Babergh & Mid Suffolk Joint Local Plan Preferred Option (Regulation

Babergh & Mid Suffolk Joint Local Plan Preferred Option (Regulation 18) Consultation

Land North of the B1070, Holton St. Mary

Prepared by Strutt & Parker on behalf of A P T Philpot Ltd.

September 2019

Site Name: Land North of the B1070, Holton St. Mary

Client Name: A P T Philpot Ltd.

Type of Report: Regulation 18 Local Plan Representation

Prepared by: Alasdair Sherry MPLan MRTPI MInstRE

Approved by: Richard Clews BA(Hons) DipTP

Date: September 2019

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Strutt & Parker, Coval Hall, Rainsford Road, Chelmsford, Essex CM1 2QF [email protected] Tel No: 01245 258201

Contents

1. Background and Overview ...... 1 2. Babergh & Mid Suffolk Joint Local Plan Regulation 18 Consultation ...... 2 3. Site Deliverability ...... 9 4. Summary ...... 13

Appendices Appendix A: Land North of the B1070, Holton St. Mary - Location Plan

1. Background and Overview

1.1 These representations are submitted by Strutt & Parker on behalf of APT. Philpot Ltd. in relation to Babergh & Mid Suffolk District Council’s Joint Local Plan Preferred Option (Regulation 18) Consultation (eLP). This submission has specific regard to our client’s interests in the Local Pan and Land north of the B1070 at Holton St. Mary, which has been identified as suitable for inclusion within the Settlement boundary and referred to as site Ref.SS0752 in the Plan-making process to date. A plan identifying the site is included at Appendix A.

1.2 Site SS0752 measures approximately 0.5ha and contains one large barn, facing the B1070, positioned adjacent to the adopted settlement boundary and opposite Holton Hall. The barn will be removed as part of the proposals. The evidence base supporting the Joint Local Plan consultation determines that the site is suitable, available and achievable for 10 dwellings.

1.3 As the Council will be aware, the site has been consistently supported through the Local Plan process. Representations have previously been made on behalf of APT Philpot Ltd. in relation to this site to earlier stages of the Babergh District Council Local Plan process. Most recently, the site was put forward as part of the Babergh and Mid Suffolk (Regulation 18 draft) Joint Local Plan (JLP) consultation in 2017.

1.4 The extension the Settlement Boundary of Holton St. Mary around the site is entirely supported and considered to be necessary and in accordance with the evidence prepared for the Local Plan. It is the only appropriate and available means for new residential development to come forward to support the rural community of Holton St. Mary, when considering the evidence.

1.5 This representation reinforces the planning arguments for the increased site boundary for Holton St. Mary, but also sets out why the site set out as SS0752 should be identified for residential development, as it would represent a sustainable and deliverable proposal to assist in meeting needs over the coming plan period. In addition, this representation sets out comments on the Joint Local Plan Regulation 18 consultation documentation, as well as providing detail on the sustainability and deliverability of the site with regards to technical considerations.

2. Babergh & Mid Suffolk Joint Local Plan Regulation 18 Consultation

Spatial Strategy 2.1 The locations for housing growth set out in the Local Plan have been identified through previous consultation phases and extensive assessment of sites put forward by promotors and developers at earlier stages. This includes a Call for Sites Exercise carried out in 2016, and a more in depth assessment undertaken as part of the Draft Strategic Housing and Employment Land Availability Assessment (SHELAA) July 2019.

Figure 1: Location of site SS0752 as shown in the Regulation 18 JLP

2.2 Draft Policy SP04 sets out the proposed distribution of the required number of units, and sets out that 118 new homes will come from settlements designated as ‘Hamlets’ over the plan period 2018-2036 within the Babergh district. We are in support of the numbers shown being referred to as minimum, to support sustainable growth within these settlements in accordance with national policy to boost significantly the supply of housing.

2.3 The adopted Local Plan for Babergh District (adopted June 2006) identifies Holton St. Mary as a ‘Non-Sustainable Settlement’, under Policy HS03. However, the more recent ‘Rural Development and Core Strategy Policy CS11’ Supplementary Panning Document (SPD) (Adopted 8 August 2014) more appropriately and more accurately finds Holton. St Mary to be a ‘Hinterland Village’. The SPD recognises the conflict that

this policy would present in comparison to national policy, and the harm that could arise from not allowing these settlements to adapt and grow. This includes that many of the smaller settlements have access to a wide range of services and facilities in nearby settlements, even if they do not contain those services themselves, and provide an attractive lifestyle that residents desire, evidenced by high house prices and worsening affordability ratios. The services that are within these settlements may struggle to survive if there is no growth or change within the settlements, failing to promote the vitality of rural settlements. With specific regard to Holton St. Mary and its nearby villages, the location close to the A12 provides good access to services, which is not reflected in the original policy but is recognised in the SPD. We therefore strongly support the approach of the SPD and the proposal in the eLP, in which ‘Hinterland Villages will accommodate some development to help meet the needs within them’. This is fully justified for the eLP and reflects the objectives of the Plan and National Policy.

