SPROUGHTON WORKING GROUP
Strategic Planning Policy Team, Sproughton Working Group Babergh and Mid Suffolk District s, Endeavour House, 8 Russell Road, Ipswich IP1 2BX
30 September 2019
Dear Sirs,
BABERGH & MID SUFFOLK JOINT LOCAL PLAN CONSULTATION (SEP19) – SPROUGHTON WORKING GROUP RESPONSE
Sproughton Working Group (SWG) has reviewed the new version of Babergh/Mid Suffolk Joint Local Plan Consultation. The response is not just the views of the Working Group but consolidates the feedback we have received from residents and parishioners. If you require clarification on any point please do not hesitate to contact us.
1. General Comment 1.1. While recognising national imperatives and the constantly changing state of Government planning policy, SWG considers that the Joint Local Plan (JLP) leaves too many policies open to interpretation hence providing ‘wiggle-room’ for developers which they will use to drive a ‘coach & horses’ through the policies likely resulting in inappropriate and unsustainable development. As a result, the document as a whole is flawed. 1.2. We hope that BMSDCs will progress to meaningful, detailed discussion of key points raised by the Working Group and parish councils across the region as part of this consultation process resulting in policies that can lead to greater confidence in the ability of BMSDC to make the right decisions for people living in the area. 1.3. We understand that what local people want is not always what policy makers believe the wider community needs. Nevertheless, much more can be achieved with the enthusiasm and support of local communities than with the adversarial approach that has typified recent planning proposals. The only way of achieving that aim is by listening to communities and embodying neighbourhood needs and aspirations into a unifying vision within the JLP. 1.4. SWG believe that creating a vision for a sustainable future depends on a grass roots approach. This means taking full account of the types of community to which people aspire before creating policy that can best fit national targets to the local vision. To achieve this delicate balance many parishes in other parts of England conduct more primary research and provide greater transparency throughout the planning process. One benefit of such research is to establish the parameters under which development should take place, at an early stage. 1.5. SWG intends this response to be a constructive step towards such a vision and that it becomes a realistic objective. 1.6. SWG feel that the vision should at the very least include the following objectives:
SPROUGHTON WORKING GROUP
1.6.1. Babergh and Mid Suffolk should remain attractive, largely rural areas with thriving towns and villages a visually appealing, varied landscape. 1.6.2. Towns and villages should each retain their distinct characters. Coalescence of settlements will be avoided. 1.6.3. Growth should be proportionate and not dominating to preserve those distinct communities and the best of the counties landscape. 1.6.4. Effective use should be made of previously developed land to minimise the need to build on greenfield sites. Some progress has been made on this 1.6.5. Wherever new housing is provided, it should respond to identified local needs including in relation to type, size, affordability and tenure. 1.6.6. All new housing should be to the highest design standards both visually, in the context of local character, and in environmental performance. 1.6.7. The adverse impact of new housing developments such as traffic congestion, air pollution and social cohesion should be minimised through the scale and location of developments and the enhancement wherever needed of physical, social and environmental infrastructure. We feel this is especially important for the A1071 and B1113 where we feel all new developments including commercial developments, benefitting from the route into Ipswich should contribute proportionately to junction, traffic management improvements and a link/access to the A14 that avoids the congested Copdock A14/A12 interchange. 1.6.8. Natural, built & heritage assets should be protected and, wherever possible, enhanced. 1.6.9. Housing Growth to match actual Employment/commercial growth, not the other way round, and actual not envisaged with Employment/commercial growth being driven by proactive policies like incentives and improved infrastructure that will actually drive growth and not just an assumption that if property is put forward business will come. 1.7. Subjective & Objective Policies 1.7.1. If a Planning Committee rejects a planning application one of the first questions posed is against what policy? 1.7.2. The next consideration is whether the rejection under the chosen policy provides a sound foundation to defend against a legal challenge at appeal or otherwise. 1.7.3. If an applicant feels they have a legal argument they are likely to proceed to appeal potentially at a significant cost to the public purse. 1.7.4. What is more if they have a weak legal case the process will be futile and even more costly if the applicant can recover their legal costs. 1.7.5. These are serious considerations in costly legal processes that may just represent a pointless and significant waste of public taxes and quite rightly may well have to weigh up the adverse impact on the funds against the adverse impact of the seriousness of breach of policy. 1.7.6. Objective policies bring clarity to this, subjective policies do not and provide fertile ground for legal argument to appeal. 1.7.7. This new JLP appears to have rid itself of much objective policy, some of it specific to dedicated sites or areas, some to specific issues, against an argument that these were too inflexible, and the LPA process is better advised by subjective consideration of each individual applications unique circumstances. 1.7.8. However, what will happen when an applicant spends months, even years consulting planning officers to construct an acceptable application based on these subjective policies but a Planning Committee views these policies differently and rejects it? 1.7.9. The contradictory opinions of subjective policy would support legal arguments for appeal and county councillors would be futilely wasting the public purse to pursue the matter. In effect the creation of so much subjective policy will hamstring democratically elected county councillors from pursuing their proper duty in a democratic process to properly represent their electorate.
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1.8. Saved Policies 1.8.1. We are concerned about adherence to a democratic process in relation to current developing sites. When main policy documents have been updated in the past policies still relevant have been retained for their specific purpose. 1.8.2. Where an application is approved by a Planning Committee on a site which has specific policies applicable due to its sensitivity or scale of impact it is expected that those policies will be applied. Where the site approval is at a halfway stage like outline planning approval then that adherence should endure, or it conflicts with the terms under which the Planning Committee gave its approval. This is especially important where objective policies under the present Local Plan/Core Strategy are replaced in the new JLP with subjective policies. 1.8.3. In the past dedicated policies still relevant have been retained but I have found no such list and it is unacceptable that dedicated and previously retained policies deliberately constructed to be more restrictive than general policies to protect specific sensitive sites etc. appear to have been thrown away. This creates a situation where a new application on a sensitive site that was only approved with an expectation of adherence to those specific policies is now potentially possible without any such adherence. 1.8.4. Wolsey Grange 2 was approved against the requirements of CS7 and other policies applicable to the area the site was located in. However only phase 1 was approved as a full planning application under the dedicated policies and the rest of the site only as an outline planning permission. 1.8.5. The new Policy specific to the site LA014 makes no reference to Policy CS7, or for that matter the landscape policies applicable when the outline planning application was approved. That means that Phase 2 and 3 could come forward in a design that would not have been acceptable when the Outline Planning application was approved. 1.8.6. A similar situation exists for LA018 Sproughton Enterprise Park where the dedicated requirements of EM04 under present policy in the Local Plan presently apply. Most of the site still awaits development but has obtained outline planning approval under EM04 etc. 1.8.7. However, the specific policy EM04 or its wording has not been retained alongside LA018 which potentially removes the specific obligations on any development on the site expected by the Planning Committee. 1.8.8. These are very important for the reasonable development in the public interest as they restrict the adverse impact on the nearby residential amenity and require protection of the associated natural environment and enhancement of recreational value. In effect LA018 dissolves the ecological and environmental obligations of any new developer below the higher standard of EM04 that was expected when this site came forward and was given approval. 1.8.9. This is a matter that goes back historically some time for good reason because the owners of the site many years ago applied for a licence to quarry the island site and that was only granted on an undertaking it would be returned to nature which they did creating lakes and planting new trees on the island. 1.8.10. Since I haven’t found a list of retained policies, I suspect this may be the case in many other parishes in relation to many previously carefully considered sensitive issues.
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2. Part 1: 03 Vision and Objectives 2.1. The government set targets for growth that set the requirements for housing needs, however this JLP is described as an ambitious plan and clearly goes beyond the identified need. Whose ambition is it to go beyond the recognised needs? because this does not mirror the ambitions and identified needs as it is apportioned to individual communities. This is a divisive and adversarial document disproportionately attacking a few parish councils and setting them up as sacrificial lambs for the benefit of others. 2.2. Rural communities are characterised by the additions of small individual developments which mirror our Parish Plan recommending individual developments of around 10 homes at a time. But what is coming forward are massive urban style estates of hundreds of houses of typical National Developer Style that matching or exceeding the size of established village settlements destroying their established village character. The only vision in this is a financial one, there is no vision to improve the heritage, Landscape, and character of the rural communities. 2.3. Wages and the ability to purchase homes in the rural areas are to low, this can only be rectified by improved wages or lower house prices. Expectations for the creation of more high-quality jobs is nothing more than ambition, there is no evidence to support this rather the opposite as new sites coming forward are more automated reducing employment needs as they abandon other sites to lay dormant. The only way that employment/wages potential will improve is if companies are attracted to the district away from other areas of the country. But this is a rural community and the aspirations of the rural community are to keep it rural which does not lend itself to a stampede of professional service providers. Even less so with an expensive inadequate rail link to London and overloaded inadequate road infrastructure. What is more, government supported development of the midlands and Northern Powerhouse areas makes this a competitive aspiration they are unlikely to win. 2.4. Therefore, the only way to bring down house prices in the rural areas where communities are struggling is to build more houses in those rural areas to adjust the supply and demand relationship. This JLP doesn’t do that, it focuses development on the Ipswich Fringe and other areas they appear to want to urbanise. The Environment vision is lacking in substance in the JLP: The previous policies were objective and clear with areas like the SLA’s clearly identifies. They have been replaced by subjective policies based on opinions that then may be indefensible even if the democratically elected county councillors do not agree. For instance, even the requirement for landscape impact reports is based on opinion. Since the understanding of flood risks increases almost daily it is not enough to avoid and reduce where possible - there should be a positive statement towards reducing flood risk. 2.5. Water companies are struggling to accommodate further development without over extracting water from water tables and rivers without ecological harm. 2.6. There is vision to reduce pollution including light pollution which has a significant effect on rural dark sky environments. Not just from new fixed lighting but by the impacts of headlight pollution of natural dark areas by vehicles introduced by new development. 2.7. So much of this document fails to put the horse in front of the cart. Visions of growth in employment and housing with no substance to tackle and create growth. Visions of important infrastructure that is needed now only as a tack-on financial contribution that might happen after developments have made critical inadequacies even worse. Simple things like plans for green infrastructure that only come in after development has destroyed the existing nature. There is a predominance of policy open to opinion at a personal level against mitigations by financial contributions to supported funds that may never be used to mitigate the communities affected. The Vision lacks proactive thinking, just a vision that ‘if they build, they will come’ with no actual objective policies or targets to proactively deal with environmental issues or infrastructure.
