Babergh and Mid Suffolk Joint Local Plan Public Examination Hearing Statement Matter 4 – Settlement Hierarchy, Spatial Distribution of Housing and the Housing Site Selection Process Stage 1 – Week 3 June 2021 21-22 July 2021 Artisan Ref: A4273 Date Version Author Checked by 03.06.2021 1 Max Short LLB(Hons) LLM AssocRTPI Leslie Short BA MRICS MRTPI Artisan does not accept any liability for the use of any information or advice contained in this report by third parties or any loss or damage caused by its unauthorised use. Artisan Planning & Development Consultants is a trading name of Artisan Planning & Property Services Ltd Director: Leslie Short BA MRTPI MRICS Berwick House Homechurch Baylham Suffolk IP6 8RF 01473 832995 [email protected] www.artisan-pps.co.uk Registered in England & Wales No. 077999008 Babergh and Mid Suffolk Joint Local Plan Examination Hearing Statement – Matter 4 Contents 1. Introduction ........................................................................................................... 2 2. Question 4.1 ......................................................................................................... 3 Appendices ..................................................................................................................... 7 Appendices Appendix 1 2017 Settlement Hierarchy Review Appendix 2 2018 Settlement Hierarchy Review Artisan Ref: A4273 Page 1 Babergh and Mid Suffolk Joint Local Plan Examination Hearing Statement – Matter 4 1. Introduction 1.1 This Hearing Statement is submitted in respect of Matter 4 – Settlement Hierarchy, Spatial Distribution of Housing and Housing Site Selection Process. 1.2 The majority of Artisan’s contributions will be made during the discussion at the Hearing. This Hearing Statement, therefore, only seeks to provide further detail in response to one of the Inspectors’ questions. The question is 4.1: Has the settlement hierarchy set out in Tables 2 and 3 been derived using a robust and objective process? 1.3 The simple answer is that the process used to derive the settlement hierarchy is neither robust nor objective. While the following section sets out some detail to demonstrate why, it is intended that Artisan will expand upon the points at the Hearing. Some specific examples are provided but they are by no means the only occasions where errors or flaws are present. Artisan Ref: A4273 Page 2 Babergh and Mid Suffolk Joint Local Plan Examination Hearing Statement – Matter 4 2. Question 4.1 2.1 There are a number of anomalies contained within the latest settlement hierarchy review, in terms of the method as well as the scoring of individual settlements. The consequence of correcting these errors is that several settlements will need to be reclassified. This in turn will require a total review of the strategic policies of the Plan. The frequency of change in the scoring of settlements across successive years is also concerning. Method 2.2 Turning to the method used to classify settlements, there are several flaws and errors insofar as the scoring is concerned. However, we first turn to some general observations. General Observations 2.3 It is noteworthy that the Councils have produced three settlement hierarchy reviews: the first in 2017 (Appendix 1 to this Statement), the second in 2019 (Appendix 2) and the third in 2020 (JLP Doc EP01). The most surprising difference is that each review has a different number of settlements. Another surprising difference between the version is that distances between settlements appear to change. Settlements that have scored points in 2017 for proximity to a Town/Urban Area or a Core Village do not score them in the later versions. 2.4 While we note that paragraph 1.4 of the 2020 review (EP01) states that it responds to comments received during consultations, there is no explanation as to how the definition of a ‘settlement’ has changed from one iteration to the next. We have no way of assessing whether this process has been objective or whether the Councils are responding to local and/or political pressure to downgrade settlements to avoid a level of growth deemed undesirable. Assessment of Services & Facilities 2.5 Paragraph 2.2 of EP01 states that the Review only assesses the services and facilities available in that settlement rather than in the wider parish. However, there are two problems with this. The first problem – Inconsistent Assessment 2.6 Firstly, there is no consistency in the way in which some settlements have been divided into clusters. Some smaller groups of settlements are assessed collectively, whereas others that are closer together are assessed separately. 