverside Road area be retained for B1, B2 and B8 uses, this policy does not support the delivery of the Lake Lothing Third Crossing. It is not positively prepared to meet infrastructure requirements.

The policy should be amended as follows:

…for uses not falling within Use Classes B1, B2 or B8 will only be permitted where:

• Development is part of or ancillary to the Lake Lothing Third Crossing project, or • […]

Policy WLP2.10 – Amendment Proposed

By requiring that land and buildings be retained in port related uses, and restricting redevelopment to non-port related uses, this policy does not support the delivery of the Lake Lothing Third Crossing. It is not positively prepared to meet infrastructure requirements.

The policy should be amended as follows:

Within the Inner Harbour Port Area land and buildings will be retained in port and other associated uses, with the exception of redevelopment required to deliver the Lake Lothing Third Crossing. Proposals involving the redevelopment or change of use of existing premises, to uses not related to the port or the Lake Lothing Third Crossing will not be permitted.

Policy WLP8.21 - Support

Parts of this Policy meet the tests of soundness and are supported by the County Council.

The County Council welcomes the priority which is given to sustainable modes of travel. Furthermore, the County Council welcomes the commitment to the Suffolk Guidance for Parking (2014 and subsequent updates).

The Policy also recognises the need to consider cumulative transport impacts, which is important. The Planning Practice Guidance sets out what needs to be considered within transport assessments. Transport assessments for individual proposals in Waveney should also consider the issues of cumulative impact which are identified in the Report.

Policy WLP8.21 – Amendments Proposed

This part of the Plan does not meet the tests of soundness. This part of the Plan is unsound because it is not effective and not consistent with national policy.

In setting out thresholds for transport statements, transport assessments and travel plans, the District Council appears to have given regard to the 2007 Department for Transport guidance on Transport Assessment. Whilst no longer in place, this guidance does still represent useful indicative thresholds for the consideration of highway impacts.

However, the Planning Practice Guidance states that ‘all developments that generate significant amounts of transport movement should be supported by a Transport Statement or a Transport Assessment’ and that ‘Local planning authorities must make a judgement as to whether a development proposal would generate significant amounts of movement on a case by case basis’. It then goes on to set out some considerations for determining whether a Transport Assessment or Transport Statement is required.

Whilst the thresholds set out are not inappropriate, they are better described as ‘indicative’. This would provide a steer for developers and the local planning authority, without being prescriptive.

It is also unclear why the policy sets thresholds for residential development, but not non-residential development.

It is therefore proposed that the policy is amended as follows:

In consultation with the Highway Authority, the scale, location and nature of development will be considered in determining how the transport impacts of development should be assessed. As indicative thresholds, Transport Statements will be required for residential development between 50-80 dwellings. Transport Assessments and Travel Plans will be required for residential developments larger than 80 dwellings. Non-residential development will be considered on a case by case basis.

In addition, it is not clear what the policy means by ‘significant adverse’ highway impacts. The test in the NPPF is set out in paragraph 32 – that development should only be prevented when the ‘residual cumulative impacts of development are severe’. It is not clear if this policy is seeking to set a different standard to the NPPF, or to seek a wider consideration of transport impacts, beyond junction capacity and highway safety.

In commenting on planning applications, the County Council will advise the District Council as to the highway impact of a proposal. The District Council, as planning authority, will be responsible for judging whether or not the policy test in WLP8.21 has been met.

It is proposed that the District Council either amends the policy to link to the NPPF test of ‘severe’ or explains in supporting text what ‘significant adverse’ means for the purposes of determining applications.

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I hope that these comments are helpful.

Given the County Council’s status and obligations under the Duty to Cooperate, and its role as a major infrastructure provider, the County Council’s participation and provision of specialist expertise on a number of topics is likely to be helpful to the process of the examination. We would be pleased to support the process of the examination, and in support of the District Council.

We will discuss the practicalities of this with Waveney District Council colleagues and the Programme Officer (when appointed).

Yours sincerely,

Robert Feakes Senior Planning and Growth Officer Growth, Highways and Infrastructure Directorate

Appendix 1: Early Education Provision

This table sets out the County Council’s strategy for ensuring that early education places can be provided to meet demands arising from the sites allocated in this Plan.