Settlement Hierarchy

2.4 The eLP includes a settlement hierarchy at SP03 and Table 2, which includes five categories of settlements. Holton St. Mary is categorised as a Hamlet Village, which represent the settlements with the fewest services within them, but which contains the largest number of settlements, emphasising the rural character of Babergh District.

2.5 We are not aware of any consultation on the methodology proposed and therefore this appears to be the first opportunity to do so. Accordingly, we make these comments to assist the Council in preparing a more robust review.

2.6 The methodology for cataloguing settlements attributes points for a number of criteria, and finds that Holton St. Mary has a settlement score of ‘7’. The threshold for Hinterland Villages (the next highest category) is 9-17 points, meaning that Holton St. Mary is one of the more established hamlets within the district.

2.7 The preparation of a settlement hierarchy based on a scoring system is commonplace for local plan preparation. However, we are concerned that the settlement scoring does not reflect the importance of some services over others, and that the nature of some settlements have been mis-categorised, including Holton St. Mary, in relation to their suitability to support residential or employment development accurately. While the adjustment of the Settlement Boundary to provide growth is welcome, the scoring method presented in the July 2019 Topic Paper – Settlement Hierarchy Review (SHR)

should be reconsidered to better reflect the benefits of Holton St. Mary as a location suitable for development.

2.8 The SHR states at paragraph 2.2 that:

The scoring is based on the relative importance of each facility available within a settlement, in that some services are more essential and used more frequently than others, such as a primary school or a convenience store. As these are important facilities that reduce the need to travel by car and support the vitality of the local community, they are given a score of 2 points. (para.2.2)

2.9 While the general point that certain services are more important, and more likely to be needed on a daily basis than others, is accepted and agreed, the scoring should be scrutinised further to ensure it achieves the aim of recognising and reflecting that very point. For example, a settlement receives an identical score for containing a pre- school, secondary school, post office, village hall, place of worship, library, allotment, and for each food and drink outlet (to a maximum of 5) within the settlement, when in reality some of these services are far more important to a successful village than others. There is no refinement of the scoring to account for any weighting of relative importance of these facilities/services, except to give some facilities 2 points and others 1 point. In reality, there is likely to be more community engagement and activity around some services than others, which is not reflected here.

2.10 For employment opportunities, the Review refers only to proximity to either strategic and small scale employment within 5km. The score is a maximum, in that regardless of the number of employment sites nearby, a settlement can only score 1 or 2 points (and in fact, no settlement scores 3 points for this criteria, meaning that a settlement cannot be near to both small scale and strategic, they are exclusive categories). This results in an employment opportunity being dwarfed by the more domestic offer within a settlement in terms of the overall score.

2.11 By referencing the distance to employment (within 5km) the scoring fails to reflect that some settlements, such as Holton St. Mary, contain employment opportunities while others are just in proximity to them. The rationale for scoring these is to ‘reduce the need to travel’ and therefore the relative distance should be accounted for, with those containing employment options being given a greater score.

2.12 Crucially, as explained below, the proximity to a town that contains various services and facilities scores just 1 or 2 points (depending on the scale of that other settlement)

but with no regard to the actual score achieved by that neighbouring settlement(s). Again, this appears to be an exclusive score with 2 points for proximity to a town/urban area and 1 point for core village. This overlooks that some settlements will be within a suitable distance of several other settlements, not just one, and also ignores the services available within those settlements.

