Section Two: Your Representation

For Official use only:: JOINT LOCAL PLAN CONSULTATION JULY 2019 Date Acknowledged: Reference:

Please indicate what part of the document you are commenting upon and use one box per comment. If your comment is more than 100 words please provide a summary.

Respondent Name / Organisation: Strutt & Parker for Hopkins Homes Ltd

Please be specific what document / part your comment below relates to: Document: Joint Local Plan Preferred X Section / Options Document option / ( Fringe) (mark ‘x’) question / Site Allocation Sustainability Appraisal site LA012 (mark ‘x’) Please indicate the nature of your comment: (mark ‘x’)

Support X Object X Comment

Please enter your comment below: (Continue on a separate sheet if necessary)

Our representations recommend the inclusion of the land east of Road, Sproughton as an allocation for residential development of up to 50 dwellings – either in addition to the existing proposed allocation Site LA012, or instead of this site allocation on the basis that the land east of Bramford Road, Sproughton is in a more sustainable location and would not result in significant landscape impact.

The Site, Land East of Bramford Road, Sproughton, is currently the subject of a full planning application for residential development – LPA reference: DC/18/02010 (and a duplicate application DC/18/02412). Application DC/18/02010 was presented to the Council’s Planning Committee in April 2019 with an officer recommendation for approval.

Detailed technical reports and documents supporting the planning application, which have been with the Council for 18 months demonstrate that the land east of Bramford Road, Sproughton, is a sustainable location for new residential development – it is very close to the existing village centre and its facilities and amenities, and can be sensitively developed for housing without significant landscape impact. The location of the Site also represents a natural extension to the built-up area of the village, and the latest proposed site layout plans also demonstrate that any impact on the setting of nearby heritage assets can be minimised to a ‘low level of less than substantial harm’, which would be outweighed by the public benefits of the proposals.

We consider that any development of the draft site allocation ‘Land north of Burstall Lane and west of B1113’ (Site Ref: LA012) would not follow the pattern of settlement in the valley. The site lies on the open slopes of the valley side where development will be far more visible and out of character. The Development Management guidelines for the rolling Valley Farmlands notes: “Settlement extension in

2 a valley side landscape is likely to have a significant visual impact and adversely affect the character of the landscape”.

In contrast to the draft allocation site (Site LA012), which has no natural boundaries to the west and north, the Site to the east (Land east of Bramford Road, Sproughton) is well contained by the existing trees along its northern and western boundaries, the existing settlement to the south as well as woodland within the Gipping Valley to the east. As such, this site provides a logical and sustainable extension to Sproughton where development would have a relatively limited landscape impact.

Full details are contained in our separate representations report and should be read in conjunction with this form.

Please enter a summary below if your comment is more than 100 words: Our representations recommend the inclusion of the land east of Bramford Road, Sproughton as an allocation for residential development of up to 50 dwellings – either in addition to the existing proposed allocation Site LA012, or instead of this site allocation on the basis that the land east of Bramford Road, Sproughton is in a more sustainable location and would not result in significant landscape impact.

Respondent Name / Organisation: Strutt & Parker for Hopkins Homes Ltd

Please be specific what document / part your comment below relates to: Document: Joint Local Plan Preferred Section / Sproughton Options Document option / (Ipswich Fringe) (mark ‘x’) question / Site Allocation Sustainability Appraisal X site LA012 and (mark ‘x’) Alternative Site ALT13 Please indicate the nature of your comment: (mark ‘x’)

Support X Object X Comment

Please enter your comment below: (Continue on a separate sheet if necessary)

The Sustainability Appraisal (SA) provides an assessment of all the proposed residential site allocations, as well as those alternative sites that were not selected for allocation. The SA therefore offers a justification for the Council’s draft site selection. In respect of Sproughton, the two potential residential site allocations are considered and assessed under the following references:

Site LA012 – Land North of Burstall Lane and West of B1113, Sproughton (Annex E, Table 20, pages 105-109); and,

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Site ALT13 – Land East of Loraine Way, Sproughton (Annex E, Table 33, pages 164-168) - currently the subject of planning applications by Hopkins Homes - DC/18/02010 and a duplicate application DC/18/02412 – Land East of Bramford Road, Sproughton.

When judged against the sustainability criteria as a whole (as set out in Annex C, chapter 2, of the SA), there is little to choose between the two sites, although on the basis of this high-level assessment, Site ALT13 is ‘red-flagged’ (“strong prospect of there being minor negative impacts and mitigation would be possible”) on individual questions within three of the sustainability objectives (10, 11 and 13).

