From: [email protected]

-----Original Message----- From: [email protected] Sent: 19 June 2020 07:14 To: BMSDC Planning Area Team Blue Subject: RE: MSDC Planning Consultation Request - DC/20/02129

Good morning Here is the Debenham Parish Council's planning recommendation re. DC/20/02129 Land South East of Low Road- Erection of 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road

1- The Debenham Parish Council strongly supports the principle of development of the site, as it is in accordance with Policies 1 and 4 of the adopted Debenham Neighbourhood Plan.

2- The Debenham Parish Council welcomes the provision of affordable housing and the bungalows proposed but requests that properties with two to three bedrooms are provided, not single bedroom ones. Policy 6 of the adopted Debenham Neighbourhood Plan applies.

3- The Debenham Parish Council would like to request that this development contributes to the provision and the improvement of off-site pedestrian and cycle routes to the village centre, from the application site. Policy 2 (d) of the adopted Debenham Neighbourhood Plan applies.

4- Development of the application site (DEB 4) must provide free and unrestricted pedestrian and cycle access from site DEB 3 to Low Road. Policy 4 of the adopted Debenham Neighbourhood Plan applies.

5- Overall, the Debenham Parish Council objects to the application due to the creation of a permanent vehicular access from the development onto Low Road. Policy 4 of the adopted Debenham Neighbourhood Plan applies.

If Mid Suffolk District Council are minded to approve the scheme, then any vehicular access onto Low Road must be temporary , until such time when it can be achieved onto Ipswich Road, via the development of site DEB3, specified in Policy 3 of the adopted Debenham Neighbourhood Plan.

Kindest regards Dina

Mrs Dina Bedwell, BEd (Hons), CPE, CiLCA Parish Clerk and Responsible Financial Officer- Debenham Parish Council Office Hours: Monday, Tuesday and Friday 9.30am to 3.30pm Tel. 01473 787861 (messages may be left on answermachine) [email protected]

Confidentiality and Privilege: This email and its attachments are intended for the above named only and may be confidential. If they have come to you in error you must take no action based on them, nor must you copy or show them to anyone; please reply to this email and highlight the error. This document is privileged and the benefit of the privilege belongs to Debenham Parish Council. The provision of this document does not amount to any waiver of privilege. This document is provided to the recipient intended in complete confidence and should not be disclosed to any other person without the Debenham Parish Council's prior consent.

-----Original Message----- From: [email protected] Sent: 05 June 2020 15:11 To: [email protected] Subject: MSDC Planning Consultation Request - DC/20/02129

Please find attached planning consultation request letter relating to planning application - DC/20/02129 - Land South East Of, Low Road, Debenham, Suffolk

Kind Regards

Planning Support Team

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Planning Applications – Suggested Informative Statements and Conditions Report

If you would like to discuss any of the points in this document please contact us on 03456 066087, Option 1 or email [email protected].

AW Site 159578/1/0085639 Reference:

Local Mid Suffolk District Planning Authority:

Site: Land South East Of Low Road Debenham Suffolk

Proposal: Planning Application. Erection of 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road.

Planning DC/20/02129 application:

Prepared by: Pre-Development Team Date: 12 June 2020

Planning Report ASSETS

Section 1 - Assets Affected

There are assets owned by Anglian Water or those subject to an adoption agreement within or close to the development boundary that may affect the layout of the site. Anglian Water would ask that the following text be included within your Notice should permission be granted.

Anglian Water has assets close to or crossing this site or there are assets subject to an adoption agreement. Therefore the site layout should take this into account and accommodate those assets within either prospectively adoptable highways or public open space. If this is not practicable then the sewers will need to be diverted at the developers cost under Section 185 of the Water Industry Act 1991. or, in the case of apparatus under an adoption agreement, liaise with the owners of the apparatus. It should be noted that the diversion works should normally be completed before development can commence.