Area/Wards Sites Dwellings Baseline – Approximate Potential mitigation existing demand for capacity, places arising summer 2018 from allocations Lowestoft Area Whitton and WLP2.4 – Kirkley 1380 -30 174 Up to 3 new settings may be required. Kirkley Waterfront and Sustainable Urban One will be delivered as part of the Neighbourhood primary school identified in WLP2.4.

WLP2.6 – Western End of 57 County Council will explore the potential Lake Lothing for establishing additional settings at existing primary schools (e.g. Phoenix St Peter Academy, within Kirkley Ward). It is also possible to consider the delivery of a new setting within employment land, where adjacent uses are suitable. Harbour WLP2.8 - Former 45 60 5 At present, sufficient capacity exists to Lowestoft Hospital) absorb the children emanating from this development. Were the capacity to be used up, the County Council would consider expanding existing settings. Gunton and WLP2.13 – North of 1300 55 166 Up to 3 new settings may be required. Corton Lowestoft Garden Village One will be delivered as part of the WLP2.20 – Gunton Park, 65 primary school identified in WLP2.13. off Old Lane, Corton The policy also makes provision for an additional setting within the local centre.

The need for, and location of, a third setting will be considered through the

Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX www.suffolk.gov.uk masterplanning process.

Oulton WLP2.14 – Land North of 150 -61 42 The scale of development, allied to Union Lane existing deficits in provision, is such that the most sensible solution would be to WLP2.15 – Land between 190 open a new setting. However, despite Hall Lane and Union Lane discussion since the previous consultation stage, our authorities have not identified a location where provision could be made.

Without an indicative strategy, identifying a location for a new setting, the Plan is not sound as it is not positively prepared, consistent with national policy or effective.

The County Council would appreciate the opportunity to discuss this further, prior to examination hearings. Carlton WLP2.16 – Land South of 900 -113 109 The scale of development is such that it Colville the Street, Carlton Colville is likely that two additional settings will be required.

One will be established at the new primary school identified within Policy WLP2.16, although the policy should be modified to enable this – increasing the area of land identified for education from 2ha to 2.2ha. Other site allocation policies also make reference to the early years setting within the policy – the District Council should consider introducing this as a further amendment.

It is intended to investigate the

establishment of a second setting at the existing primary school – Carlton Colville Primary School. This would be subject to resolution of the existing traffic issues at the school site, via the car park identified in the illustrative masterplan. Beccles and Worlingham Beccles WLP3.1 – Beccles and 1,250 Beccles North: 185 The scale of growth makes it likely that North, Worlingham Garden -31 three additional settings will be required. Beccles Neighbourhood Beccles South: South, -75 Policy WLP3.1 makes provision for two Worlingham WLP3.2 – Land West of 280 Worlingham: of these three settings, which is likely to (part) London Road, Beccles -42 be commensurate with the level of housing proposed. However, the Total: -148 allocation for the primary school needs to be increased to 2.2ha to enable the provision of early education facilities.

A third setting is likely to be required. The County Council will work with existing primary schools in Beccles to consider establishing a setting alongside primary education, but this cannot be guaranteed. Therefore, given the size of this site, policy WLP3.2 should include provision for a setting to enable this, should it be required. Halesworth and Holton Halesworth WLP4.1 – Halesworth 215 -6 59 The scale of growth is sufficient to (with parts Healthy Neighbourhood justify establishing a new early years Blything and setting. The Saints) WLP4.2 – Land adjacent 200 to Chediston Street, Provision is made for this within Halesworth WLP4.5.