However, since our client’s planning applications (and their extensive supporting technical reports) have been under consideration now for nearly 18 months, the Council should be aware that these issues do not justify rejection of the site for residential development, and that, in the case of nature conservation impact, that the comments are wholly incorrect. Indeed, it is the case that planning application DC/18/02010 was recommended for approval by officers back in April 2019.

SA Objective 10 concerns the risk of flooding and in this respect it must be noted that only a very small section of the north-eastern margin of the site is within Flood Risk Zones 2 and 3 and this part of the site is not proposed for development – i.e. all dwellings and roads would be outside of the Flood Zone 2 and 3 areas. A revised Flood Risk Assessment (FRA) has now been prepared for the latest revised layout, which demonstrates that the site will be able to discharge surface water via infiltration, with infiltration tests confirming the suitability of this approach. The surface water run-off from the site can therefore be catered for both in terms of discharge and pollution mitigation. Micro-drainage calculations within the FRA demonstrate the feasibility of the proposed drainage strategy and SuDS selection. The information within the revised FRA demonstrates that the site will appropriately deal with its storm water in the 1-in-100-year event (with +40% allowance for climate change) and that the feasibility of the development can be adequately proven. Overall the proposed development will address and mitigate any risk from flooding in line with the policies set out in the NPPF.

SA Objective 11 concerns biodiversity and geodiversity and the commentary within the site specific assessment for Site ALT13 notes that development would be likely to impact on NNRs, LoWSs, LNRs, CWS or Ancient Woodland. This assessment is erroneous - there are no statutory and non- statutory designated sites or ancient woodland habitats (or other priority habitat types listed under Section 41 of the 2006 Natural Environment and Rural Communities Act, 2006) likely to be impacted by residential development within the site or within the zone of influence of the site according to current spatial data held by the Biodiversity Information Service. Consequently, the commentary should be amended and the site ‘green flagged’ under question 11.2.

SA Objective 13 seeks to conserve and enhance the quality and local distinctiveness of landscapes and townscapes, and suggests that because there is a Tree Preservation Order (TPO) on one tree on the site, there is a strong prospect of there being minor negative impacts. However, the only tree that is the subject of a TPO would be retained, and form a key feature of the new area of public open space proposed as part of the residential development.

The conclusions of the SA in respect of the Site (Land east of Bramford Road, Sproughton), which is listed as ‘Land East of Loraine Way, Sproughton’ (Site ALT13), suggest a heavily constrained site, however, development would not have any impact on any County Wildlife Site, flooding is not an issue, and the tree that is the subject of a TPO is proposed to be retained within any residential development. In addition, a Heritage Impact Assessment (HIA) has been submitted with the planning applications, and the proposals have been further revised (and the total number of dwellings reduced), to reduce

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the potential impact on the setting of heritage assets to a ‘low level of less than substantial harm’. A revised HIA also concludes that the public benefits of the proposals would outweigh this level of harm.

It must be concluded therefore, that the SA assessment of Site ALT13 is erroneous and does not justify rejection of the site for residential development. Indeed our detailed representations (see separate report), conclude that Site ALT13 is a more sustainable option for a residential site allocation, and one that would follow the pattern of the settlement in the Gipping Valley and result in significantly less visual impact and adverse affects on the character of the landscape, when compared to the proposed site allocation – Site LA012.

For these reasons, we do not believe that the SA provides any justification for the rejection of Site ALT13 as a residential site allocation. We therefore strongly recommend the inclusion of the land east of Bramford Road, Sproughton (Site ALT13) as an allocation for residential development of up to 50 dwellings – either in addition to the existing proposed allocation Site LA012, or instead of this allocation.

Please enter a summary below if your comment is more than 100 words:

The SA assessment of Site ALT13 is erroneous and does not justify rejection of the site for residential development. Indeed our detailed representations (see separate report), conclude that Site ALT13 is a more sustainable option for a residential site allocation, and one that would follow the pattern of the settlement in the Gipping Valley and result in significantly less visual impact and adverse affects on the character of the landscape, when compared to the proposed site allocation – Site LA012.

We therefore strongly recommend the inclusion of the land east of Bramford Road, Sproughton (Site ALT13) as an allocation for residential development of up to 50 dwellings – either in addition to the existing proposed allocation Site LA012, or instead of this allocation.