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2.8. This vision should support the Government's 25 Year Environment Plan published on 16th May 2019 proactively demonstrating with objective policies and clear targets enhancing beauty, heritage and engagement with the Natural Environment and achieving thriving plants and wildlife. 2.9. So much of this JLP, its vision and the policies proposed are just that a vision and ambition but written as a non-committal passport for planners to follow their opinions unhampered by objective policies based on the opinions of the democratically elected county councillors. The policies are supposed to be direction decided through a democratic process that represents the public interest.
3. Part 1: 04 Implementation 3.1. Another concern about the ‘ambitious’ vision for growth and expansion is that the data used is so old it does not account either for the Brexit Vote or its looming consequences. 3.2. The needs are therefore at best questionable and the ambitions potentially a fairy tale. The housing figures show OPP housing approved already at more than half of the government projected need and yet the appears desperate to approve everything now. There is no hold and checks in this JLP to ensure a progressive expansion over 18 years. As this document comes forward more housing than is needed will be built in just a few years, quite possibly the full quota could be approved by the next review in 5 years! Where will that leave us? That will either create an environmental disaster with half-finished abandoned urban estates scattered across the district, or a massive influx of people into the area creating an even bigger demand that will spread even further into the rural landscape. 3.3. The lack of Objective policy in this JLP threatens to undermine the democratic process. The purpose of planning policy to be approved by democratically elected county councillors should reflect what they and hopefully what the electorate they represent want and need. It should set clear guidance so that applications that come before planning committee conform to their collective opinion. The predominantly subjective nature of this document removes that direction and refers direction to opinions of unelected officers potentially creating in any case of objection a legally un-defendable difference of opinion. 3.4. If this JLP does appear unsuitable then approving it now potentially subjects communities and electorate to 18 years of conflict and exploitation. However, to reject this JLP will place the LPA in a position of not having an up to date Local Plan. It’s not an easy choice but we hope we are represented by strong people who will do what is right and fair.
4. Part 1: 05 Duty to Co-operate 4.1. Ipswich say they have insufficient land to meet their projected housing numbers which means under the ‘Duty to Cooperate’ all surrounding districts must assist in finding land to accommodate Ipswich’s housing overspill, not just Babergh. While this is understandable it should not be at the expense of Sproughton’s innate village character. 4.2. The concept of an Ipswich Fringe development area has been applied so disproportionately that almost a half of the necessary new applications required across a district of 75 parishes is proposed in one Parish, Sproughton. And even within the proposed Babergh’s Ipswich Fringe Area three quarters the JLP’s ambitions for new applications is proposed in Sproughton. This is disproportionate in the extreme and it is not supported by sufficient infrastructure to make this sustainable.
5. Part 1: Policy SP01 – Housing Needs
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5.1. Development must be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. Housing should be provided for a price that local residents can afford. Our recent Housing Needs Survey (questionnaire constructed in conjunction with Babergh) has concluded a total of 87 people need housing. That conflicts hugely with the 1600+ houses put forward – a significant percentage of the 7,560 houses that Babergh says is needed. In fact, the 7,560 houses include 4,036 which already have planning permission but not been built leaving 3,524 so technically Sproughton is picking up around 50% of the requirement.
5.2. This policy is very weakly worded and allows lots of room for interpretation of however people would like to use it. For example, “the new housing development will be expected to reflect established needs in the most relevant district needs assessment” – there are many assessments that can be completed on a Parish level to show a proven local need by the way of Neighbourhood Plans and Housing Needs Surveys. We have recently completed a Housing Needs Survey in Sproughton which describes our proven Housing Need to be around 13-15 dwellings. In the Joint Local Plan, Sproughton has a housing allocation of 1,650 dwellings and this doesn’t include the 30 homes on our Bennett Homes site in Church Lane which is currently under construction. We in Sproughton are therefore taking Babergh’s housing requirement for the next 3 years which doesn’t seem to match the “established needs” when we have conducted a Housing Needs Survey which only needs around 13- 15 dwellings. In cases such as these, it makes villages feel powerless as we have these avenues to go down to try and make a point and a difference which ultimately doesn’t end up being listened to.
6. Part 1: Policy SP02 - Affordable Housing
6.1. Affordable housing must be enforced – developers too commonly get away with building larger houses saying that the affordable element is unviable. Viability numbers should be publicly available so they can be reviewed and challenged. The percentage should be increased to 40%.
6.2. Where it states, “Proposals which provide a greater amount of affordable housing than that set out above will also be permitted, subject to the relevant Joint Local Plan policies.” It should be added that it is with regard to the local Housing Needs Survey requirements.
6.3. Amendments should be made to the policy to ensure a wider mix of housing is achieved across the district, and also ensuring that policies are not written to just actively seek to approve development and meet housing targets in areas that are dominated by development. 6.4. With respect to villages where small developments are encouraged or more likely the Local Plan should recommend an affordable housing contribution or considerations to build on sites smaller than 10 homes. The need for affordable homes in rural villages is the only way to combat the aging population and encourage young families back into the countryside. The policy is driven by an assessment of viability rather than sustainability.
7. Part 1: Policy SP03 Settlements Hierarchy 7.1. The description of Sproughton does not clarify or mark the two distinctive areas. Although the village is identified under the Ipswich Fringe its unique and historic core village which contains multiple heritage assets is not truly represented. 7.2. Sproughton Working Group holds the landscape and its associated environment along the western side of the Gipping valley in high esteem. It believes it to be an asset of considerable value both for the village and the wider community. This is an important stretch of Suffolk flood plain, woodland and farmland. 7.3. There are characteristically Suffolk sunken lanes that are single track width in places with overarching trees, hedgerow and high banks that form the boundary infrastructure on the westside of the core village.
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7.4. To the north of the village is the Grindle, another sunken lane flanked by a watercourse that drains springs and run-off from the higher ground down to the River. The issues of the village flooding and potential increase in surface drainage issues have been mentioned. There are significant wildlife corridors, eleven significant Grade II listed buildings in the core village. To be listed under "The Fringe" is detracting from the rural and only green space remaining on the outskirts of Ipswich. 7.5. Development should take into account the capacity of physical and social infrastructure or new/enhanced infrastructure as well as having regard to the built and natural environment. 7.6. The evidence document https://www.babergh.gov.uk/assets/Strategic-Planning/Current-Evidence- Base/Settlement-Sensitivity-Assessment-July2018.pdf shows in detail the concerns of the two parts of our village. In Section IP6 of the above document it details the sensitivity of the landscape and the valley slopes which are valued in providing a buffer and sense of perceived separation between existing urban edge of Ipswich and the Gipping Valley, the latter reading as part of the wider western setting of the town.
8. Part 1: Policy SP04 Housing & Spatial Distribution 8.1. Development should be balanced between provision of homes and employment. Development shouldn’t lead to communities losing their identities by swamping and creeping coalescence (merging of communities). The location of growth should be spread more pragmatically across Babergh rather than in fewer large sites. The separation of Ipswich/Bramford should be enforced by protection of the green space around it and never built on i.e. SS1178 (opposite the Millenium Green), SS0775 (next to the Millenium Green), SS0711 (next to the Tithe Barn & Police House), SS0740 (opposite Sproughton House), SS0725 (between the school and A14) 8.2. The JLP allocation and other additional known proposed housing for Sproughton is extensive expanding a community of 611 into 3426. This would represent comparative over-development for the village and would be regarded as excessive and destroy the rural character of the village. 8.3. Makes provision for a total of 4147 new homes in the Ipswich Fringe, Market Towns and Urban Areas, Core Villages and hinterland villages. However, provision is only made for 118 new homes in hamlet villages, as a windfall allowance, with no sites for these homes being allocated in the Local Plan. 8.4. The planned spatial distribution of housing set out in Policy SP04 is unsound because it ignores the potential of 87 hamlet villages to accommodate small scale, appropriate growth, which cumulatively could make a significant contribution to the District’s housing needs. 8.5. It is strongly recommended that there is a review the proposed spatial strategy and allocate small sites for development in hamlet villages. These small sites are more in keeping with the character and local distinctiveness. Their impact is of less harm and more sustainable. 8.6. Development must be sustainable (economic, social and environmental), in the right place, of the right type and which meets the local need. Housing should be provided for a price that local residents can afford. Our recent Housing Needs Survey (questionnaire constructed in conjunction with Babergh) has concluded a total of 87 people need housing. That conflicts hugely with the 1505 houses put forward – a significant percentage of the 7,560 houses that Babergh says is needed. In fact, the 7,560 houses include 4,036 which already have planning permission but not been built leaving 3,524 so technically Sproughton is picking up around 50% of the requirement. 8.7. The concept of an Ipswich Fringe development area has been applied so disproportionately that almost a half of the necessary new applications required across a district of 75 Working Groups is proposed in one parish, Sproughton. And even within the proposed Babergh’s Ipswich Fringe Area of the 5 parishes three quarters the JLP’s ambitions for new applications is proposed in Sproughton. This is disproportionate in the extreme and it is not supported by sufficient infrastructure to make this sustainable. 8.8. We agree the cumulative impact of development should be a major consideration, not only locally but in the surrounding area. Especially with regard to the Fringe area and core villages involved. 8.9. A massive improvement to traffic movement throughout the A14 and A12 area would be the northern bypass.