WASTEWATER SERVICES

Section 2 - Wastewater Treatment

The foul drainage from this development is in the catchment of Debenham Water Recycling Centre that will have available capacity for these flows

Section 3 - Used Water Network

The sewerage system at present has available capacity for these flows via a gravity connection to the existing foul sewer. If the developer wishes to connect to our sewerage network they should serve notice under Section 106 of the Water Industry Act 1991. We will then advice them of the most suitable point of connection. (1) INFORMATIVE - Notification of intention to connect to the public sewer under S106 of the Water Industry Act Approval and consent will be required by Anglian Water, under the Water Industry Act 1991. Contact Development Services Team 0345 606 6087. (2) INFORMATIVE - Notification of intention to connect to the public sewer under S106 of the Water Industry Act Approval and consent will be required by Anglian Water, under the Water Industry Act 1991. Contact Development Services Team 0345 606 6087. (3) INFORMATIVE - Protection of existing assets - A public sewer is shown on record plans within the land identified for the proposed development. It appears that development proposals will affect existing public sewers. It is recommended that the applicant contacts Anglian Water Development Services Team for further advice on this matter. Building over existing public sewers will not be permitted (without agreement) from Anglian Water. (4) INFORMATIVE - Building near to a public sewer - No building will be permitted within the statutory easement width of 3 metres from the pipeline without agreement from Anglian Water. Please contact Development Services Team on 0345 606 6087. (5) INFORMATIVE: The developer should note that the site drainage details submitted have not been approved for the purposes of adoption. If the developer wishes to have the sewers included in a sewer adoption agreement with Anglian Water (under Sections 104 of the Water Industry Act 1991), they should contact our Development Services Team on 0345 606 6087 at the earliest opportunity. Sewers intended for adoption should be designed and constructed in accordance with Sewers for Adoption guide for developers, as supplemented by Anglian Water’s requirements.

Section 4 - Surface Water Disposal

The preferred method of surface water disposal would be to a sustainable drainage system (SuDS) with connection to sewer seen as the last option. Building Regulations (part H) on Drainage and Waste Disposal for England includes a surface water drainage hierarchy, with infiltration on site as the preferred disposal option, followed by discharge to watercourse and then connection to a sewer.

From the details submitted to support the planning application the proposed method of surface water management does not relate to Anglian Water operated assets. As such, we are unable to provide comments on the suitability of the surface water management. The Local Planning Authority should seek the advice of the Lead Local Flood Authority or the Internal Drainage Board. The Environment Agency should be consulted if the drainage system directly or indirectly involves the discharge of water into a watercourse. Should the proposed method of surface water management change to include interaction with Anglian Water operated assets, we would wish to be re- consulted to ensure that an effective surface water drainage strategy is prepared and implemented.

Planning Report From: SM-NE-Consultations (NE) Sent: 10 June 2020 07:13 To: BMSDC Planning Area Team Blue Subject: MSDC Planning Consultation Request - DC/20/02129

Dear Sir or Madam,

Application ref: DC/20/02129 Our ref: 319029

Natural England has no comments to make on this application.

Natural England has not assessed this application for impacts on protected species. Natural England has published Standing Advice which you can use to assess impacts on protected species or you may wish to consult your own ecology services for advice.

Natural England and the Forestry Commission have also published standing advice on ancient woodland and veteran trees which you can use to assess any impacts on ancient woodland.

The lack of comment from Natural England does not imply that there are no impacts on the natural environment, but only that the application is not likely to result in significant impacts on statutory designated nature conservation sites or landscapes. It is for the local planning authority to determine whether or not this application is consistent with national and local policies on the natural environment. Other bodies and individuals may be able to provide information and advice on the environmental value of this site and the impacts of the proposal to assist the decision making process. We advise LPAs to obtain specialist ecological or other environmental advice when determining the environmental impacts of development.