WLP4.3 – Land north of 10

Old Station Road, Halesworth

WLP4.4 – Land west of 15 Lodge Road, Holton

WLP4.5 – Dairy Farm at 40 Saxons Way, Halesworth Bungay Bungay WLP5.1 – Land West of St 400 6 59 The scale of growth is sufficient to John’s Road, Bungay justify establishing a new early years setting. WLP5.2 – Land East of St 85 John’s Road, Bungay Provision is made for this within WLP5.2. Southwold and Reydon Southwold WLP6.1 – Land West of 220 89 27 At present, it appears that the scale of and Reydon Copperwheat Avenue, development, allied to existing capacity Reydon in the area, means that a new early years setting will not be required. This will be kept under review, as available capacity is subject to change. Rural Areas Worlingham WLP7.2 – Land between 50 -42 6 The County Council’s preference is to The Street and A146, seek expansion of existing settings. Barnby Lothingland WLP7.3 - 16 17 14 At present, it appears that the scale of Land south of Lound development, allied to existing capacity Road, Blundeston in the area, means that a new early years setting will not be required. This WLP7.4 – Land North of 45 will be kept under review, as available Pickwick Drive, capacity is subject to change. Blundeston

WLP7.5 – Land North of 10 The Street, Somerleyton

WLP7.6 – Mill Farm Field, 35 Somerleyton

WLP7.12 – Land East of 10 The Street, Lound

Blything WLP7.7 – Land North of 16 -21 5 The County Council’s preference is to Elms Lane, Wangford seek expansion of existing settings in adjacent wards. WLP7.17 – Land west of Lock’s Road, Westhall 18 Wrentham WLP7.8 – Land north of 60 -60 15 The County Council’s preference is to Chapel Road, Wrentham seek expansion of existing settings.

WLP7.9 – Land South of 50 Southwold Road, Brampton

WLP7.10 – Land at 8 Toodley Farm, Station Road, Brampton The Saints WLP7.11 – Land south of 25 -37 5 The County Council’s preference is to Hogg Lane, Ilketshall St seek expansion of existing settings. Lawrence

WLP7.15 – Land east of 15 Mill Road, Rumburgh Wainford WLP7.13 – Land north of 6 -28 6 The County Council’s preference is to Chapel Road, Mutford seek expansion of existing settings.

WLP7.14 – Land north of 30 School Road, Ringsfield

WLP7.16 – Land North of 10 Woodfield Close, Willingham

Appendix 2: Primary School Provision

This table sets out the strategy for ensuring provision of primary school places for children emanating from the development proposed in this Plan.

Current Catchment Residential Sites Dwellings/Children Strategy Emanating from Development Lowestoft Area Dell Primary/Red Oak Primary WLP2.4 – Kirkley Waterfront 1,380 dwellings / 345 children Needs to be met by new and Sustainable Urban school identified on site Neighbourhood WLP2.4. IDP identifies that new school should be funded through Section 106. Whilst the reference to a school site in Policy WLP2.4 is welcomed, the reference to a 1.5 form of entry school should be amended. This size of school (315 children) would not be sufficient to mitigate the impact of all development. The policy should instead refer to a 2.2ha school site – enabling development of a 2 form of entry school (420 places) plus early years provision, which would provide sufficient capacity for the entire allocation, plus site WLP2.6 and some capacity to support future growth.

Whilst this site has permission, the policy should be updated to reflect current practice should the permission lapse and a new permission be sought.

Dell Primary WLP2.6 – Western End of Lake 57 dwellings / 14 children Within the catchment of Dell Lothing Primary. This school is forecast to be in deficit, hence a contribution via CIL to provide additional places is likely to be required. If Dell Primary cannot be expanded, provision could be made at the new primary school on site WLP2.4. St Margaret’s Primary WLP2.8 – Former Lowestoft 45 dwellings / 11 children Within the catchment of St Hospital Margaret’s Primary School. This school is not forecast to have capacity to accept the children emanating from the development. If designed careful, it is likely that this school can be expanded using CIL contributions. Corton Primary School WLP2.13 – North Lowestoft 1,300 dwellings / 325 children Needs to be met by new Garden Village school identified on site WLP2.13. IDP identifies that a new school should be funded through Section 106. 2.2ha land should be identified to meet the needs of a 2 form of entry school and pre-school. Gunton Primary Academy WLP2.20 – Gunton Park, off 65 dwellings / 16 children Gunton Primary School is not Old Lane, Corton forecast to have capacity and is not considered able to expand, however the site is located close to the catchment for Corton Primary School (which has some spare places – potentially enough to accommodate this development) and will also be in reasonable proximity to the