2.7 For example, Walsham-le-Willows, Brantham, East Bergholt and Long Melford all have multiple parts to the settlement but are assessed collectively as Core Villages. By contrast, other settlements, which were Core Villages in the 2017 assessment, have been split up and assessed separately such that they have been downgraded. Artisan Ref: A4273 Page 3 Babergh and Mid Suffolk Joint Local Plan Examination Hearing Statement – Matter 4 2.8 A good example of this is Chelmondiston. In 2017, Chelmondiston scored ‘21’ and was thus designated a Core Village (18 being the minimum required for a core village). However, in 2019 and 2020, Chelmondiston has been split into multiple parts, including Pin Mill. The result is that Chelmondiston now scores 17, just 1 point below the threshold. 2.9 Moreover, these settlements are so close together that they should be considered as one. Figure 2.1 below demonstrates how close the settlement boundaries are. It is only a matter of metres between the settlement boundaries. Compared to, for example, East Bergholt, where the components are much further apart, it cannot be objective or robust to carve up Chelmondiston or any other village in this way. Fig 2.1 Proximity of Chelmondiston Settlement Boundaries Artisan Ref: A4273 Page 4 Babergh and Mid Suffolk Joint Local Plan Examination Hearing Statement – Matter 4 2.10 Similarly, Great Waldingfield scored 21 points in the 2017 review, but it too has been carved up into multiple clusters. Great Waldingfield also now sits on 17 points. However, there is no logical distinction between assessing the Church and Upsher Green clusters as one, when they are just as close to the main part of the Great Waldingfield village. This further indicates that settlements are being split in order to fit a preferred, predetermined strategy. Accordingly, the process is not objective nor is it robust. The second problem – No relationship between lower tier settlements 2.11 At paragraph 2.3 of the 2017 review (Appendix 1), the Councils fully embraced the interconnectivity of rural settlements. It states: Where a facility can be found within the built up area of the village, points are scored irrespective of the exact location of the facility. Where an adjacent village can make use of a facility i.e. it is within walking or cycling distance, that village can also score points for that particular service. Furthermore, some facilities are located quite a distance from any village but could still count if within walking or cycling distance. 2.12 This approach fully embraces NPPF78. However, the 2019 and 2020 version of the settlement review, and therefore the JLP itself, has abandoned that approach. Some services and facilities within walking/cycling distance are discounted from settlements, while others are now separated through carving up a village into multiple settlements. For example, Old Newton, Chelmondiston and Great Waldingfield. 2.13 In the case of Old Newton, which is currently scored at 16 points, it is only 550m from the ‘Old Newton – Church’ hamlet. This contains a primary school and a church that is plainly well related to the main part of the village. When the settlements are looked at as one settlement, Old Newton would/should be classified as a Core Village, as it was during the Council’s 2017 review. 2.14 The artificial separation is even more apparent in Chelmondiston where the settlement boundary is a matter of metres from the allotments in the Chelmondiston – Pin Mill’ hamlet. As 1 point is scored for allotments, this would elevate Chelmondiston to a Core Village. 2.15 Therefore, it is submitted that the Councils have carved up settlements in order to fit its preferred outcome. Artisan does not have the resources to re-assess each and every settlement in the review, but we have seen enough to indicate that the method used to produce the settlement hierarchy is not objective and it is not robust. 2.16 The Councils need to reconsider those settlements that have been split up in order to knock them down the hierarchy. Alternatively, the Councils need to revisit the interconnectivity between rural settlements as per the 2017 review. NPPF78 is clear that services in one village can support another village. There is no logical discrimination between scoring proximity to a Artisan Ref: A4273 Page 5 Babergh and Mid Suffolk Joint Local Plan Examination Hearing Statement – Matter 4 Core Village but not scoring proximity to a Hinterland Village that may contain day-to-day services and facilities. In its current form, the JLP is not consistent with NPPF78. Omission of Rural Services 2.17 Some settlements benefit from services that have been developed specifically for their rural nature. For example, while Gislingham does not have a permanent Post Office, it (amongst others) benefits from a mobile service twice a week. The Councils do not appear to have given any consideration to this type of service. Incorrect Scoring 2.18 A number of settlements have not been scored correctly. For example, the primary school in Stoke-by-Nayland also runs a nursery and therefore provides a pre-school service/facility. It should receive an additional point and therefore be elevated to a Core Village. Fressingfield and Old Newton both have sports clubs and should be scored accordingly. 2.19 As noted above, Artisan does not have the resources to re-assess every settlement.