PLEASE ENSURE YOU HAVE READ AND SIGNED THE DECLARATION ON THE RESPONDENT DETAILS PAGE EARLIER

Thank you for taking the time to comment

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REPRESENTATIONS TO BABERGH & MID SUFFOLK JOINT LOCAL PLAN – PREFERRED OPTIONS DOCUMENT

Land on the East Side of Bramford Road, Sproughton, Suffolk

Prepared by Strutt & Parker on behalf of Hopkins Homes

September 2019 Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

Land on the East Side of Bramford Road, Site Name: Sproughton, Suffolk

Client Name: Hopkins Homes

Type of Report: Joint Local Plan Representation

Prepared by: Paul Sutton BTP MRTPI Dip Urban Design IHBC

Checked by: Chris Smith (Hopkins Homes)

Date: 20/09/2019

COPYRIGHT © STRUTT & PARKER. This publication is the sole property of Strutt & Parker and must not be copied, reproduced or transmitted in any form or by any means, either in whole or in part, without the prior written consent of Strutt & Parker. Strutt & Parker does not accept any liability in negligence or otherwise for any loss or damage suffered by any party resulting from reliance on this publication.

Strutt & Parker, 66 – 68 Hills Road, Cambridge, Cambs. CB2 1LA [email protected] Tel No: 01223 789391

Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

CONTENTS

1. INTRODUCTION ...... 4 2. PLANNING BACKGROUND ...... 6 3. SETTLEMENT CONTEXT ...... 10 4. JOINT LOCAL PLAN – PREFERRED OPTIONS CONSULTATION ...... 13 5. CONCLUSIONS ...... 17

Version Description Originated Authorised/comments Date

Draft For comment PS 24/09/2019

Final For submission

Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

1. INTRODUCTION

1.1 These representations are being submitted on behalf of Hopkins Homes and relate to a site in the village of Sproughton that is currently the subject of a full planning application for residential development – LPA reference: DC/18/02010 (and a duplicate application DC/18/02412). These applications were submitted by Hopkins Homes in May 2018 and are still under consideration by the District Council.

1.2 The Site (Land East of Bramford Road, Sproughton) is situated immediately adjacent to the defined ‘built-up area boundary’ of the village of Sproughton, which is identified in the emerging Joint Local Plan as a ‘Core Village’ within the Ipswich Fringe, where a significant level of new housing development is envisaged – 24% of the total number of new homes for the over the new Joint Local Plan period, 2018 – 2036.

1.3 While the emerging Joint Local Plan identifies a number of significant site allocations (for both housing and employment development) within the Sproughton Parish, the largest of these do not adjoin the village and are located on the western edge of Ipswich to the east of the A14 trunk road. Only one housing site allocation is proposed on the edge of the built-up area of the village – Site LA012: Land north of Burstall Lane and west of B1113, Sprougton – for approximately 75 dwellings.

1.4 These representations recommend the inclusion of the land east of Bramford Road, Sproughton as an allocation for residential development of up to 50 dwellings – either in addition to the existing proposed allocation Site LA012, or instead of this site allocation on the basis that the land east of Bramford Road, Sproughton is in a more sustainable location and would not result in significant landscape impact.

1.5 Our representations demonstrate that the land east of Bramford Road, Sproughton is in a sustainable location close to the existing village centre and its facilities and amenities, and can be sensitively developed for housing without significant landscape impact. The location of the site (land east of Bramford Road, Sproughton) also represents a natural extension to the built-up area of the village, and the latest proposed site layout plans also demonstrate that any impact on the setting of nearby heritage assets can be minimised to a ‘low level of less than substantial harm’, which would be outweighed by the significant public benefits of the proposals – including 17 affordable dwellings.

1.6 The map overleaf shows the boundary of the site referred to in this report as ‘Land east of Bramford Road, Sproughton.’

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

Site Location Plan

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

2. PLANNING BACKGROUND

2.1 Representations in respect of the site ‘Land east of Bramford Road, Sproughton’ (hereafter called ‘the Site’), have been made by Hopkins Homes at each of the consultation stages of the emerging Joint Local Plan, suggesting that the site should be allocated for residential development.

2.2 The Site was submitted at the ‘call for sites’ stage and included within the Council’s Strategic Housing and Employment Land Availability Assessment (SHELAA) as site reference SS0711. The assessment concluded that the Site was potentially suitable for residential development, taking into account the identified constraints (highways/access, biodiversity issues, and impact on heritage assets). The estimated site capacity was 70 dwellings.