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8.10. A clear and concise table of figures detailing exactly the expected, current, plus 20%, residual requirement on one page would be beneficial. The information is scattered and divided making the number less alarming. 8.11. The impact is not only on the village of Sproughton it is the entrance to Ipswich town from the main access point of the A12/A14 junction. Any development here has a significant impact on the visual appearance of Ipswich. 8.12 Roads and Traffic 8.8.1. Burstall Lane More recent investigation, assessment and treatment of the lane’s contribution to the severe congestion at the High Street, Lower Street and Loraine Way crossroads is required. Mitigation measures must ensure stringent discouragement of its use of as a rat-run due to congestion on Hadleigh Road. 8.8.2. Loraine Way Traffic considerations and environmental concerns have been looked at (2015). However, these surveys are out of date and have been conducted inappropriately at times of low demand e.g. during school half term holidays and bank holidays. New, cohesive and precise peak flow data is required urgently to describe and service the predicted three thousand new houses to be built along the Gipping Valley. An awareness of what needs to happen in Sproughton exists and some small steps have been taken. 8.8.1. A14, A12 and the Copdock Roundabout 8.8.1.1. The bigger picture involves inadequacies in the larger road system that serves ways in and out of Ipswich, difficulties on the Orwell Bridge and the inability of the A14 to deal with adequate diversions in the event of traffic hold ups. These play a huge part in the gross overloading of Sproughton’s High Street, Lower Street, Loraine Way and Burstall Lane. These roads are not highways and do not exist to deal with the volume of traffic that they are currently expected to carry. 8.8.1.2. The conservation needs of valuable village assets should be met by official designation in ways that demand respect. The present situation, already at crisis level, can only get worse with no practical relief scheme in place and additional adjacent residential development increasing the load. 8.8.1.3. The traffic load on Sproughton is now critical with serious hold-ups, even grid lock occurring on a regular basis at almost any time of the day and night. 8.8.1.4. These events are currently aggravated by construction at the old Sugar Beet Factory site on Sproughton Road. The difficulties are unlikely to diminish after this major development is complete. 8.8.1.5. The reasons for these inadequate traffic provisions are, as usual, mostly the result of unexpected consequences. Growth has overwhelmed forward planning and strategic decisions have been found wanting when conflicting outcomes have clashed. 8.8.1.6. The solutions to Sproughton’s road and traffic problems far outstrip any housing demands the village may exhibit and additional residential building in the Working Group will not provide an easy solution to the problems other areas may have. The cumulative impact of development must be a major consideration, not only locally but in the surrounding area, especially with regard to the Fringe area and core villages involved. 8.8.1.7. A massive improvement to traffic movement throughout the A14 and A12 area would be a northern bypass for Ipswich.
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9. Part 1: Policy SP07 -Tourism 9.1. To promote tourism and the rural economy it should be recognised that the any development proposals should be particularly carefully assessed in light of the sensitive nature of the heritage landscape, historic buildings and that cumulative development includes aspects that retain the nature of the Suffolk landscape, wildlife corridors and environmental protection zones. These are so important to tourism. 9.2. The policy doesn’t address the issue of increased traffic on an already over stretched infrastructure. Access from the A12 to this area is particularly an issue. 9.3. There is no mention of Snoasis. Should this come to fruition it would be a large attraction for Suffolk. 9.4. The policy should support all forms of tourism in all parts of the district and not just in the historic settlement. 9.5. Policy LP14 is much more comprehensive, including specific details on increasing tourism in alternative areas. 9.6. Alternative types or sustainable eco-tourism should be encouraged. 9.7. Overall it is a weak policy lacking detail and substance.
10. Part 1: Policy SP08 – Infrastructure Provision 10.1. The provision of infrastructure is fundamental to maintaining the quality of life, the prosperity and environmental credentials of the area. It is essential that any future growth and development is supported by infrastructure to meet the needs of the population, businesses and the wider community. 10.2. With the proposed development of Sproughton Parish the above statement is very welcome. The issues regarding cumulative development are still of primary concern. Multiple developments in neighbouring parishes should be inclusive and part of larger infrastructure plans, from experience cross district lines should also be addressed. For example: Bramford BMSDC and Sproughton BDC. 10.3. Within the evidence base Babergh and Mid Suffolk Infrastructure Delivery Plan (IDP) we are encouraged by the prospects of new schools especially a Secondary school within the area. 10.4. The prospect of changes to Junction 55 – Copdock Interchange - £63 million, flyover from southbound direction to the east would be of great benefit as it is a sticking point to the entrance to Ipswich and currently hinders the movement of traffic into and around the town. 10.5. Water management issues are a great concern within the village and the impact on the heritage assets on Lower Street. 10.6. Ipswich Fringe area and Sproughton with the River Gipping and its tributaries are flood zones, and this should be addressed again with any highway’s infrastructure and housing development plans. 10.7. Protected Habitat Sites Mitigation Zone should include wildlife corridors and consideration to the ancient and historic landscape, alongside cumulative development ensuring protected habitat zones are not isolated but inclusive with other green amenity areas. 10.8. There is no mention of extended bus or cycle routes especially in connection with SP07 – Tourism, cycle routes included in cumulative development areas. 10.9. The prospect of an Ipswich Northern Route highway is most welcome and a necessity to alleviate the infrastructure issues that Sproughton gets during the Orwell Bridge Closure or an accident on the A12/A14.
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10.10. The Northern route which is due to be completed within the next 15 years would have a significant impact on the JLP, has this been considered? 10.11. Applicants are only required to mitigate the additional impacts their development will place on infrastructure. It is not clear how the existing impacts of cumulative developments are to be addressed. 10.12. The IDP however as an evidence base contains some incorrect information on the Parish of Sproughton. Shown below.
Settlements Estimated Existing Allotments Amenity Recreation Play Play where number of new Population Green Grounds (Children) (Youth) preferred dwellings from Space (Combined) sites are potential JLP site Including located allocations within Outdoor Sport the settlement (Fixed Sproughton 1711 1376 0.83 0.38 0.13 0.01 -0.05
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10.13. SP08 makes much of the links with the A12 and A14 but in relation to Babergh one of the most important arterial routes is the A1071. For most people from the western end of Babergh driving to Ipswich or wanting to link into the A14/A12 network they first must get there along the A1071. This takes them to Sproughton where they need to choose their route to their destination. But every way out the other side is restricted or congested which creates a backlog into the pinch points through: - 10.13.1. Travelling to the London Road and turning right just hits the Copdock interchange congestion. 10.13.2. Travelling to the London Road and turning left just hits the backlog jam up from the Hadleigh Road/London Road traffic lights and river crossing. 10.13.3. Turning off left at Hadleigh Road just hits the same backlog jam up from the Hadleigh Road/London Road traffic lights and river crossing. 10.13.4. Turning left onto the B1113 at the Beagle to access Ipswich or the A14 just leads into a complete jam through the Wild Man Junction and across the weak bridge. (The houses in Sproughton were built beside roads intended for horse and carts, they simply are not suitable for the traffic they now endure). 10.13.5. And taking the rat run along Burstall Lane again to access Ipswich or the A14 leads into same jam through the Wild Man Junction and across the weak bridge. 10.14. Basically, all the traffic coming into Sproughton along the A1071 just backs up because it can’t get out the other side. 10.15. The Wolsey Grange 2 traffic improvements demonstrate how well they can move traffic along the A1071, but they do not explain how, as they expel the traffic more efficiently out the other end, it will clear the backlogs on these exit routes. Basically, if more traffic is expelled into the same congested exit it will just back up onto the A1017 and the road improvements will just become a slightly bigger holding car park. 10.16. The limitations of the village layout mean that any attempts to improve traffic through Sproughton would be mere Elastoplast measures. 10.17. Before more house are built adding to the congestion and before the A1071 is improved to streamline traffic flows along it two problems need to be resolved: 10.18. More efficient traffic management/system/road layout at Hadleigh Road/London Road River Crossing/traffic Lights to clear larger volume of vehicles more efficiently. 10.19. Copdock Interchange improvements to clear A1071 traffic quicker. 10.20. Until these are resolved the back up of traffic at those points will always be the foundation of congestion on the A1071 and all the problems with rat runs and 20 minutes queues will not go away they will only get worse.
11. Part 1: 12 Protection & Management of the Environment 11.1. Section 12 Protection and Management of the Environment Strategic Issues 11.2. This section is confusing to any reader unless they read all the JLP in full which many may not. It refers to Environmental Protection, Biodiversity, Landscape, Historic Environment and Change of use of Land but then provides no policies relevant to these.
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11.3. It only contains two policies: SP09 cross border habitat protection and SP10 Climate change. However, in relation to both of these policies the JLP fails to consider the local implications of Environmental Protection, Biodiversity, Landscape, Historic Environment and Change of use of Land on those policies which are important as there should be a balance between cross border requirements and any adverse impact on a community.
12. Part 1: Policy SP09 - Cross-boundary mitigation of effects on Protected Habitats Sites 12.1. Sproughton lies within in the Zones of Influence for European/ Habitat Sites. With over 2500 homes to built in the parish this policy needs to be robust and adhered to. Mitigation and compensation should be considered exceptional and last resort. 12.2. Important local habitat sites should include the River Gipping, flood plains alongside the historic rolling valley landscape of the Gipping Valley. These are areas of extraordinary significance which will be affected by the creeping coalescence and ribbon development of the Gipping Valley. 12.3. BMSDC Should consider the points raised in LP016 – Environmental Protection 12.4. Please also see Comments on the ‘Habitats Regulations Assessment including Appropriate Assessment Report’ which is one of the three main ‘Current documents open to consultation’ in this JLP Consultation. 12.5. The greatest threat to SSSI and AONB sites is increased adverse impact from new development and an increasing population. Natural England and The National Planning Policy Framework require that the impact of new development on such sites is assessed and in the first instance impact should be avoided, if that is not possible mitigated, and finally only in an ‘Unavoidable Imperative Reasons of Overriding Public Interest’ compensated. 12.6. This report does not consider logical and practical measures of avoidance but rather relies on the Recreational disturbance Avoidance and Mitigation Strategy (RAMS)’ report - a set of mitigation measure proposed for these sites to accommodate and manage increased impacts that will be funded by 106 payments by developers set out in the new JLP Policies at an application stage. This is at best Mitigation instead of Avoidance, and although the RAMS report proposes mitigation measures the proposed 106 Payments are in effect compensation paid to management of these sites as BMSDC is undertaking no practical measures to mitigate themselves.