We recommend referring to our SSSI Impact Risk Zones (available on Magic and as a downloadable dataset) prior to consultation with Natural England. Further guidance on when to consult Natural England on planning and development proposals is available on gov.uk at https://www.gov.uk/guidance/local-planning-authorities-get-environmental-advice

Yours faithfully,

Julie Lunt Operations Delivery Consultations Team Natural England Hornbeam House, Electra Way Crewe Business Park Crewe, Cheshire CW1 6GJ

Mr Daniel Cameron Direct Dial: 01223 582711 Babergh Mid Suffolk Endeavour House Our ref: W: P01202690 8 Russell Road Ipswich Suffolk IP1 2BX 8 June 2020

Dear Mr Cameron

T&CP (Development Management Procedure) (England) Order 2015 & Planning (Listed Buildings & Conservation Areas) Regulations 1990

LAND SOUTH EAST OF LOW ROAD, DEBENHAM, SUFFOLK Application No. DC/20/02129

Thank you for your letter of 5 June 2020 regarding the above application for planning permission. On the basis of the information available to date, we do not wish to offer any comments. We suggest that you seek the views of your specialist conservation and archaeological advisers, as relevant.

It is not necessary for us to be consulted on this application again, unless there are material changes to the proposals. However, if you would like detailed advice from us, please contact us to explain your request.

Yours sincerely

Joanne Robinson Business Officer E-mail: [email protected]

24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU Telephone 01223 582749 HistoricEngland.org.uk

Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation. From: RM Archaeology Mailbox Sent: 26 June 2020 08:36 To: BMSDC Planning Mailbox Subject: RE: Dc/20/02129 - Land South East Of Low Road, Debenham, Suffolk

Good morning Kirsty,

Apologies I thought I had sent our reply…

We have looked at this proposal. In our opinion there would be no significant impact on known archaeological sites or areas with archaeological potential. We have no objection to the development and do not believe any archaeological mitigation is required.

Best regards

Lisa

Lisamaria De Pasquale Assistant Archaeological Officer (Technical Support) Suffolk County Council Archaeological Service Bury Resource Centre Hollow Road Bury St Edmunds Suffolk IP32 7AY Tel.:01284 741230 M: 07523931041 Email: [email protected]

Website: http://www.suffolk.gov.uk/archaeology Search the Suffolk HER online at: http://heritage.suffolk.gov.uk Follow us on Twitter at: https://twitter.com/SCCArchaeology

Your ref: DC/20/02129/FUL Our ref: Land off Low Road. Matter No: 59877 Date: 1 July 2020 Enquiries to: Ruby Shepperson Tel: 01473 265063 Email: [email protected]

By e-mail only: [email protected]

Dear Daniel,

Re: Debenham, Land off Low Road, IP14 6QU – developer contributions

I refer to the proposal: Full Application – Erection 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road.

I previously responded by way of letter dated 26 June 2020. This letter, dated 1 July, sets out Suffolk County Council’s position, which provides our revised infrastructure requirements associated with the development proposed.

In light of the withdrawal of the Taylor Wimpey scheme in Debenham (DC/19/05769/OUT), the cumulative impacts on infrastructure for this application have changed. The new early years provision previously stated in the previous letter was to be delivered in accordance with the now withdrawn development. Despite this, there still exists a deficit of places in the Debenham ward. On this basis, SCC instead requests a contribution of (2 FTEs x £16,596) = £33,192 to go towards expansion costs of existing early years provision.

Please see the updated summary table of infrastructure requirements split between CIL/S106 below:

CIL Education - Primary expansion costs £66,384 - Secondary expansion costs £68,214 - Sixth form expansion costs £22,738 CIL Pre-school expansion £33,192 CIL Libraries £3,888 CIL Waste £1,980

S106 Highways Tbc

Yours sincerely,

Ruby Shepperson Planning Officer Growth, Highways & Infrastructure Directorate – Strategic Development cc Planning Contributions, Suffolk County Council

Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX 1 www.suffolk.gov.uk OFFICIAL Suffolk Fire and Rescue Service

Fire Business Support Team

Floor 3, Block 2 Endeavour House 8 Russell Road Ipswich, Suffolk Mid Suffolk District Council IP1 2BX Planning Department Endeavour House Your Ref: Our Ref: FS/F200945 Russell Road Enquiries to: Water Officer Ipswich Direct Line: 01473 260588 IP1 2BX E-mail: [email protected] Web Address: http://www.suffolk.gov.uk

Date: 17/06/2020

Dear Sirs

Land South East of Low Road, Debenham IP14 6QU Planning Application No: DC/20/02129/FUL

I refer to the above application.