2.3 The Site was also included in the ‘Issues and Options’ Joint Local Plan consultation document in August 2017 as one of two potential residential site allocations (see map extract below). The other site, ‘Land north of Burstall Lane and west of B1113’, was also identified through the SHELAA (Site Ref: SS0223), and noted as having capacity for up to 75 dwellings. The consultation responses show a similar level of objection from the local community for each site.

Site Ref: SS0711

Site Ref: SS0223

Extract from Babergh Mid Suffolk Joint Local Plan: Consultation Document (August 2017) - Sproughton

2.4 The Site (‘Land east of Bramford Road, Sproughton’) is currently the subject of a full planning application for residential development – LPA reference: DC/18/02010 (and a duplicate application DC/18/02412). These applications were submitted to the Council in

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

May 2018 following consultation with the local community (public exhibition of draft proposals in September 2017), and a meeting with the Parish Council (on 26/01/2018). At this earlier consultation stage, the proposed development comprised 67 dwellings. A formal request for pre-application planning advice was also submitted to the Council in August 2017 and their response was received by letter dated 25/10/2017. The Council’s advice concluded that changes should be made to the proposed layout in order to respect the setting of heritage assets, and to retain a view of the church tower across the site from the B1113 (Bramford Road).

2.5 Revisions were made to the proposals prior to submission of the full planning applications in May 2018 and the number of dwellings was reduced to 64. An area of open space was also included within the layout immediately adjacent to the nearest listed buildings. During the course of consideration of the applications by the Council’s officers, it was evident that they still had concerns about the impact of the proposals on the setting of nearby heritage assets; consequently, further revisions were made to the layout in February 2019 (including increasing the area of open space adjacent to the nearest heritage assets), and the number of dwellings was reduced to 54 units.

2.6 The planning application DC/18/02010 (‘Land east of Bramford Road, Sproughton’) was considered by the Council’s Planning Committee on 17th April 2019, which was described as: “residential development of 54 dwellings with new vehicular access from Branford Road (B1113), associated parking, landscaping and open space.” The planning officer’s report recommended that authority be delegated to the Chief Planning Officer to approve the application, subject to the prior agreement of a Section 106 Planning Obligation. However, the Committee resolved to refuse the application on the grounds that the proposed development would lead to a ‘medium level of less than substantial harm’ to the setting of heritage assets, and that the public benefits of the scheme would not outweigh this harm. To date, no decision notice has yet been issued due to further discussions on the design and layout of the proposed development.

2.7 Following further discussions with the Council’s planning officer during Summer 2019, the number of dwellings proposed was reduced still further to 49 units, to allow for an even larger area of open space within the vicinity of the nearest heritage assets, and to move the nearest proposed dwellings further away from these heritage assets. These discussions are still ongoing at the time of writing this report. However, it is expected that this issue will be able to be resolved to the satisfaction of the Council’s planning and heritage officers, and that a further positive report will be able to be considered by the Council’s Planning Committee in the very near future.

2.8 The plan below shows the current proposed layout for the Site, which would comprise:

 32 open-market houses and bungalows (13 x 2 bed; 11 x 3 bed; and 8 x 4 bed)  17 affordable dwellings (6 x 1 bed; 9 x 2 bed; and 2 x 3 bed)  New access from the B1113 Bramford Road  Significant areas of public open space  New footpath links through the site connecting into the village

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

Proposed Site Layout Plan – DC/18/02010

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

2.9 A hybrid planning application for residential development has also been submitted by Pigeon Land on ‘Land north of Burstall Lane and west of B1113’ (including SHELAA Site Ref: SS0223), in February 2019 and is currently under consideration by the Council (LPA Ref: DC/19/00567). This application is described as:

“Hybrid application comprising: outline planning application (access to be considered) erection of up to 114 dwellings, including 13 self-build/custom build plots, affordable housing, open space including village green, land for B1(a) offices and D1 nursery, provision of land to extend grounds of Wild Man Public House, village allotments, paddocks and caravan storage; Full planning application for Spine Road and associated highway works.”

2.10 However, it is clear that the application site does not respect the boundary of the draft Site Allocation LA012 as shown in the emerging Joint Local Plan.

DC/19/00567 - Land north of Burstall Lane and west of B1113 – Indicative Layout with draft Joint Local Plan Site Allocation in red

2.11 The plan above shows the indicative layout of the development proposed in application DC/19/00567, as well as the boundary of the draft Site Allocation LA012 as shown in the emerging Joint Local Plan (in red).