2.13 As an alternative, we recommend a more sophisticated system be applied. It is clear that Babergh is a largely rural district with many smaller settlements that depend upon each other to meet the needs of residents. The scoring system adopted for the SHR is incapable of fully reflecting the availability of services within such a district. Of primary importance are four aspects that would result in a more sophisticated understanding of the living standards and desirability of different Settlements within the hierarchy:

a. The scoring should reflect the relative scores of neighbouring settlements and not simply apply a single number to a standard proximity. A reduction or scaling of the score could be applied, but this would likely be an arbitrary reduction unless there were a judgement on the value of the reduction (based on distance, or relative accessibility, for example). Our preference would be for a supplementary value to further inform the overall score for the settlement, or to inform the suitability of the village/town to accommodate additional residents and employment.

b. Distances to neighbouring settlements are not always meaningful in a rural district where travel times are likely to be more meaningful in assessing relative connectivity. It is recommended that a score is based on travel time, potentially dropping the 5km distance entirely.

c. The scores of different facilities should not hold the same weight. A consultation on the scoring would have been useful. In the absence of a consultation, a rational assessment of the relative importance of facilities would provide a more sophisticated approach that would better reflect the living conditions of different villages. The proximity of a primary school or medical facility is, generally, more critical to residents daily lives than a library, dentist, or allotment, yet there is very little in the scores between them. A place of worship does not necessarily provide as important a function to most residents as local employment, or access to convenience retail (convenience store), and travel options, yet there is again little between the relative scores and no meaningful indication of importance in defining a settlement.

d. The value of local employment should be given much greater weight to reflect its importance to creating balanced communities and reducing the need to travel.

2.14 In addition to the above, we recommend that the Council also consider a general additional score for proximity to highest-tier settlements on the basis of travel time, not distance, and for this to include settlements outside of Babergh and Mid Suffolk, such as Colchester and Ipswich, and not be limit to proximity to settlements within the districts.

2.15 The support given to rural settlements by the more established villages was recognised in the previous Core Strategy & Policies document as part of the New Babergh Local Plan in February 2014. Holton St. Mary was previously recognised as part of the East Bergholt ‘functional cluster’. As a cluster, the range of services provided amongst the settlements making up the group were considered to serve not just the village they were in, but also the smaller surrounding hamlets and settlements. It is considered that the services available to villages such as Holton St. Mary as part of a ‘functional cluster’ should be recognised in a more sophisticated system of assessment and that the Council should continue the earlier work in identifying these collective services.

2.16 Currently, the methodology undertaken fails to recognise the availability of services in nearby settlements, and does not provide any scaling for the size or additional services offered in the nearby settlements, except at a rudimentary level of an additional point or two. This is something we consider should be assessed as part of the review of each settlement - For example, the system could regard certain services as being essential in order to be identified within a certain category of settlement. This in turn would allow hamlets and villages in closer proximity to a larger, better serviced settlements to score higher than those that really are located in unsustainable locations.

2.17 Other scoring elements, such as the availability of superfast broad band, can also be misconstrued. Currently, Offcom consider superfast BB to be any speed above 50Mb (download), not 74Mb as set out in the Hierarchy. Holton St. Mary currently benefits from the provision of good internet speeds - A quick study online shows that speeds of up to 67mb (ranked as superfast fibre) is available within Holton St. Mary, and the service used within the assessment (http://www.betterbroadbandsuffolk.com/) implies that speeds of up to 80mbps may be achievable. As a result, Holton St. Mary should be granted 2 points in this respect. As a suggestion to refine this further, the Council

should consider using the Offcom standard for superfast and ultrafast broadband with scores of 1, 2 and 3 points respectively.

Holton St. Mary

2.18 For each of the above reasons, we consider that amendments to the Settlement Hierarchy should be undertaken. Accordingly, we consider it likely that such amendments would better reflect what we consider to be Holton St. Mary’s true level within the hierarchy, resulting in the identification of an attractive settlement within a suitable environment that is suitable for additional residential development. This would firmly justify the changes to the settlement boundary identified within the eLP, which is fully supported.

Figure 2: Settlement Boundary for Holton St. Mary as set out in the Regulation 18 JLP, which includes site SS0752.

Policy LP01

2.19 Policy LP01 is the relevant policy to be considered when bringing forward residential development in rural hamlets. We support the draft policy in that it has been designed to reflect Paragraph 78 of the NPPF, promoting sustainable development in rural areas and maintaining the vitality of rural communities. The development of the site shown in Appendix A will meet the criteria of draft policy LP01, as the development can be proportionate to the location and context of the settlement, including Holton St. Mary, and would not be detrimental to the character of the surrounding landscape and

townscape. We are conscious of the refused planning application and appeal for a similar level of development and would comment that this was due to conflict with adopted policies (which are of course being revised through this eLP) and the reasons for refusal did not cite any detriment a result of design or incompatibility with the settlement. In fact, the appeal supported the proposed layout and design of dwellings.