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12.7. Policy SP09 relies on this report which: - . 12.7.1. Fails to consider Local Habitat sites that contain protected species, these should be considered and afforded protection and can contribute to the footfall avoidance option. 12.7.2. Fails to recognise sites that may threaten the protected National and European Habitats with contaminated water. This is because it doesn’t recognise proposed developments sites that are already or could be linked hydraulically, which is a guidance criterion that has not been assessed correctly. 12.7.3. Fails to consider the preservation and enhancement of local Green Spaces and nature areas to divert footfall away from National and European Habitat sites which should according to the national guidance be the first consideration (SANG’s) Suitable Alternative Natural Greenspace provision one of the recommended options to achieve avoidance. Enhancing local green/nature areas as SANGs has the advantage of enhancing the natural area in which a new development is set to the benefit of the development and the local community rather than just destroying it. 12.7.4. Since this policy relies on the ‘Habitats Regulations Assessment including Appropriate Assessment Report’ which is significantly flawed in failing to consider the above listed points it does not support this policy to ignore local enhancement in favour of 106 payments which amount in reality to no more than compensation.
13. Part 1: Policy SP10 - Climate Change 13.10. We would assume that everybody including BMSDC would support policy to address adverse impacts on climate, however.: 13.11. The terminology used in this policy creates an expectation that BMSDC will support developers for doing little more than considering one or more categories listed in the policy. 13.12. The wording is also subjective which makes its application legally challengeable on mere opinion. 13.13. An application refusal based on inadequate Climate Change proposals therefore becomes legally challengeable simply by the applicant considering one element of the policy or on a difference of opinion. 13.14. Climate change measures should be objective and absolute baseline policy requirements for any new development and policy should not be worded to guarantee a legal argument by mere consideration of policy or difference of opinion. 13.15. Also, the requirements are inadequate in that the base line expectation appears to be set at mitigation rather than avoidance or improvement. Climate Policy should not just mitigate by 106 payments for some remote scheme that provides no benefit to the community that is impacted by the application. Policy should aim to mitigate or improve locally for the adverse impact of construction and development with new greenspaces, tress and hedgerows in the same community.
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14. Part 2: Policy LP02 – Residential Annexes
14.1. This policy is well conceived, it is important to encourage annexes as an alternative to purpose-built specialist buildings. It covers in detail the main issues however it does not cover the similar issues in LP03. 14.2. Serious strength and consideration should be given to adjacent (impacted) properties with regard to light, amenity, noise, privacy, visual impact and overbearing out of scale or out of character designs.
14.3. The detail of any extensions or annex should not be overbearing with regard to the existing property is to be encouraged, they should not be visually disconnected from the original building in design.
14.4. The design, size, scale, mass and materials of the resultant annex development must be compatible to the area’s character and appearance and must not be significantly different and no more visually intrusive to that of the original dwelling and must not significantly urbanise the plot or property curtilage.
15. Part 2: Policy LP03 – Residential Extensions and Conversions
15.1. We would like to see bungalows given more protection and prevented from conversion to houses – there is a shortage of this type of property – request that wording be added, “bungalows to remain in perpetuity through the removal of permitted development rights.”
15.2. Serious strength and consideration should be given to adjacent (impacted) properties with regard to light, amenity, noise, privacy, visual impact and overbearing out of scale or out of character designs.
15.3. The design, size, scale, mass and materials of the resultant development must be compatible to the area’s character and appearance and must not be significantly different and no more visually intrusive to that of the original dwelling and must not significantly urbanise the plot or property curtilage.
16. Part 2: Policy LP04 - Replacement Dwellings in the Countryside (Outside of Settlement Boundaries)
16.1. Proposals to replace an existing dwelling in the countryside or the conversion/erection of ancillary buildings or boundary treatments for such dwelling, may be permitted providing the proposal complies with policy on (Residential extensions and conversions policy) criteria and in addition: 16.1.1. The design, size, scale, mass and materials of the resultant development must be compatible to the area’s character and appearance and must not be significantly different and no more visually intrusive to that of the original dwelling to be replaced and must not significantly urbanise the plot or property curtilage. 16.1.2. The existing dwelling must not be a listed building or a building of historic or architectural importance and merit or a non-designated heritage asset. 16.1.3. There must not be any increase in the number of dwellings on the site. If the proposal incorporates any increase in dwellings on the site refer to the Hamlets and Clusters of development in the countryside policy and settlement hierarchy policy.
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16.1.4. The original dwelling must have a lawful permanent residential use and be capable of residential occupation in its current condition and form before any acceptable approved alteration.
16.2. This policy should be stringently adhered to and include: - 16.2.1. Should a dwelling be demolished and any additional ancillary buildings on the site also be demolished the replacement residential building should not reflect the total of the number and therefore the size, mass and scale of the combined buildings. 16.2.2. The number of outhouses, garages, barns and ancillary buildings should be subject to restrictions where multiple buildings have been demolished to build one single residence. 16.2.3. The housing needs are not met for the whole community and it results in large posh housing, it also leads to infill between villages on rural lanes. 16.2.4. Does not achieve the range and mixture of housing that is required and set out in the Sproughton Parish Council Housing needs survey. 16.2.5. They are isolated from village life, amenities and socially disconnected. 16.2.6. Policy should be put in place to ensure that sites are carefully approved with regard to location to the village, infill between villages, infrastructure, impact on the heritage landscape context and sustainability and the environment. 16.2.7. LP04 fails to include ‘impact on neighbouring amenity’. The impact on neighbouring properties is an important factor in the planning process and should stipulate restrictions towards the development in favour of any adjacent properties.
17. Part 2: Policy LP05 – Replacement Dwellings and additional dwellings on sub- divided plots within settlement boundaries 17.1. The term, ‘Neighbouring Occupiers’ needs greater detail and explanation 17.2. Some settlements are clustered around a single street. In these cases, subdividing plots to allow for additional dwellings could lead to a fundamental change of character of a settlement. 17.3. It is important to the character and appearance that where subdivision / replacement dwellings and / or materials used that they are compatible with the character and appearance and not significantly different. 17.4. The design, size, scale, mass and materials of the resultant development must be compatible to the area’s character and appearance and must not be significantly different and no more visually intrusive to that of the surrounding dwellings and must not significantly urbanise the plot or property curtilage.
18. Part 2: Policy LP06 – Supporting and Special Needs Housing 18.1. The plan should address the issue of accommodation for the elderly. Suitable access to services should be ensured. These should include transport links to shops, doctors etc. 18.2. Evidence should include mention of a recognised and approved parish Housing Needs Survey. 18.3. 3% for bungalow development is insufficient.
19. Part 2: Policy LP07 – Affordable Housing 19.1. The policy states “The Joint Local Plan will seek to retain and deliver 35% requirement for affordable housing on relevant sites of ten or more units or sites of 0.5ha or more.”
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19.2. To seek to retain and deliver is not a commitment to do so. We need to actively ensure that policies are upheld and stringent. 19.3. Relevant Sites: why shouldn’t all developments contain AT LEAST 35% affordable housing. 19.4. Housing Needs survey should play a vital role in dictating affordable housing needs in a parish and any development should be judged against the identified housing needs for the parish. This should be explicitly threaded into the proposed Joint Local Plan 19.5. The above should also apply to the Neighbourhood Plan. 19.6. Policy LP07 mentions “rural exception sites” but there is no explanation of what these are and how they work? 19.7. The clause “Specialist accommodation for specific needs” in the exemption of affordable housing should be removed. There is a specific need for specialist accommodation for specific needs that is sustainable and affordable. 19.8. A suggested recommendation with a statement regarding clawback needs to be added
20. Part 2: Policy LP08 – Provision for Gypsy and Traveller and Travelling Show people
20.1. The evidence base for the above policy shows that the Babergh Five Year estimate of the need for permanent/residential site pitches (2016-2021) is zero. There has also been a significant decline in un-authorised sites in the last two years (2016 -2018) from 12 to 5 showing a rapid decline in the need for any additional provision for sites. 20.2. Considering the extensive site at the ASDA roundabout, this policy is considered irrelevant to the parish, also, the parish currently would not fill the criteria of the policy statement due to lack of amenities. 20.3. The Policy in foundation covers the main points, it is however important to have a policy that sets out how applications for potential future sites would be considered. 20.4. The Planning Policy for Traveller Sites 2015 sets out a comprehensive and detailed set of guidance points that would be crucial in determining and need for additional sites and their development. 20.5. The Document clearly states that “local planning authorities should make their own assessment of need for the purposes of planning.” 20.6. This has been clearly shown by the evidence base for the policy provided by Babergh District at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/457420/Final_planning _and_travellers_policy.pdf 20.7. The Plan’s Policy should outline any brownfield / Greenfield preferences for plot and pitch locations; and not Greenfield land.
21. Part 2: Policy LP09 – Moorings and Marinas 21.1. This Policy does not directly affect the parish of Sproughton, it would be reasonable to assume that the River Gipping is non navigable within the parish boundaries and therefore not suitable for houseboats. The policy specifically details: - 21.1.1. Pin Mill and Chelmondiston 21.1.2. Stour & Orwell Estuaries SPA and Ramsar site
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21.2. Should this situation arise within the parish and on the River Gipping, then the parish policy would not approve of any house boats navigable or permanent mooring be allowed.