The plans have been inspected by the Water Officer who has the following comments to make.

Access and Fire Fighting Facilities

Access to buildings for fire appliances and firefighters must meet with the requirements specified in Building Regulations Approved Document B, (Fire Safety), 2006 Edition, incorporating 2010 and 2013 amendments Volume 1 - Part B5, Section 11 dwelling houses, and, similarly, Volume 2, Part B5, Sections 16 and 17 in the case of buildings other than dwelling houses. These requirements may be satisfied with other equivalent standards relating to access for fire fighting, in which case those standards should be quoted in correspondence.

Suffolk Fire and Rescue Service also requires a minimum carrying capacity for hard standing for pumping/high reach appliances of 15/26 tonnes, not 12.5 tonnes as detailed in the Building Regulations 2000 Approved Document B, 2006 Edition, incorporating 2010 and 2013 amendments.

Water Supplies

No additional water supply for fire fighting purposes is required in respect of this planning application.

/continued

We are working towards making Suffolk the Greenest County. This paper is 100% recycled and made using a chlorine free process. OFFICIAL OFFICIAL Suffolk Fire and Rescue Service recommends that proper consideration be given to the potential life safety, economic, environmental and social benefits derived from the provision of an automatic fire sprinkler system. (Please see sprinkler information enclosed with this letter).

Consultation should be made with the Water Authorities to determine flow rates in all cases.

Please be advised that there is a fire hydrant located at the entrance to this site which will be used for this development. Please ensure that this is identified and protected while work is being carried out and is easily accessible for inspection and work after the build is complete. Failure to protect the fire hydrant could incur repair or replacement costs.

Should you need any further advice or information on access and fire fighting facilities, you are advised to contact your local Building Control in the first instance. For further advice and information regarding water supplies, please contact the Water Officer at the above headquarters.

Yours faithfully

Water Officer

Suffolk Fire and Rescue Service

Copy: [email protected] Enc: Sprinkler information

We are working towards making Suffolk the Greenest County. This paper is 100% recycled and made using a chlorine free process. OFFICIAL From: GHI Floods Planning Sent: 07 October 2020 08:56 To: BMSDC Planning Area Team Blue Cc: Daniel Cameron Subject: 2020-10-07 JS Reply Land South East Of, Low Road, Debenham Ref DC/20/02129

Dear Daniel Cameron,

Subject: Land South East Of, Low Road, Debenham Ref DC/20/02129

The following submitted documents have been reviewed and we recommend approval of this application subject to conditions;

• Flood Risk Assessment and Drainage Strategy Ref EX18/046/03 • Location Plan Ref 3908-01E • Technical Note Land off Low Road, Debenham Suffolk Dated October 2020

We propose the following condition in relation to surface water drainage for this application.

1. The strategy for the disposal of surface water and the flood risk assessment (FRA) (dated April 2020, ref: EX18/046/03, including and technical note dated October 2020) shall be implemented as approved in writing by the local planning authority. The strategy shall thereafter be managed and maintained in accordance with the approved strategy.

Reason: To ensure that the principles of sustainable drainage are incorporated into this proposal, to ensure that the proposed development can be adequately drained

2. Within 28 days of completion of the last dwelling, details of all Sustainable Drainage System components and piped networks shall be submitted, in an agreed form, to and approved in writing by the Local Planning Authority for inclusion on the Lead Local Flood Authority’s Flood Risk Asset Register.

Reason: To ensure that the Sustainable Drainage System has been implemented as permitted and that all flood risk assets and their owners are recorded onto the LLFA’s statutory flood risk asset register as per s21 of the Flood and Water Management Act 2010 in order to enable the proper management of flood risk with the county of Suffolk https://www.suffolk.gov.uk/roads-and-transport/flooding-and-drainage/flood-risk-asset-register/