2.20 Policy LP01 is fully supported and consistent with the evidence base in relation to development in Holton St. Mary.

3. Site Deliverability

3.1 The site is deliverable immediately and can assist with the Council’s housing supply within the first 0-5 year period of the Plan. Estimates from the Council state that the site could be built out within 2 years of any works commencing and this is fully supported.

3.2 The site has limited constraints. The analysis of site SS0752 undertaken as part of the Draft Strategic Housing and Employment Land Availability Assessment (SHELAA) 2019 sets out that the site is suitable, available, and achievable, subject to only two identified constraints; Highways and Heritage. These are not problematic constraints and both were fully mitigated with the recent planning application and appeal (Ref. DC/17/05127 and ref: 3205344 respectively).

3.3 Draft Policy SP09 relates to cross boundary mitigation of effects on Protected Habitats Sites. As noted in the Draft SHEELA (July 2019), the site falls within the 13km Zone of Influence for the Recreational Disturbance Avoidance and Mitigation Strategy (RAMS). A plan of the zone of influence is included at paragraph 12.05 of the BMSDC Joint Local Plan Preferred Options. Our client supports a unified approach to the protection of sensitive habitat areas through the RAMS strategy.

3.4 Draft Policy LP07 sets out the Joint Local Authority’s approach to the provision of affordable housing in new development, alongside Policy SP02 which requires sites of ten or more dwellings or larger than 0.5ha to provide 35% affordable housing. This policy is predicated on the information set out at Section 07 of the Regulation 18 JLP, which finds that Babergh will require a total of 1,986 affordable homes to be delivered over the plan period.

3.5 We support the proactive approach to secure and retain the delivery of affordable housing. It is considered that the criteria relating to site area (0.5ha) should explicitly refer to the expectation for outline applications to include provision for affordable housing, while as currently drafted this would capture non-major development on large parcels of land. Given that outline proposals must include an indication of quantum of development, this is not considered to be necessary but would reflect that proposals can change between submissions.

3.6 Also included within the Regulation 18 JLP evidence base is the Babergh and Mid Suffolk Open Space Study. Development of the proposed site will not impact on the nearby Class B Amenity Greenspace at Rose Acre, located to the south within Holton St. Mary, and will not negatively impact any other identified open spaces.

Housing Delivery Test Action Plan

3.7 Released alongside the Local Plan was a document setting out how Babergh and Mid Suffolk would meet the requirements of the Housing Delivery Test. The Housing Delivery Test Action Plan (June 2019).

3.8 Points made at paragraph 3.4, under the heading of general recommendations, set out the extensive strategies for ensuing delivery from identified sites happens in a timely fashion and does not cause delay that would compromise the aim of the plan to effectively deliver on the required number of homes in the right places.

3.9 While this approach is supported, and a number of the recommendations are agreed (such as the developing a framework for meeting with key stakeholders), it is also considered that smaller sites such as SS0752 have the ability to come forward quickly and when needed to ensure a steady supply in line with the aims of the NPPF. The SHELAA assessment of site SS0752 states that the site could come forward to develop in the region of 10 homes over a period of 2 years. We would state that’s the landowner is willing and the site is immediately deliverable with limited constraints, the site could come forward in an even shorter timeframe, following the plan process.

Landscape

3.10 The evidence base includes Landscape Guidance published in 2015 to assist in directing areas for growth. Holton St. Mary and the surrounding areas falls into the landscape category of ‘Plateau Farmlands’. The landscape guidance sets out that this category typically comprises hamlets and settlements set amongst the rolling countryside in and around the Dedham Vale. On Holton St. Mary, the guidance states that:

‘Holton St Mary and Raydon have a ribbon settlement pattern that follows the narrow winding path of the main road to Hadleigh from East Bergholt. With a

mix of old and new developments surrounded by mature hedges and trees the villages sit seamlessly within the landscape’.

3.11 We note the design principles set out within the guidance, which relate to proposed development within plateau farmland character areas. It has been shown that development can occur on the proposed site in line with these principles, and that new housing in this location will retain the scenic quality of the village and surrounding area and ensure that any visual impact is within keeping of the existing character. Amending the settlement boundary at Holton St. Mary, as proposed in the Local Plan, will assist in meeting the identified housing requirement without the need to identify more sensitive sites in landscape terms.

3.12 The amendment to the settlement boundary as proposed at Holton St. Mary is fully supported by the evidence base prepared by the Council and we endorse the approach of the LPA in this regard.

Viability

3.13 In line with other recommendations set out within the NPPF, the emerging Local Plan is also supported by a Viability and CIL Review Study, completed by Aspinall Verdi. The study seeks to ensure that the viability impacts of emerging planning policies and overall strategy is viable and deliverable.