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

3. SETTLEMENT AND SITE CONTEXT

3.1 Sproughton is located approximately 4km to the west of Ipswich, immediately west of junction 54 of the A14 trunk road. The village is located on the western side of the on the edge of the flood plain and extends up the lower slopes of the valley sides towards the B1113. Well-rounded slopes provide containment to the north and south-west of the village. The land rises from the banks of the river to the west and south-west - from around 5 metres AOD to 15 metres AOD at Burstall Lane (close to the Wild Man public house), although the majority of the more recent development in the village is located between the 5 and 10 metre contours.

3.2 The historic core of the village is located around the Parish Church of All Saints, close to the crossing point over the River Gipping at Sproughton Bridge. Sproughton Bridge represents an historic crossing point of the River Gipping and provides the only entrance into the village from the east. The historic core of the village contains several listed buildings, including: Sproughton Hall, the Root Barn, the Tithe Barn, Mill House, the Mill, and the Parish Church of All Saints.

3.3 Most of the residential expansion of the village occurred in the late 20th century, which saw the construction of a number of housing estates laid out on cul-de-sac layout principles. These include: Ransome Close (off Burstall lane) in the 1970s; Oak Grove (off High Street) in the 1990s; Church Crescent and Beech Close (off Church Lane) in the 1960s/70s; and Glebe Close and Gipping Way (also off Church Lane) also in the 1960s. In addition, a new primary school was built on the west side of Church Lane (in the 1960s/70s), and a number of blocks of flats around Sproughton Court (on the west side of High Street) in the 1980s.

3.4 The Site (Land East of Bramford Road, Sproughton) extends to around 3.45ha (8.52 acres) of land, which includes several small paddocks in the southern half of the Site, and a larger area of rough pasture in the northern half of the site. The B1113 minor road is located to the west of the Site, which runs straight in a north-south direction between the village and the neighbouring village of Bramford to the north. The eastern boundary of the Site is contained by an area of existing woodland on the west bank of the River Gipping, and the gardens and grounds of Sproughton Hall. The Site adjoins the barn to the south-west of Sproughton Hall, which has been converted to a dwelling, and the Tithe Barn fronting onto Lower Street, which is used as a community shop, meeting rooms and sports hall. The western boundary of the Site is bordered by an existing tree belt that provides separation from the wider, open countryside to the west of the Site.

3.5 Most of the properties on the north side of Lower Street back onto the Site, together with three properties in Bramford Road – Forge House, Cardinalls and the Police House – which adjoin the south-western boundary of the Site. The Site is visually contained by existing natural features and the properties on the northern edge of the village. There are only two existing buildings on the Site – a large hay barn (modern construction) and a smaller storage building to the north of the barn.

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

3.6 The Site is generally flat with no significant changes in level although the land gently rises to the south-west from around 5 metres AOD in the north-east corner, to around 13 metres AOD adjacent to the car park of the Wild Man public house.

Sustainability Map - Sproughton

3.7 The Site is situated in a particularly sustainable location, being within easy walking distance of the facilities provided within Sproughton (the site is situated within 400 metres of the centre of the village). These facilities include a primary school, a pub/restaurant, community shop and sports hall, the Parish Church, post office, a bowls club, tennis courts and playing field. In addition to Sproughton Church of Primary School, the village is also served by a number of secondary schools within Ipswich (Chantry Academy and Westbourne Academy) as well as Claydon High School in Claydon, 5.5km north of the village. The Suffolk ‘One’ sixth form college is also located 2.5km south of the village on the edge of Ipswich.

3.8 In addition to the above facilities, daily bus services pass through the village, with bus stops located on nearby Lower Street and on the B1113 (Loraine Way) to the south- west. These services (routes 18A, 89A, 111, 111A and 120) provide direct access to the larger settlements of Stowmarket and Ipswich (including ‘Suffolk One’), which are both connected to the rail line, as well as a number of other local villages including: Hitcham, Somersham, Claydon, and .

3.9 The Site lies on the northern edge of the village, on the transition of the Rolling Valley Farmlands, Landscape Character Type (LCT18) and the Valley Meadowlands (LCT26); as defined in the Suffolk Landscape Character Assessment. The development of the Site would continue the historic settlement pattern of the villages in the Gipping Valley where built form in both Sproughton and Bramford lie to the east of Bramford Road/

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

Lorraine Way. The road forms a distinct separation between the more enclosed/wooded valley meadowlands of the Gipping and the open countryside on the slopes of the valley sides.