22. Part 2: Policy LP10 – Self-Build and Custom-Build
“The councils will support proposals for self-build/custom-build housing or proposals that make a proportion of serviced dwelling plots available for sale to self-builders or custom builders, on appropriate sites and where in compliance with all other relevant policies of this Joint Local Plan”
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22.1. Discounted alternative approaches 22.1.1. “13.65 No alternatives are put forward at this stage, as the policy proposes a flexible approach in conformity with the NPPF.” 22.1.2. This policy is extremely vague and unstructured. Given the detail in the Acts below the policy should not be guided by a “flexible approach” and should at least give some parameters of what should be expected on self-build plots specific to the district of Babergh. We live in a rolling valley character area within a historic landscape that must be given the respect it deserves when it comes to self-build and custom-build plots. We cannot and will not accept development that is completely out of character with the parish of Sproughton and would have liked to have seen a detailed policy in order to make comments on rather than relying on the NPPF for all the main policies. 22.1.3. Due to the policy being so vague, we have the following crucial concerns: - 22.1.3.1. Single or maximum of 3 self-build plots on any one development should be a considered factor. Multiple self-build plots raise concerns of: 22.1.3.2. Infill along country lanes leading to creeping coalescence and ribbon development 22.1.3.3. Multiple designs that are not indicative of local heritage, uncharacteristic in design 22.1.3.4. Lack of residential amenity for multiple plots 22.1.3.5. Impact on the heritage landscape 22.1.3.6. The need for sustainable and progressive development encouraging affordable houses not large posh housing 22.1.3.7. Multiple large plots increase environmental impact, increased vehicle usage due to rural locations 22.1.3.8. They are isolated and socially disconnected 22.1.3.9. They can easily be made to encroach on neighbours’ houses with little consequences 22.1.3.10. Drainage is a concern as much of rural Sproughton is on heavy clay, where non- conventional stand-alone systems would be required. 22.1.4. A key challenge for the parishes is to provide affordable homes for local people. Support will be given to innovative delivery mechanisms for affordable housing as recognised and supported by the recent Housing Needs Survey as 13-15 homes for the community with a mix of affordable housing and smaller homes for the elderly 22.1.5. Local distinctiveness of property design 22.1.6. Impact on heritage landscape and the impact of the heritage context 22.1.7. Posh housing in an area that requires affordable housing 22.1.8. Social cohesion, they can be isolated and socially disconnected 22.1.9. Creeping coalescence, Sproughton merging in to Bramford and Burstall, the infill and number of Self build properties along road corridors, this pushes us closer and closer into Ipswich, essentially condemning us to be a suburb which is something we strongly reject in our hinterland village. 22.1.10. Self-build register and local demand for self-build houses is minimal only 160+ applications on the BDC register. 22.1.11. Plot sizes should be restricted, and land classifications upheld. 22.1.12. Impact on highways and infrastructure 22.1.13. Sustainability and progressive development, and innovation 22.1.14. Multiple self-builds are not in keeping with the heritage and legacy of Sproughton, which has a rural and delicate combination of Heritage and circa 1970-2000 buildings.
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22.1.15. It is impossible to put back the best of a landscape, the best biodiversity and best green leisure areas once they are built over. 22.1.16. BDC should not consider Self-build plots purely on the bases of CIL payments. 22.2. The Ipswich Fringe is typical of urban growth with multiple self-build houses along country lanes. These need to be stringently controlled as they frequently offer no public benefit beyond policy requirement to outweigh harm. They are not sustainable, do not promote social cohesion, are isolated posh housing, which do not reflect the need for affordable housing in our parish or District. 22.3. Self-build for specific disability needs should be strongly supported as there is a lack of suitable homes which cater for disabled people. As well as sheltered accommodation of which is hugely lacking across the whole district which should also be covered in a policy in detail of how as a District, we can fill this huge gap. 22.4. There is no reference to the following guidance only the NPPF. 22.4.1. Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) 22.4.2. Self-build and Custom Housebuilding Regulations 2016 22.4.3. Self-build and Custom Housebuilding (Time for Compliance and Fees) Regulations 2016 22.4.4. Guidance on the housing and economic development needs assessment and the housing and economic land availability assessment. 22.5. Conclusion 22.5.1. Encourage self-build for specific needs and disability requirements, to meet the varied needs of existing and future residents, accommodate the needs of an ageing population and households with restricted mobility; specialist housing projects for people with a range of disability, and the specific opportunities for self and custom build and co-housing to meet these needs. 22.5.2. Max 3 per development, tying this to ensuring affordable house requirements are met or exceeded. 22.5.3. Smaller plots for more affordable self-builds 22.5.4. Must support sustainability and innovative design and technology, water recycling, ground source, solar etc 22.5.5. No multiple plots that encourage ribbon and infill between villages and parish. 22.5.6. Self and custom build housing will be supported providing they meet the over-arching sustainable development, general amenity and design policies. 22.5.7. The draft JLP does not consider the cumulative effect for BDC and its component parishes. It comprises a top-down exercise in meeting Government-led numerical housing targets and avoids engaging in the debate of what that means for people in preserving the rural feel of the area. 22.5.7.1. Total number of houses in JLP plus other advanced development proposals is 2815. 22.5.7.2. That is a 461% increase on the current 611 houses 22.5.7.3. 1198 to be built around the village 22.5.7.4. 1617 in and around Chantry Vale 22.5.7.5. Total number of houses BDC needs to build in Babergh = 7560 22.5.7.6. So the known proposals for Sproughton account for 37% of Baberghs housing need. (i.e. 2815/7560)
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22.5.7.7. Consider how will this impact schools, roads, GP surgeries etc which are already overloaded. Also, the wellbeing and health of the local residents. 22.5.8. A diffused expansion across the BDC, by creating a merit-based policy for controlled expansion of communities of all sizes. Thereby creating sufficient economic mass for smaller communities to benefit from a wider range of services. Our communities deserve a broad-based discussion of different scenarios, not simply a re-hash of the status quo. Many of the communities and villages in Babergh are crying out for more development and growth in order for them to really grasp their full potential and become the best villages they can be; however, they do not have any allocations. Glemsford and Whatfield are examples of villages that could attract investment and amenities in the these villages if only there is the growth that they need which is being put into all of the urban areas in Babergh rather than spread out equally which will leave some villages left out.
23. Part 2: Policy LP16 – Environmental Protection 23.1 Any policy to protect the environment is welcomed. We have however noted the following issues with this policy 23.2 Policy 1(a) claims to prioritise use of previously used land to minimize the use of best and most versatile land for housing. However, most of the new applications coming forward are just that on high value agricultural land. This is an 18-year plan so applications on farming land should be refused or delayed on this principle until brownfield and already developed land is exhausted. 23.3 The vast majority of development proposed is along the A14 corridor which appears to be at odds with policy 2(a) which in effect emphasizes a duty of care to communities as being close to the A14 those sites will be subjected to, and contribute to, the very issues identified in this policy. However, for existing communities will this mean that attention will now be given to mitigate or reduce such adverse health impacts? It doesn’t actually say that. 23.4 3b ground/surface water run-off from residential development is inadequately considered. Traditionally avoidance of commercial pollution has been the focus of planning but commercial and agricultural activity is now heavily regulated whereas individuals and residents can gain access to all manner of chemical concoctions for cleaning and gardening that are then carried away in SUD’s into attenuation basins and discharged as controlled overflows into rivers. This can only be remedied by all Infiltration SUDS or chemical filtration of Attenuation basin overflows. 23.5 Development along the A14 corridor will also adversely impact on the natural environment and wildlife removing or narrowing the wide undeveloped wildlife corridors that run adjacent to this road. 23.6 Although this policy considers fixed light pollution no consideration is given to road design or screening to eliminate headlight pollution both residentially and on the natural environment. 23.7 The policy sets no quantifiable objectives in support of the national government plans to reduce Greenhouse gasses. This is a national objective that requires all possible action is to be taken and the lack of quantifiable commitment to this is unacceptable. 23.8 Similarly, a lack of any policy for a process or commitment to enforce and police compliance and/or adequate performance of environmental policy makes these policies worthless.
24. Part 2: Policy LP17 – Biodiversity 24.1 Although the Policy is substantial much of its terminology is inappropriate or inadequate. 24.2 The policy seems to suggest approval (support) will be given by simply conforming to the minimum standards of this policy for one section or another, not necessarily all. 24.3 Would an application refused for failing on one element have grounds for a legal challenge by proving it had conformed in another?
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24.4 For instance, by showing compliance with 1(b) when no such site was relevant and then doing nothing about any other element of LP17? 24.5 1(a) Simply states the NPPF hierarchy but does not state final qualifier that dropping to the lowest standard would require of ‘Imperative Reasons of Overriding Public Interest’. 24.6 1(b) Does not clearly define ‘designated sites’ and may therefore be interpreted in a more limited application than it appears. 24.7 1(c), Enhancements at a micro level within a development need to be appropriate and advantageous to the identified biodiversity and there needs to be a guarantee they will endure. Fitting bat bricks may provide an alternative to a tree roost but may not be appropriate and even if they are there is no guarantee a new house owner will maintain them. 24.8 1(d) Green corridors are now frequently nothing more than a path that is necessary anyway, or micro green corridors which are actually restricted tracks that funnel every element of wildlife creating an ideal killing zone for predatory domestic cats that the residents of new development introduce into a previously wild environment of wide and varied groundcover. There needs to be policy to quantify the size of green infrastructure and how it is incorporated into a development in a way that protects the biodiversity that it is created for. 24.9 1e appropriate 24.10 1f appropriate 24.11 (2) This element suggests that planning is refused unless there is no alternative, but what that actually amounts to is not defined. NPPF used the phrase Imperative Reasons of Overriding Public Interest which might appear appropriate assuming there is case law to quantify this level. 24.12 (3) This policy relies entirely on ‘appropriate’ as a quantifier. This is purely subjective and completely open to legal challenge. What is more this completely ignores the first standard expected by NPPF of ensuring avoidance before mitigation. The policy therefore diminishes the expected standards below the nationally expected guidance.