3.14 The study principally focussed on sites and policies that were deemed to have significant effects on viability of the plan as a whole. As such, a number of the policies relating to developments in hamlets and clusters were not of the scale relevant to the assessment. When reviewed against policies associated with affordable housing provision however, it was noted that the table at ES 28 of the study sets out a potential for financial provision upwards of £36,000 to be expected from smaller sites that did not provide any affordable housing, in combination with a CIL of up to £300m2.

3.15 It is recommended that the survey data and methodology backing up his recommendation is benchmarked against other local authorities within the east of England, in order to ensure the contributions and CIL expected of smaller developments does not become excessive. Should onerous contributions be expected of smaller schemes in the rural area and hamlets, particularly those that do not provide affordable housing, it may deter such proposals coming forward. This would have the adverse effect of preventing sustainable development coming forward in these

locations, and prevent the plan from effectively meeting the requirement to deliver housing to sustain the vitality of rural communities in line with paragraph 78 of the NPPF.

Surrounding Development

3.16 The proposed site is located opposite an established rural employment area, which is also under the ownership and management of APT Philpot Ltd. The landowner is currently in discussions with the Council to expand local employment opportunities by providing a wellbeing and rehabilitation development to the west of the Business Park.

3.17 This development will provide a new range of employment opportunities locally from services to managerial jobs and specialist professions. A balance of new dwellings delivered locally, to compliment the expanding employment offer in and around the village, can assist with sustainable growth and in particular secure more sustainable forms of travel by reducing the distance between home and work.

4. Summary

4.1 We fully support the inclusion of site SS0752 within the settlement boundary of Holton St. Mary. The site has been shown to have no constraints to development and to provide benefits to the vitality of Holton St. Mary as a location that is fully capable of supporting growth within the District over the plan period. We agree with the assessment and evidence base work undertaken to support the Regulation 18 JLP.

4.2 Holton St. Mary is an excellent area for future development, with previous and recent applications, citing the suitability of Holton St. Mary for family housing, those that are elderly or mobility impaired (indicating that the village is very accessible and convenient for a wide range of services and needs that such individuals would expect to access, and therefore the village must be suitable for most individuals and families), and with convenient links to the wider transport network. The landowner also operates the business park and there are clear synergies between the employment and potential rental of properties to those working at the business park, reducing travel distances for those individuals.

4.3 Combined with the business park and other local employment opportunities, Holton St. Mary is ideal for a proportionate delivery of additional housing over the plan period. The only site identified as being suitable for development in the LPPO for Holton St. Mary, is site SS0752.

4.4 We fully endorse the allocation and can confirm that it is deliverable immediately upon adoption of the Plan for the number of dwellings proposed. This provides reassurance of early delivery in the Plan to offset the major development sites that delivery in the longer term.

4.5 Within this representation we provide recommendations for the Settlement Hierarchy Review that we consider would better reflect the experience in certain rural settlements and we would be willing to discuss these further with the Council.

4.6 We note the possible constraints identified in the assessment of the site as part of the Draft SHELAA 2019 and can confirm that these are readily overcome and that the Council will have all the information to identify suitable mitigation, as presented in the recent planning application.

4.7 We recommend that the expansion of the settlement boundary for Holton St. Mary is fully justified by the LPA and would be appropriate, with policy safeguards presented

in the Local Plan to ensure that any development harmonises with the local character and is successfully integrated into the village. This will support the rural vitality of Holton St. Mary, in a manner that is in line with the spatial strategy set out in Policy SP04 and paragraph 78 of the NPPF.

4.8 A development has been proposed on this site and was refused by the LPA. The refusal was on the basis that it was located outside of the settlement boundary for Holton St. Mary, as identified in the adopted Local Plan. That particular scheme should not unduly influence any decisions in relation to the allocation of land through the local plan process, which is a holistic approach to identifying and delivering the homes and communities the district needs over the plan period, through a plan-led approach.

4.9 The site is fully capable of assisting in that delivery and provides benefits that other locations cannot, such as immediate proximity to a local employment market that is growing, minimal impact on landscape character, and support for a rural community that would otherwise be unlikely to expand during the plan period except through Rural Exception proposals for affordable housing. Holton St. Mary can support a sustainable level of growth and this site is the only suitable site put forward to the Council with supporting evidence. We fully endorse the Council’s approach to amending the settlement boundary at Holton St. Mary and the policies that would control the nature of any proposed development.

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