3.10 In terms of potential landscape impact, the Site comprises low-lying land that is well- contained by existing landscape features: woodland and tree belts to the east and north; and a line of existing mature trees along the western boundary to Bramford Road. The southern boundary of the Site immediately adjoins the built-up area at the centre of the village, along with a short section of the western boundary. In contrast, the land on the west side of Bramford Road, which is proposed as a draft housing site allocation in the emerging Joint Local Plan, has no natural boundary to the west or north and is situated on rising land towards the south-west. The land is very open and housing development in this location would be likely to have a much greater visual impact on the wider countryside.

3.11 The land on the west side of Bramford Road, proposed as a draft housing site allocation (Site LA012), is also more remote from the services and facilities in the village, especially the local primary school which could only be reached on foot by crossing the busy B1113. The proposed allocation also includes existing allotments, which are currently well placed to serve the village. Any replacement of the allotments further north or west would not be as convenient and would be remote from most residents in the village, and certainly not within walking distance.

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

4. JOINT LOCAL PLAN – PREFERRED OPTIONS CONSULTATION

4.1 Sproughton is identified as a ‘Core Village’ within the Ipswich Fringe in the emerging Joint Local Plan. Historically, the Babergh and Mid Suffolk Ipswich fringe areas have been strategic designations as growth areas in recognition of the cross-boundary influence of the county town of Ipswich as a regional service centre. This strategic area is proposed to remain in the new Joint Local Plan.

4.2 Policy SP04 of the Joint Local Plan sets out a spatial distribution of housing across the Babergh and Mid Suffolk districts. Within the Babergh Ipswich Fringe area 1,977 new homes are proposed during the Local Plan period (2018 - 2036). The Babergh Ipswich Fringe area includes the settlements of: ; and ; Pinewood; Sproughton; (Bourne Hill); and Wherstead Park. The table below sets out the levels of housing expected in each settlement:

Babergh Ipswich Fringe Settlement New homes (2018 – 2036)

Belstead 14 Copdock & Washbrook 238 Pinewood 0 Sproughton 1,650 Wherstead (Bourne Hill) 75 Wherstead Park 0 TOTAL 1,977

4.3 From the above it can be seen that Sproughton (Parish) is expected to provide a significant amount (83%) of the total amount of new homes to be provided within the Babergh Ipswich Fringe area. This is largely a reflection of the extent of available development land within the Parish on the east side of the A14 trunk road, but is also due to the fact that the village of Sproughton is also the largest and most sustainable settlement within the Babergh Ipswich Fringe area, which contains a primary school and other services and facilities (see paragraph 3.7).

4.4 The proposed allocation of Site LA012 (Land north of Burstall Lane and west of B1113) indicates that the village of Sproughton is considered to be a sustainable location for future housing growth, which would help to support existing local services and facilities. However, this site seems an unusual choice given the historic settlement pattern of the village, and the fact that it is very open in landscape terms and lacking any natural boundaries to the west and north. In addition, 50% of the site is currently used as allotments which even if replaced, would be located further from the village they serve – it makes no sense to build houses further from the edge of the village and retain the allotments so their re-provision will inevitably be on the very extremity of the village.

4.5 The Sustainability Appraisal (SA), which forms a key part of the evidence base for the emerging Joint Local Plan, provides an assessment of all the proposed residential site allocations, as well as those alternative sites that were not selected for allocation. The

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

SA therefore offers a justification for the Council’s draft site selection. In respect of Sproughton, the two potential residential site allocations are considered and assessed under the following references:

Site LA012 – Land North of Burstall Lane and West of B1113, Sproughton1; and, Site ALT13 – Land East of Loraine Way, Sproughton2 (currently the subject of planning applications by Hopkins Homes - DC/18/02010 and a duplicate application DC/18/02412 – Land East of Bramford Road, Sproughton).

4.6 When judged against the sustainability criteria as a whole (as set out in Annex C, chapter 2, of the SA), there is little to choose between the two sites, although on the basis of this high-level assessment, Site ALT13 is ‘red-flagged’ (“strong prospect of there being minor negative impacts and mitigation would be possible”) on individual questions within three of the sustainability objectives (10, 11 and 13):

SA Objective Key Question Timescale Commentary

10: to reduce vulnerability 10.1 – will it minimise the risk Short – long Site is within Flood and increase resilience to of flooding to people and term Risk Zones 2 and 3 extreme weather events and property from rivers and flooding which may be watercourses? caused by climate change.

11: to conserve and enhance 11.2 – will it maintain and Short – long Development likely to biodiversity and geodiversity enhance nationally designated term impact on NNRs, nature conservation sites? LoWSs, LNRs, CWS or Ancient Woodland.