school to be delivered on WLP2.13. Woods Loke Primary WLP2.14 – Land North of 150 dwellings / 38 children Rather than expand Woods Union Lane Loke to accommodate this development it would be WLP2.15 – Land between Hall 190 dwellings / 48 children preferable to expand The Lane and Union Lane Limes – the new school in Oulton due to open in September 2018. The new school has been designed to enable additional expansion. Carlton Colville Primary WLP2.16 – Land South of the 900 dwellings / 225 children Needs to be met by new Street, Carlton Colville school identified on site WLP2.16. IDP identifies that new school should be funded through Section 106. The policy specifies a 2ha school site – this should be amended to 2.2ha to allow an early years setting to be provided on the school site. Beccles and Worlingham Worlingham CEVC Primary WLP3.1 – Beccles and 1,250 dwellings / 313 children Needs to be met by new and Beccles Primary Academy Worlingham Garden school identified on site Neighbourhood WLP3.1. IDP identifies that new school should be funded through Section 106. The policy specifies a 2ha school site – this should be amended to 2.2ha to allow an early years setting to be provided on the school site. The Albert Pye School WLP3.2 – Land West of 280 dwellings / 70 children Albert Pye school cannot be London Road, Beccles expanded. The long term strategy would be to review catchment boundaries to enable capacity to be provided

at the new school on the strategic site. In the short term, it is likely that some pupils could be accommodated at existing schools. Halesworth and Holton Edgar Sewter Primary School WLP4.1 – Halesworth Healthy 215 dwellings / 54 children A total of 123 additional Neighbourhood children expected within these Holton St Peter Primary School school catchments. WLP4.2 – Land adjacent to 200 dwellings / 50 children Chediston Street, Halesworth Both schools are likely to require some expansion, to be WLP4.3 – Land north of Old 10 dwellings / 3 children funded through CIL, with the Station Road, Halesworth majority of additional places likely to be provided at Edgar WLP4.4 – Land west of Lodge 15 dwellings / 4 children Sewter school in Halesworth. Road, Holton

WLP4.5 – Dairy Farm at 40 dwellings / 10 children Saxons Way, Halesworth

WLP7.15 – Land East of Mill 10 dwellings / 3 children Road, Rumburgh Bungay Bungay Primary School WLP5.1 – Land West of St 400 dwellings / 100 children Current forecasts suggest that John’s Road, Bungay Bungay Primary School has some spare capacity, sufficient WLP5.2 – Land East of St 85 dwellings / 21 children to accommodate c. 106 John’s Road, Bungay additional pupils whilst maintaining 5% places spare, or 122 pupils if the school were to reach 100% capacity (which is not recommended).

A change in parental preferences could result in space not being available to

serve development. The County Council would explore expansion on site, to be funded by CIL, but expansion could necessitate relocation of the school. Not only would this be expensive, the former middle school site is not currently available to enable this to take place.

To manage this risk, the level of growth at the two sites could be reduced, or the policy allocating site 5.2 could be amended to ensure that the phasing of development and housing mix enables primary school places to be delivered. For example – provision of 1 bed dwellings will reduce the number of school places required. Provision of specialist housing for older people would also reduce the need for school places. This is considered a proportionate response to the issue, given that school forecasts may change and that options exist for providing school places.

Southwold and Reydon Reydon Primary School WLP6.1 – Land West of 220 dwellings / 55 children Whilst it is currently forecast Copperwheat Avenue, Reydon that there is some available (Also Southwold Primary capacity at Reydon and School, nearby) WLP7.7 – Land north of Elms 16 dwellings / 4 children Southwold primary schools, it

Road, Wangford is not sufficient to accommodate the level of WLP7.8 – Land north of 60 dwellings / 15 children growth within the Reydon Chapel Road, Wrentham catchment. There is no scope to expand Southwold Primary School, and Reydon could only be expanded if adjacent land were secured.