25. Part 2: Policy LP18 – Landscape 25.1 Rather than setting requirements as a minimum the authority appears to be offering approval for application by subjective assessment. Opinion based policy creates a potential conflict not just with applicants but within the as any application recommended to Planning Committee could not be rejected by county councillors on committee based on their opinion as to do so would immediately create a conflict of opinion exploitable by an applicant. 25.2 The policy also is not clear as to whether approval is being offered for individual policy compliance or whether the expectation is for compliance to all sections. 25.3 This leaves the policy open to legal challenge at appeal on grounds of opinion and a need to only apply to one section if rejected on another. 25.4 The proposed removal of Special Landscape Areas Policy is detrimental to the council’s legal authority to control the impact on Landscapes as this was an objective policy and not open to interpretation and legal challenge. The removal of this policy also removes a level of protection from development in the established open, and the best, landscape areas between settlements. 25.5 A concept not considered is proactive mitigation where measures to prevent adverse impacts on a landscape are required before building. What has been witnessed in Sproughton recently is exactly the opposite where hedgerows and trees are being removed before formal application, but during the time that an applicant is actively consulting the planners. 25.6 Evidence of proactive enhancing a landscape to soften the application should be considered positively and any recent removal of natural landscape features should be considered negatively as if their removal was part of the application when submitted.
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25.7 Policy refers to the ‘s Local Landscape Guidance’ which doesn’t seem to exist under that title. I assume this is the ‘Joint Local Landscape Guidance’ and should be correctly identified to be binding.
26. Part 2: Policy LP19 – Area of Outstanding Natural Beauty This policy appears to be fit for purpose provided it is adhered to.
27. Part 2: Policy LP20 – The Historic Environment 27.1 There many elements of this policy that are subjective. This creates the potential of differences of opinion. Any application recommended to Planning Committee which they then have a mind to reject based on a different opinion would immediately create a conflict of opinion to support an appeal. Effectively once recommended to committee the committee county councillors would have no effective ability to apply their democratic right to consider and if appropriate reject an application, they considered inappropriate for the public they were elected to represent. 27.2 (c) Only heritage assets with archaeological interest would be required to submit a desk top assessment. Surely this is inadequate and inappropriate for any designated heritage asset. This policy then subjectively suggests were appropriate a field evaluation by a suitably qualified person. But no requirement is made for these to be by an independent person. 27.3 (d) It is suggested that the JLP will adopt the NPPF position on non-designated heritage assets which is welcomed as Sproughton not only has many listed buildings but many old buildings and a historic Landscape. However, although mentioned there is little consideration of the interaction between listed or old non listed buildings or the historic environment like farmland, landscape, and townscape which interact with the listed buildings. The setting of the heritage asset within a place and that places association with the asset is important. The protection for the setting of the heritage asset is referred to in NPPF paragraphs 189 and 190. 27.4 (e) Policy then requires subjectively that depending on the nature of proposal that a heritage statement is required and sets out what might be required in that, but again no indication this needs to be completed or informed by a suitably qualified and independent person. 27.5 1(g) This state ‘Support (an application) where adverse impact cannot be reasonably avoided and are outweighed by public benefits’. This becomes a double subjective personal opinion supported by terminology that provided a positive expectation for approval. 27.6 I.e.: ‘adverse impact cannot be reasonably avoided’ and ‘outweighed by public benefits’ 27.7 These are undefined quantities open to opinion and bias that on appeal would probably be legally un-defendable.
28. Part 2: Policy LP21 – Change in Land Use for Equestrian or Other Animal/Rural Land Base Uses 28.1 This is an extremely comprehensive and demanding policy and would be more appropriately aimed at residential/commercial development. 28.2 It is difficult to understand why a much stricter policy is being applied to rural land uses and farmers who work/create the landscape, than to developers who take good farmland and permanently obliterate it?
29. Part 2: Policy LP22 – Agricultural Land To Residential Garden Land 29.1 This policy is fairly robust but does not remove the possibility of infill development or residential extension. If you feel that is appropriate, then the policy appears adequate. 29.2 If your view is that change of use applications for purchases of farmland to use as residential garden should not allow for anything other than green use of that land, then it is inadequate.
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29.3 That view predominantly applies to land attached to homes outside village envelopes to prevent expansion that impacts negatively on the landscape. Or to prevent irreversible loss of traditionally good farmland that may in the future need to be farmed again. 29.4 If you feel that farmland should remain green then this policy should do more than remove permitted development rights, it should be subject to planning conditions that prevent any development or the use category should not be changed and the applicant should be expected to use the land in a smallholding capacity.
30. Part 2: Policy LP28 Designated Open Spaces: Allotments: Grave concerns regarding LA012 - An alternative provision of equal or greater quality, accessibility and quantity of allotments space is provided as part of the scheme; 30.1. Heritage and emotional connection with the past, allotments here for a very long time. They are our heritage and in some cases our connection with our family past. 30.2. Many years of hard work to get high fertility and organic system on existing plots: Getting the soil on your plot in tip-top condition takes years of dedication and hard work. 30.3. Mature shrubs, bushes and trees cannot be transplanted. 30.4. New land will not be as fertile or in such good condition as soil regularly worked. New plots on any fresh location would certainly not be as fertile nor would the soil be in such good condition as our current plots, which are regularly worked. It will require a significant investment of time and effort to get back to where we were, through no fault of our own. 30.5. Presence of residual chemicals pesticides, fertilisers etc. Establishing a new plot on what was previously arable farmland that will be contaminated with commercial pesticides and fertilisers means that those of us who prefer organic methods will be set back years as we struggle to clean the soil. 30.6. Disease and wind damage: Any new site for the allotments may not provide anything like the existing shelter afforded by nearby buildings or mature trees. This would make any new plots susceptible to wind damage and wind-borne weeds, pests and diseases. 30.7. Livestock more at risk from predators due to the remoteness of the site. Those of us who keep livestock like rabbits and chickens fear that any new site would mean greater losses to predators like foxes and rats. 30.8. Overall it is thought that, in landscape terms, the allotments in their present form provide a very satisfactory transition from the residential edge of the village into the greenfield hillside. 30.9. We would also draw your attention to the new JLP allocated sites for potential development, noting that the whole of the Pigeon, Burstall Lane/Lorraine Way site isn’t designated, only the area around and including the allotments. Given that the FTCT in a letter dated to the SWG 7th May 2019 stated, “On the matter of allotments, may I reassure you that we wish to maintain allotments in Sproughton, and could consider, via Pigeon, extending the area if there is a demonstrable need.”
31. Part 2: Policy LP31 – Managing Infrastructure Provision 31.1. Whilst the policy would seem to secure the infrastructure needed for new development, it does not address the existing insufficiency of transport infrastructure for requirements arising from previously permitted development. In order to remedy congestion such as happens in Sproughton Village, any new development which would result in additional traffic flows must only be permitted when it is certain that transport infrastructure capacity is available & sufficient for both existing and forecast demand. 31.2. The plan is to increase in the amount of traffic through Sproughton Village. This a bad because the ability to accommodate growth here has already been compromised by previous planning
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decisions. Adding to the traffic will further compromise the ability of future generations to meet their needs. 31.3. Sproughton Village is a residential area where the community suffers from an unusually high volume1 of road traffic. Air quality at the High Street / Lower Street junction is predicted2 by the District to be the worst of all its junctions. This junction has no spare capacity3 to accommodate growth. It already carries more than 10,000 vehicles a day; over 1,200 vehicles during peak hours. Footways are narrow and below current design specifications. Built homes have front doors which open directly onto the highway. 31.4. Previously agreed mitigation of development impacts has not happened because the proposed measures failed Stage 2 Safety Audit 4. 31.5. Claims that options for mitigation are available, and that they are adequate, are untested. It is not known whether the Infrastructure Delivery Plan can perform as intended. In it the B1113/Lower St junction is described as ‘critical’, a mitigation priority greater than ‘essential’. The recommended3 further model runs needed to inform mitigation have yet to be carried out. With regard to those living in Sproughton, the Sustainability Appraisal does not do what it says in its text - assess all relevant elements of the plan that could give rise to any environmental, social or economic effects. The terms ‘effective’ and ‘sufficient’ as used to describe acceptance of the anticipated mitigation are not quantified. For Sproughton residents living in the built environment there is no surety that the plan will promote healthy and safe communities. 31.6. References 31.6.1. Report on the B1113 Traffic Monitoring Survey. Suffolk County. 2008. 31.6.2. Assessment of air quality in the Babergh District 2005. Table 18. NO2 concentrations at busy junctions. 31.6.3. Local plan modelling report. Suffolk County. January 2019. 31.6.4. Stage 2 road safety audit SA497. Suffolk County. January 2013.
32. Part 2: LP32 Health & Education Provision 32.1. Healthcare in the Ipswich area is already under significant stress. In the UK as a whole there are not enough GPs, not enough doctors wanting to become GPs and steadily increasing demand. How will more GPs be found to provide healthcare to an increased population? 32.2. An increase in elderly residents means more carers are required. In 20 years’, time it is estimated that there will be a deficit of ½ million carers. 32.3. The strategy of the Plan should be flexible enough to address additional social issues which will arise during the lifetime of the document; for example, the needs of an increasing elderly population. 32.4. Developments should not go ahead unless there is a proven quantified solution for the provision of health & education services. Local providers should be statutory consultees e.g. local GP surgeries, the CCG & local schools not just NHS England and the Department of Education.