13: to conserve and enhance 13.2 – will it reduce the Short – long TPO on site the quality and local amount of derelict, degraded term distinctiveness of landscapes and under-used land? and townscapes.

4.7 Given that our client’s planning applications (and their extensive supporting technical reports) have been under consideration now for nearly 18 months, the Council should be aware that these issues do not justify rejection of the site for residential development, and that, in the case of nature conservation impact, that the comments are wholly incorrect. Indeed, it is the case that planning application DC/18/02010 was recommended for approval by officers back in April 2019.

4.8 In respect of flood risk, only a very small section of the north-eastern margin of the site is within Flood Risk Zones 2 and 3 and this part of the site is not proposed for development – i.e. all dwellings and roads would be outside of the Flood Zone 2 and 3 areas. A revised Flood Risk Assessment (FRA) has now been prepared for the latest revised

1 Sustainability Appraisal, Annex E, Table 20, pages 105-109 2 Sustainability Appraisal, Annex E, Table 33, pages 164-168

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

layout, which demonstrates that the site will be able to discharge surface water via infiltration, with infiltration tests confirming the suitability of this approach. The surface water run-off from the site can therefore be catered for both in terms of discharge and pollution mitigation. Micro-drainage calculations within the FRA demonstrate the feasibility of the proposed drainage strategy and SuDS selection. The information within the revised FRA demonstrates that the site will appropriately deal with its storm water in the 1-in-100-year event (with +40% allowance for climate change) and that the feasibility of the development can be adequately proven. Overall the proposed development will address and mitigate any risk from flooding in line with the policies set out in the NPPF.

4.9 SA Objective 11 concerns biodiversity and geodiversity and the commentary within the site specific assessment for Site ALT13 notes that development would be likely to impact on NNRs, LoWSs, LNRs, CWS or Ancient Woodland. This assessment is erroneous - there are no statutory and non-statutory designated sites or ancient woodland habitats (or other priority habitat types listed under Section 41 of the 2006 Natural Environment and Rural Communities Act, 2006) likely to be impacted by residential development within the site or within the zone of influence of the site according to current spatial data held by the Suffolk Biodiversity Information Service. Consequently, the commentary should be amended and the site ‘green flagged’ under question 11.2.

Land East of Bramford Road, Sproughton – SBIS Data Search Results

4.10 SA Objective 13 seeks to conserve and enhance the quality and local distinctiveness of landscapes and townscapes, and suggests that because there is a Tree Preservation Order (TPO) on one tree on the site, there is a strong prospect of there being minor negative impacts. However, the only tree that is the subject of a TPO would be retained,

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

and form a key feature of the new area of public open space proposed as part of the residential development (see proposed site layout plan on page 8).

4.11 Therefore, it can be concluded that the Sustainability Appraisal only provides a very high level assessment of the relevant site constraints, and that these have now been more than adequately addressed in the detailed supporting information provided with the planning application that is currently still under consideration. It is also noted that the assessment of the likely impact of any development on national and locally designated sites of nature conservation value is completely erroneous.

4.12 The conclusions of the SA in respect of the Site (Land east of Bramford Road, Sproughton), which is listed as ‘Land East of Loraine Way, Sproughton’ (Site ALT13), are set out below:

“The site is proposed for residential development and has a good relationship to the wider transport network via the A14. Development would also be likely to have an impact on a County Wildlife Site therefore proposals must consider the scale and type of development, as well as this, there is a TPO on site, which should be retained within any development going forward. The site will require a Heritage Impact Assessment and proposals must consider scale/ design and layout due to its proximity to listed buildings. The site is also within FRZs 2 & 3; flood risk should be avoided through effective site layout. The site is within 100m from nearest water source and within Groundwater Source Protection Zone 3. The implications of development within this zone are uncertain and dependant on consultation with relevant bodies.”

4.13 For the reasons set out above, these conclusions suggest a heavily constrained site, however, development would not have any impact on any County Wildlife Site, flooding is not an issue, and the tree that is the subject of a TPO is proposed to be retained within any residential development. In addition, a Heritage Impact Assessment (HIA) has been submitted with the planning applications, and the proposals have been further revised (and the total number of dwellings reduced), to reduce the potential impact on the setting of heritage assets to a ‘low level of less than substantial harm’. A revised HIA also concludes that the public benefits of the proposals would outweigh this level of harm.