The County Council is investigating the acquisition of land to enable the expansion of Reydon Primary School. However, if it cannot be secured, the result would be that pupils are displaced into neighbouring catchments – Brampton, Wenhaston and Bramfield. This would represent a less sustainable pattern of development. Rural Areas Barnby and North Cove WLP7.2 – Land between The 6 dwellings / 2 children It expected that these children Primary Street and A146, Barnby could be accommodated at the catchment school through WLP7.13 – Land North of 50 dwellings / 13 children expansion on its existing site. Chapel Road, Mutford Blundeston CEVCP WLP7.12 – Land East of the 10 dwellings / 3 children The school is forecast to Street, Lound exceed capacity due to housing development being WLP7.3 – Land South of Lound 16 dwellings / 4 children delivered at Woods Meadow. Road Following the opening of The Limes in September 2018, it is WLP7.4 – Land North of 45 dwellings / 11 children expected that capacity will be Pickwick Drive, Blundeston available. However, should the school need to expand, the County Council could

investigate the acquisition of adjacent land to enable this to happen. Brampton Church of England WLP7.9 – Land South of 50 dwellings / 13 children The school has potential to Primary Southwold Road, Brampton expand to accept the additional children arising within WLP7.10 – Land at Toodley 8 dwellings / 2 children catchment, and may also need Farm, Station Road, Brampton to expand to meet needs arising from development in WLP7.16 – Land East of 10 dwellings / 3 children nearby Wangford. Woodfield Close, Willingham Ilketshall St Lawrence School WLP7.11 – Land South of 25 dwellings / 6 children Ilketshall St Lawrence has Hogg Lane, Ilketshall St sufficient space on site to Lawrence expand to accept additional pupils from development within WLP7.17 – Land West of 18 dwellings / 5 children its catchment. Lock’s Road, Westhall Ringsfield Church of England WLP7.14 – Land North of 30 dwellings / 8 children Ringsfield Primary has Primary School Road, Ringsfield sufficient space on site to expand to accept additional pupils from development within its catchment. Somerleyton Primary School WLP7.5 – Land North of The 10 dwellings / 3 children Based on current forecasts, it Street, Somerleyton may not be possible to accept all additional pupils from WLP7.6 – Mill Farm Field, 35 dwellings / 9 children development at the catchment Somerleyton school. A significant number of current pupils come from out of catchment. Based on current forecasts, this scale of development may displace a small number of pupils (c.3-6) to their catchment schools, most likely the new school at Woods Meadow (The Limes) or Blundeston.

Appendix 3: Secondary School Provision

This table sets out the strategy for ensuring provision of secondary school places for children emanating from the development proposed in this Plan.

For development within the catchments of Sir John Leman (Beccles) and Bungay High Schools, it is envisaged that post-16 (Sixth Form) provision will be made at those schools respectively. This impact has been factored in to the calculations. For other areas, provision is made at East Coast College (formerly Lowestoft College).

Current Catchment Residential Sites Dwellings/Children Emanating Strategy from Development (aged 11-16 unless stated) Benjamin Britten WLP2.13 - North of Lowestoft Garden 1300 dwellings / 234 children Benjamin Britten Academy is Academy Village 150 dwellings / 27 children considered able to expand to meet WLP2.14 - Land north of Union Lane, 190 dwellings / 34 children this demand. The school is forecast Oulton 10 dwellings / 2 children to have some available places, but WLP2.15 - Land between Hall Lane 16 dwellings / 3 children the site size is sufficient to enable and Union Lane, Oulton 45 dwellings / 8 children significant expansion – in theory WLP7.12 - Land east of The Street, 10 dwellings / 2 children sufficient for at least a 1,750 place Lound 35 dwellings / 6 children secondary school – expected to be WLP7.3 - Land south of Lound Road, more than is required for the level of Blundeston growth within the catchment. This WLP7.4 - Land north of Pickwick Drive, level of expansion was discussed in Blundeston January 2018 with the headteacher WLP7.5 - Land north of The Street, who was supportive in principle. Somerleyton WLP7.6 - Mill Farm Field, Somerleyton Ormiston Denes WLP2.8 - Former Lowestoft Hospital 45 dwellings / 8 children This school is forecast to have some Academy WLP2.20 - Gunton Park, off Old Lane, 65 dwellings / 12 children spare capacity – likely to be Corton sufficient to absorb these additional pupils without a need for expansion. However, Ormiston Denes Academy catchment area borders some of the allocated sites within Benjamin Britten Academy’s catchment, so the school could be considered for taking some pressure off Benjamin