33. LA012 Land North of Burstall lane and West of B1113 31.1. The new JLP proposal to remove the Special Landscape Designation from this area removes an objective policy that protected this historic farmland scene. 31.2. The subjective landscape assessment policies proposed in the JLP to replace this will be opinion based and legally challengeable on appeal. 31.3. Any conflicts, between the recommendations of the planning department when an application comes before Planning Committee and the opinions of county councilors, in relation to a subjective policy provides applicants with ammunition for an appeal. Defending an appeal against rejection by the planning committee based on a subjective policy therefore involves a considerable financial risk. 31.4. Will these subjective policies hamstring democratically elected county councilors form rejecting applications they consider against the expectations of their electorate to ensure reasonable
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development in the public interest when faced with the dilemma that to do so will subject the as a public body to significant legal expense? 31.5. The SLA applicable to this site is a thoroughly appropriate designation for this valley side site thought to be some of the first land cultivated in the lands surrounding Ipswich. The superior agricultural land south and west of the Gipping Valley is due to undulating valleys and vales that created ideal drainage for a fertile soil. This is supported by the abundance of Listed farm buildings that have visual aspects both towards and from this site. The Barns, Farmhouses and Mill all link in agriculturally and visually and these are supported by the listed church, manor houses, Public House, village houses and a predominance of old but unlisted houses in this Northern edge and original village centre. 31.6. The SLA is also clearly appropriate as the landscape character assessment and sensitivity reports for this area support a recommendation not to build on these valley sides or to remove the green landscape scenery that divides two distinct villages within the wider landscape setting. 31.7. It is unclear why the policy does not provide for the impact of this site on the designated Habitat sites in the HRA report. 31.8. However, if it subsequently does then it appears that the HRA report neglected to consider the first recommended option of avoidance for relevant new development within the designated Habitat sites impact zone. 31.9. Rather than avoid impact BMSDC has adopted for mitigation/compensation (the lowest options in the recommendations) towards the management proposals for the protected Orwell sites. Better measures can be achieved by improving the recreational and natural value of areas accessible to a development known as ‘SANG’s’ to attract ramblers etc. away from the Orwell sites. This provides an enhanced greenspace for new residents and the existing community and diverts any increase in footfall on the designated habitat sites. 31.10. LA012(x) also applies a policy to regulate discharge into the watercourse. The watercourse is the River Gipping and the River Gipping is the Orwell so the discharge from this site will be hydraulically linked to the designated Orwell Habitats and should again fall within the assessment of the HRA. 31.11. Wildlife and Biodiversity is also a relevant as this site is ancient and established as a wildlife greenway between the wider landscape area and the Gipping Valley which has important significance not just for this site but on the wildlife within the Gipping Valley Corridor.
34. LA013 Land North of the A1071, Sproughton 32.1. The new JLP proposal to remove the Special Landscape Designation from this area removes an objective policy that protected this historic farmland scene. 32.2. The subjective landscape assessment policies proposed in the JLP to replace this will be opinion based and legally challengeable on appeal. 32.3. Any conflicts, between the recommendations of the planning department when an application comes before Planning Committee and the opinions of county councilors, in relation to a subjective policy provides applicants with ammunition for an appeal. Defending an appeal against rejection by the planning committee based on a subjective policy therefore involves a considerable financial risk. 32.4. Will these subjective policies hamstring democratically elected county councilors form rejecting applications they consider against the expectations of their electorate to ensure reasonable development in the public interest when faced with the dilemma that to do so will subject the as a public body to significant legal expense? 32.5. The SLA that was applicable to this site reflected its importance further reinforced by the opinions of the BDC Planning Department and the Environment Secretary Nicholas Ridley in 1987 who on conclusion of the appeal by Wilcon Homes to develop Chantry Vale said that it was a ”significant
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contribution to the attractive south west approach to Ipswich” and “if the scheme went ahead it would mean losing an area of attractive countryside and would also have a large impact on the village of Sproughton”. 32.6. This was against a proposal to build another 8000 homes for Ipswich, very similar circumstances to today and all that has changed is that the land had been bought by a major developer and the opinion of the planners which emphasises how dangerous subjective policies on sensitive issue can be. 32.7. What the Environment Secretary recognised in 1987 was a valley that has now been classified as having a landscape charter type mix that only occurs again in Suffolk in the Dedham Vale AONB around Flatford Mill. 32.8. The SLA designation is therefore appropriate whereas the subjective polies are completely open to opinion that may not be able to be challenged even by democratically elected council councilors. 32.9. It is unclear why the policy does not provide for the impact of this site on the designated Habitat sites in the HRA report. 32.10. LA013(viii – xii) are requirements for mitigation payments which seems to be a predominant peculiarity of the New JLP policies. Instead of dealing with an issue for the good of the local community it just asks for money that may end up being spent elsewhere. 32.11. However even though the HRA appeared to have forgotten the primary recommendation of avoidance and approved mitigation payments instead there is no specific policy to recover even these here. 32.12. This site will impact ecologically on the protected Orwell sites due to its location and the primary recommendation by NE and NPPF is to try and avoid impacts can be done by creating a country park in the Chantry Vale which is also a recommendation in the BDC Green Infrastructure Framework since 2012. This would create green spaces for any new development, the local community and that of Ipswich within walking distance to enjoy it thereby diverting footfall from the Orwell Habitat sites. This is a recognised resolution referred to as ‘SANG’s’. 32.13. LA013(xiii) also applies a policy to regulate discharge into the watercourse. The watercourse is the River Gipping and the River Gipping is the Orwell so the discharge from this site will be hydraulically linked to the designated Orwell Habitats and should again fall within the assessment of the HRA. The immediate river where this would discharge is adjacent to the Island Site of the Sproughton Enterprise Park which has an abundance of protected species and is planned to be designated at a nature reserve. However, contaminates have been identified in the water here this year which appears to have adversely affected the wildlife. This is a wakeup call especially for the Protected Orwell Habitats as the water around the Island site will flow down to the Orwell and threaten those sites, they are the same river. 32.14. Both the HRA and BMSDC need to consider the water run-off discharge from 1600 homes unhampered by regulations in the chemicals they use on their drives and gardens very carefully. The Green infrastructure Framework recommends a preference for Infiltration instead of Attenuation in this area and that may be necessary to filter out any ecological harmful elements in the water run off to the Island Site and the protected Orwell Habitats that sit downstream. 32.15. Wildlife and Biodiversity connect ability (greenways) is also a significant issue to ensure the Ancient tree lined wildlife area of Chantry Park remains substantially connected to the Gipping Valley Corridor to ensure a positive wildlife future for Chantry Park.
35. LA014 Land at Poplar Lane 33.1. The new policy for this site which was designated as a strategic development site under the present Local Plan has, amongst other things, removed all ecological policies.
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33.2. The Strategic Development Site Policy specific to this site against which it was approved ensured an adherence to wildlife, landscape, and other ecological matters but apparently, they are all now removed by Policy LA014 allowing the developer to come forward with the rest of the site that has outline planning approval with a requirement that is worded to only require compliance to: 33.2.1. Open Space provision 33.2.2. Healthcare Provision 33.2.3. Highway improvements 33.2.4. Education provision 33.2.5. Library provision 33.3. This not only removes all the ecological, landscape, design requirements that restricted the site from unreasonable development to avoided harm to the site and the local area, but it is worded to remove compliance to any other requirements applicable in the new JLP 33.4. This is very dangerous with a developer who said they would retain the hedgerows along Poplar Lane for the bats that crossed the site and then as soon as they were on the site ripped them out. 33.5. This site has impact risks for the protected Orwell Habitat areas and was identified in the HRA report as such. But even that did not recognise the appropriate action to implement avoidance from recreational impact by provision of appropriate green and wild spaces in the area for the new residents and it also failed to recognise the significant ecological threat of a SUDS system with an unfiltered final attenuation discharge into the River Gipping and therefor the River Orwell habitats downstream. 33.6. Policy LA014 is virtually now offering the developer a free hand on a site that was brought forward on an understanding it would be regulated against the specific requirements of its specific Strategic Development Site policy. This is completely unacceptable the new policy for this dedicated site should as a minimum replicate the policies its outline planning was approved against.
36. LA018 Sproughton Enterprise Park 33.7. The new policy for this site which was designated as a strategic development site under the present Local Plan has removed all the policies under which its outline planning approval was approved to replace them with a requirement to comply with: ‘the relevant policies set out in the Joint Local Plan’ 33.8. This is unacceptable as some of the policies relevant to the site were specific to the site and those were the conditions that county councilors considered and expected to be conformed to when they granted approval. These are mainly ecological. 33.9. Proposals for redevelopment or re-use of the site must be approached on a comprehensive basis, with full regard to the future of the entire site. A range of land uses will be required, as appropriate to the different parts of the site. Permission will only be granted subject to: 33.9.1. protection of the biodiversity of the locality and any opportunities for enhancement; 33.9.2. protection of the wider river environment in the locality and any opportunities for enhancement; 33.9.3. retention of the natural area known as the island site and existing landscape tracts, together with proposals for further measures; 33.9.4. no adverse impacts on residential amenity; 33.9.5. provision for outdoor recreation on appropriate parts of the site; 33.9.6. provision for improvement of the River Gipping Riverside Path; 33.9.7. production of a green travel plan; and 33.9.8. production of a Flood Risk Assessment. 33.10. This site has impact risks for the protected Orwell Habitat areas and although it was identified in the HRA report it failed to recognise the significant ecological threat of a SUDS system with an unfiltered final attenuation discharge into the River Gipping and assumed there was no hydraulic connection between the commercial sites surface water drainage and the river. This element of the
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sites SUDS design is already built with a large outfall into the River Gipping which is just the name for the upper part of the Orwell and therefor the River Orwell habitats are downstream and any contaminated surface water drainage from the site will flow unfiltered freely downstream to the Habitat Sites. This site and the SUDS system employed should therefore be evaluated within the HRA report as the site only has outline planning approval and further applications for the remaining plots should have their drainage evaluated by the HRA. 33.11. This discharge is also directly into a stretch of river supporting a high level of fish, insects and other species which in turn support many other species some of which are protected. Particularly Otters but also Water Voles, Nesting Kingfishers, Bats and Owls. My understanding is that the HRA should consider protected species and their habitats as well as designated National and European Habitats sites.