4.14 It is also noted that Sproughton is not included for assessment within the ‘Heritage and Settlement Sensitivity Assessment’ (March 2018) undertaken by Place Services – presumably because there is no Conservation Area in the village (one of the key criteria for inclusion). It can therefore be concluded that the village is not considered to be an area of ‘high sensitivity to change’ (as defined in SA). In any event, the SA assessment of Site ALT13 does not ‘red flag’ impact on heritage assets as issue, although it does note the proximity of a number of listed buildings and the need to consider the impacts of any development on the historic environment.

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

5. CONCLUSIONS

5.1 These representations are submitted on behalf of Hopkins Homes and relate to a site in the village of Sproughton that is currently the subject of a full planning application for residential development – LPA reference: DC/18/02010 (and a duplicate application DC/18/02412). The Site is known as ‘Land East of Bramford Road, Sproughton’ in these applications and application DC/18/02010 was presented to the Council’s Planning Committee in April 2019 with an officer recommendation for approval.

5.2 Detailed technical reports and documents supporting the planning application, which have been with the Council for 18 months demonstrate that the land east of Bramford Road, Sproughton, is a sustainable location for new residential development – it is very close to the existing village centre and its facilities and amenities, and can be sensitively developed for housing without significant landscape impact. The location of the Site also represents a natural extension to the built-up area of the village, and the latest proposed site layout plans also demonstrate that any impact on the setting of nearby heritage assets can be minimised to a ‘low level of less than substantial harm’, which would be outweighed by the public benefits of the proposals.

5.3 Representations in respect of the Site have been made by Hopkins Homes at each of the consultation stages of the emerging Joint Local Plan, suggesting that the site should be allocated for residential development.

5.4 A hybrid planning application for residential development has also been submitted by Pigeon Land on the ‘Land north of Burstall Lane and west of B1113’ in February 2019 and is currently under consideration by the Council (LPA Ref: DC/19/00567). However, it is clear that the application site does not respect the boundary of the draft Site Allocation LA012 as shown in the emerging Joint Local Plan. This scale and extent of development would have a significant and detrimental impact on the landscape character and setting of the village.

5.5 We consider that any development of the draft site allocation ‘Land north of Burstall Lane and west of B1113’ would not follow the pattern of settlement in the valley. The site lies on the open slopes of the valley side where development will be far more visible and out of character. The Development Management guidelines for the rolling Valley Farmlands notes: “Settlement extension in a valley side landscape is likely to have a significant visual impact and adversely affect the character of the landscape”.

5.6 In contrast to the draft allocation site, which has no natural boundaries to the west and north, the Site to the east (Land east of Bramford Road, Sproughton) is well contained by the existing trees along its northern and western boundaries, the existing settlement to the south as well as woodland within the Gipping Valley to the east. As such, this site provides a logical and sustainable extension to Sproughton where development would have a relatively limited landscape impact.

5.7 Sproughton is identified as a ‘Core Village’ within the Ipswich Fringe in the emerging Joint Local Plan and Policy SP04 of the Joint Local Plan sets out a spatial distribution of housing across the Babergh and Mid Suffolk districts, including 1,977 new homes within

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Representations to Babergh & Mid Suffolk Joint Local Plan – Preferred Options Document

the Babergh Ipswich Fringe area during the Local Plan period (2018 - 2036). Sproughton (Parish) is expected to provide 83% of this total amount – 1,650 dwellings. A modest increase in the total number of homes that might be provided in Sproughton would not run counter to this policy direction.

5.8 The Sustainability Appraisal (SA) offers some justification for the Council’s draft site selection in respect of Sproughton village. However, when judged against the sustainability criteria as a whole there is little to choose between the two sites north of the village on either side of Bramford Road (B1113). It can be further concluded that the apparent reasons (‘red flags’) for excluding the site ‘Land east of Bramford Road, Sproughton’, do not stand up to detailed scrutiny in that:

 There are no flood risk issues related to the proposed development of the Site;

 There are no statutory and non-statutory designated sites or ancient woodland habitats (or other priority habitat types listed under Section 41 of the 2006 Natural Environment and Rural Communities Act, 2006) likely to be impacted by residential development within the site or within the zone of influence of the site; and,

 The only tree that is the subject of a TPO would be retained, and form a key feature of the new area of public open space proposed as part of the residential development.

5.9 These representations therefore strongly recommend the inclusion of the land east of Bramford Road, Sproughton as an allocation for residential development of up to 50 dwellings – either in addition to the existing proposed allocation Site LA012, or instead of this allocation. This amendment to the emerging Joint Local Plan can be made at the next (submission) stage of the Joint Local Plan, and can be fully justified for the reasons set out in these representations.

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