Britten. The site size is theoretically large enough for a 1,700 place secondary school. This level of expansion was discussed in January 2018 with the headteacher who was supportive in principle. East Point Academy WLP2.4 - Kirkley Waterfront and 1380 dwellings / 248 children ESFA are rebuilding to 900 places. Sustainable Urban Neighbourhood 57 dwellings / 10 children The site is large enough for further WLP2.6 - Western End of Lake Lothing expansion and once confirmation of the rebuild is received discussions with the school will take place to understand how any further expansion could take place. It should be noted that, at present, significant numbers of pupils from the East Point Academy catchment travel to Beccles for secondary education. Should this trend change, a new strategy would have to be developed. Pakefield WLP2.16 - Land south of The Street, 900 dwellings / 162 children Not possible to expand. These new Carlton Colville pupils would need to go to East Point Academy which would need expansion. Sir John Leman High Sir John Leman is an 11-18 school Total growth (11 to 18 year olds) is School (Beccles) and these pupil numbers cover that expected to be 436 additional age range pupils. Sir John Leman High School and has no additional capacity but has been identified as being able to Beccles Free School 1250 dwellings / 275 children expand to provide an additional 244 WLP3.1 - Beccles and Worlingham 280 dwellings / 62 children places (to be a 1,450 place school). Garden Neighbourhood 220 dwellings / 48 children Beccles Free School has been WLP3.2 - Land west of London Road, 8 dwellings / 2 children identified as able to expand by 124 Beccles 6 dwellings / 1 child places which could accommodate WLP6.1 - Land west of Copperwheat 30 dwellings / 7 children some of the new pupils. The site Avenue, Reydon 10 dwellings / 2 children size is 5.79 hectares so in theory WLP7.10 - Land at Toodley Farm, 50 dwellings / 11 children this is enough land for a 750 place

Station Road, Brampton 16 dwellings / 4 children secondary school. This level of WLP7.13 - Land north of Chapel Road, 60 dwellings / 13 children expansion was discussed in Mutford 50 dwellings / 11 children January 2018 with the headteachers WLP7.14 - Land north of School Road, who were supportive in principle. Ringsfield This means that some new pupils WLP7.16 - Land east of Woodfield may have to be accommodated in Close, Willingham other schools, most likely Bungay WLP7.2 - Land between The Street High School. and A146, Barnby WLP7.7 - Land north of Elms Lane, Wangford WLP7.8 - Land north of Chapel Road, Wrentham WLP7.9 - Land South of Southwold Road, Brampton Bungay High School Bungay High School is an 11-18 The school has some available school and these pupil numbers capacity. The school is currently 900 cover that age range 11-16 places plus a sixth from of 150 (1,050 in total) on its current 215 dwellings / 47 children site. BB103 guidance shows that a WLP4.1 - Halesworth Healthy 200 dwellings / 44 children school of 1,050 places 11-16 plus a Neighbourhood 10 dwellings / 2 children sixth from approaching 200 would WLP4.2 - Land adjacent to Chediston 15 dwellings / 3 children require a site of approximately 8 Street, Halesworth 40 dwellings / 9 children hectares so an additional 1.5 WLP4.3 - Land north of Old Station 85 dwellings / 19 children hectares is required. To further Road, Halesworth 400 dwellings / 88 children futureproof the school to allow for WLP4.4 - Land west of Lodge Road, 25 dwellings / 6 children additional growth in the future Holton 10 dwellings / 2 children expansion of 1200 11-16 plus 300 WLP4.5 - Dairy Farm at Saxons Way, 18 dwellings / 4 children sixth form (1,500) would require Halesworth circa 9.4 hectares so an additional WLP5.1 - Land east of St Johns Road, 2.75 ha. To enable this to happen, Bungay an amendment is proposed to policy WLP5.2 - Land west of St Johns Road, WLP5.2 – increasing the land for the Bungay school site extension by 0.75 of a WLP7.11 - Land south of Hogg Lane, hectare. Ilketshall St Lawrence WLP7.15 - Land east of Mill Road,

Rumburgh WLP7.17 - Land west of Lock's Road, Westhall