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37. Habitats Regulations Assessment including Appropriate Assessment. 37.10. JLP on European designated nature protection areas to fulfil requirements under NPPF to protect these areas from development. In this respect the report supports a general policy to take money from developers to create better managements and facilities for the increased number of residents to visit the protected Habitat Sites particularly those along the Orwell. That policy however in doing so dissolves the policies and protections relevant to local habitats. If you feel that this is the correct thing to do then despite some identified issues in the report this supports that view. 37.11. However, if you feel there should be more consideration for local Habitats and nature areas, a balanced view, or something other than financial payments to exclude responsibility for local nature, or something in-between the following shortcomings in the report have been identified for your consideration. 37.12. Other sites with Protected Species 37.12.1. In relation to the River Orwell which is a designated protected habitat site Sproughton lies within the identified range of potential impact which means any development in our area has to assessed against impact on the Orwell Sites. 37.12.2. Other local Habitat sites like the West end of Chantry Park, Belstead Brook, the SEP Island Site and other nature/country park areas do not in themselves have been considered in relation to any adverse impact as they do not have European status. However, the species on these sites do have protected status, especially Otters, Dormice and Bats and several species on the British protected lists like Water Voles, Grass Snakes etc. 37.12.3. Developments close to these sites not only represent an adverse recreational use impact on both the sites and the protected species in them or the adverse impact of noise vibration and light from commercial development but also the significant risk created by the introduction of large numbers of roaming predatory domestic cats on the vulnerable ecology and protected species on the sites. 37.12.4. Our understanding is this report should also consider protected species, not just protected habitats which if correct it does not. 37.13. Water Quality Impact 37.13.1. In relation to Water Quality Impact an assumption is drawn from previous cases that no consideration should be given to contamination impacts unless a source is hydraulically connected to the Habitat Site. In effect hydraulically connected means directly by water with no intermediate filtration medium. 37.13.2. Of the sites in Sproughton LA012 is close to the River Gipping which is the extension of the river Orwell. It has not been established if the SUDS drainage system proposed for this site will be exclusively Infiltration or will include Attenuation basins discharging directly or indirectly into the River Gipping. If this is the case it will be Hydraulically linked to the River Orwell which is the same river but by a different name. 37.13.3. In the case of LA018, the SEP, a large dedicated discharge from the sites Attenuation Basins has already been built into the River Gipping and so there is clear evidence of Hydraulic links to the River Orwell 37.13.4. In the case of LA014 The Taylor Wimpey Wolsey Grange stage 1 site the application provides surface water drainage through a system of attenuation/Infiltration basins that finally feed into a large Attenuation basin created by damming part of the valley. This then discharges via the existing surface drainage system which for the most part is an open drainage ditch into the Gipping. This is a direct hydraulic link from the Dam, via the ditches into the Gipping and therefore the River Orwell. 37.13.5. In the case of LA013 The Taylor Wimpey Wolsey Grange stage 2 site the SUDs systems has be at the base of the development which places them at the bottom of the valley and
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therefore in a position and height unlikely to be able to cope with such a large development purely by infiltration. The only logical position for these would again involve attenuation with water being discharged into the Gipping. 37.13.6. Downstream of all these proposed developments is the SEP Island site which is in itself an important Habitat Site with identified Water Voles, Otters, Grass Snakes, Slow worms, Bats, Owls, Nesting Kingfishers, and many more other important and protected species reliant on its ecology. This site has in the last year seen a reduction in the occurrences of larger Nesting Birds like swans and geese and one problem identified in a survey by Geosphere for the SEP is water contamination. Indeed, in the last couple of years there has been occurrences of Red and Green blooms in the river. The river is still being investigated by Geosphere however there is a real risk that the adverse impact on the island site will carry downstream to the Orwell Habitat sites. Therefore, any risk from proposed developments to this Island Habitat is a risk to the Orwell Habitat Sites. 37.13.7. The report appears to focus more on industrial contamination. This is a threat from the SEP as a commercial site with its surface water run off linked hydraulically to the Gipping and yet LA018 actually removes all the ecological conditions previously applied to this site from its policy. However, I would argue the biggest ecological threat is from residential surface water run-off. Farming and Commercial businesses are subject to strict controls in relation to contamination / pollution whereas residents are not. There is the potential for the use of all manner of cleaning, fertilising, herbicides and other chemicals and concoctions harmful to the ecology being used by private residents that in any system with a runoff into the rivers will pose an ecological threat. 37.13.8. LA013 and LA014 the combined Wolsey Grange site represents the biggest housing project in BMSDC JLP with approximately 1,600 homes plus associated community buildings and areas. This poses a significant ecological threat that should be considered in its entirety as it will almost certainly have a common discharge into the River Gipping. It will therefore be hydraulically linked to the Orwell Habitat sites and therefore needs specific consideration and yet the JLP policies have removed all the previous ecological restraints in favour of a mitigation payment. 37.13.9. LA012 is also devoid of any site-specific ecology policy in favour of mitigation payments. 37.14. Recreational Impact of Residential Development 37.14.1. Both this report and the RAMs reports which proposes mitigation measures for the Orwell focus away from the preferred option under both Natural England (NE) and National Planning Policy Framework (NPPF) guidance to avoid impact by diverting footfall away from the habitat sites. Instead both focus on 106 charges to developers. Money for mitigation instead of avoidance. 37.14.2. There is a focus on methods and timetables for securing appropriate contributions from developers for mitigation measures in the form of rangers, paths, car parks etc. agreed with various organisations including wildlife authorities. But there is no clarity as to why the preferred options have not been pursued or considered both generally and specifically for individual sites. Just a blind reliance on the easy option of demanding money from a developer. 37.15. Quotes from report and the Technical Report for RAMS 37.15.1. “Alternative recreation options should be located at convenient points for many users and offer facilities sufficient to attract some people from European sites.” 37.15.2. ‘The mitigation hierarchy requires any effects to firstly be avoided, with any remaining effects that cannot be avoided being adequately mitigated for.’ 37.15.3. ‘The appropriate assessment stage considers any effects that have not been avoided and will look at the effectiveness of mitigation or minimization measures that could be applied to
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reduce an effect to an acceptable level. The final stage of the ‘mitigation hierarchy’ is the use of compensation as a last resort’ 37.15.4. ‘The mitigation hierarchy concept of avoid before mitigate, and mitigate before compensate, whilst at the same time seeking enhancements, is an established process in the assessment of impacts on the natural environment, promoted in the Royal Town Planning Institute publication ‘Good Practice Guide - Planning for Biodiversity’ 1999, republished in 2001. The mitigation hierarchy is now incorporated into the National Planning Policy Framework’. 37.15.5. ‘Where housing growth will be significant in one particular location, large scale natural greenspaces are an additional measure, which are delivered individually within development projects. These provide an alternative to recreation on European sites are referred to as Suitable Alternative Natural Greenspaces (SANGs). The need for SANGs as an additional measure may be identified as new housing allocations are brought forward with Local Plan reviews. 37.15.6. LA013 and LA014 the combined Wolsey Grange development sits in Chantry Vale a green valley between Chantry Park, The River Gipping and the village of Sproughton. Although already subject to adverse planning due to the A14 and the SEP it still retains its Character of a rural Vale with sunken country lanes, rolling fields and ancient trees with the Listed and impressive Red House with its ancient Barns set in its midst. 37.15.7. The landscape character mix in the Vale, although not unique, consisting of a mix of Rolling Valley Farmlands, Meadowlands topped around its perimeter with Plateau farmlands bordered by the ancient and listed Tree line of Chantry park appears to only be matched in Suffolk in the Dedham Vale AONB in the area of Flatford Mill. 37.15.8. Sproughton village consists of a large group of old buildings many of which are listed residential and agricultural buildings. Ramblers taking one of the circular routes that pass though the village do so to take in these buildings and the way they still sit traditionally within the surrounding historic farmland landscape. 37.15.9. Along the river the Listed Mill and the Nature and Wildlife opportunities provide a further dimension of interest to Ramblers taking in these walks. 37.15.10. Many ramblers and cyclist from Ipswich transit through the Vale either along Church Lane or Churchman’s Way and then through Sproughton and return along the River Path as part of a circular route from Ipswich taking in the listed parklands of Chantry Park, The Landscape of Chantry Vale, The old listed buildings in the village of Sproughton and The Nature and Wildlife Habitat along the River Gipping Path. Others take a similar circular route along the Gipping from Bramford returning along Lorain Way. 37.15.11. Removing the attraction of the Vale or harming the ancient landscape as it interacts with the ancient agricultural edge of Sproughton will divert recreational users from Ipswich to other nearby sites of interest, and that potentially means towards the Orwell habitat Sites. 37.15.12. Wolsey Grange 1 and Wolsey Grange 2 represent the biggest residential developments in this JLP with around 1,600 homes, potentially well in excess of 3000 residents with a desire to enjoy the nature areas around them. This represents a significant threat of increased recreational visitors to the Habitat sites on the Orwell. 37.15.13. Development that diminishes the landscape and Nature value of these surrounding walks will divert both new residents and present users from Ipswich who will no longer use these routes away potentially towards the Orwell Habitat sites. 37.15.14. A double adverse ecological whammy this report has failed to recognise. 37.15.15. NE and NPPF clearly recommend Habitat Impact avoidance as the first consideration and that can be done by designating SANG’s (Suitable Alternative Natural Greenspace provision) to preserve the best of this area for recreational use diverting recreational users away from the Orwell Habitat sites. There is no reason why planning officers cannot pursue such a policy or why
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it has not been considered in this report. Neither a Developers, nor an LPA’s desire to develop an area is an ‘Imperative Reasons of Overriding Public Interest to justify this. There has to be some overriding reason why a development has to go in some place, in some way, that cannot be done some other place or, some other way that is acceptable.
Sproughton Working Group is happy to engage with Babergh District and to help ensure that the new Local Plan meets the needs of our local community, providing a framework for sustainable growth through to 2036. Sproughton Working Group would like to see Babergh District engaging with, listening to and incorporating the views of our parishioners in the refreshed Joint Local Plan.
Yours sincerely
Rhona Jermyn Chair, Sproughton Working Group
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