3. No development shall commence until details of a Construction Surface Water Management Plan (CSWMP) detailing how surface water and storm water will be managed on the site during construction (including demolition and site clearance operations) is submitted to and agreed in writing by the local planning authority. The CSWMP shall be implemented and thereafter managed and maintained in accordance with the approved plan for the duration of construction. The approved CSWMP and shall include: a. Method statements, scaled and dimensioned plans and drawings detailing surface water management proposals to include :- i. Temporary drainage systems ii. Measures for managing pollution / water quality and protecting controlled waters and watercourses iii. Measures for managing any on or offsite flood risk associated with construction

Reason: To ensure the development does not cause increased flood risk, or pollution of watercourses or groundwater https://www.suffolk.gov.uk/roads-and-transport/flooding-and-drainage/guidance-on-development- and-flood-risk/construction-surface-water-management-plan/

Informative

• Any works to a watercourse may require consent under section 23 of the Land Drainage Act 1991 • Any discharge to a watercourse or groundwater needs to comply with the Water Environment (Water Framework Directive) (England and Wales) Regulations 2017 • Any discharge of surface water to a watercourse that drains into an Internal Drainage Board district catchment is subject to payment of a surface water developer contribution • Any works to lay new surface water drainage pipes underneath the public highway will need a section 50 license under the New Roads and Street Works Act 1991 • Any works to a main river may require an environmental permit

Recommendations

The Lead Local Flood Authority (LLFA) would recommend that the advice set out in the consultation reply from the Environment Agency dated the 5th October 2020 regarding the need for an emergency flood plan and a safe escape route or the site can be accessed by emergency vehicles is provided. As the LLFA is not a emergency services, we recommend that you consult with the emergency services or emergency planners on this requirement.

Kind Regards

Jason Skilton Flood & Water Engineer Suffolk County Council Growth, Highway & Infrastructure Endeavour House, 8 Russell Rd, Ipswich , Suffolk IP1 2BX

Your Ref:DC/20/02129 Our Ref: SCC/CON/2251/20 Date: 25 June 2020

All planning enquiries should be sent to the Local Planning Authority. Email: [email protected]

The Planning Department MidSuffolk District Council Planning Section 1st Floor, Endeavour House 8 Russell Road Ipswich Suffolk IP1 2BX

For the attention of: Daniel Cameron

Dear Daniel Cameron,

TOWN AND COUNTRY PLANNING ACT 1990 CONSULTATION RETURN: DC/20/02129 PROPOSAL: Planning Application. Erection of 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road. LOCATION: Land South East Of, Low Road, Debenham, Suffolk Notice is hereby given that the County Council as Highway Authority recommends that any permission which that Planning Authority may give should include the conditions shown below:

COMMENTS

We have reviewed the data supplied with this application, the summary of our findings are as follows:

 The proposed visibility splays for the accesses are sufficient for this application.  The proposal for 18 dwellings would create approximately 11 vehicle movements within the peak hour (1 vehicle every 5 minutes).  Debenham village has primary and high schools, a Coop store, doctors surgery, leisure and community centre and many other amenities.  the development is approximately 1000m from the centre of the site to the primary school with safe routes for the vulnerable user.  there are bus stops approximately 250m from the centre of the site with frequent services.  The developer is proposing highway improvements as part of the sites mitigation

Taking all the above into account, it is our opinion that this development would not have a severe impact (NPPF para 109) therefore we do not object to the proposal.

CONDITIONS Should the Planning Authority be minded to grant planning approval the Highway Authority in Suffolk would recommend they include the following conditions and obligations:

V 1 - Condition: Before the access into the site is first used, visibility splays shall be provided as shown on Drawing No. EX18/046/03/04-P1 with an X dimension of 2.4 and a Y dimension of 43m and Endeavour House, 8 Russell Road, Ipswich, Suffolk. IP 1 2BX www,suffolk.gov.uk thereafter retained in the specified form. Notwithstanding the provisions of Part 2 Class A of the Town & Country Planning (General Permitted Development) Order 1995 (or any Order revoking and re-enacting that Order with or without modification) no obstruction over 0.6 metres high shall be erected, constructed, planted or permitted to grow within the areas of the visibility splays.

AL10 - Condition: Before the development is commenced, details of the access and associated works, (including layout, levels, gradients, surfacing and means of surface water drainage), shall be submitted to and approved in writing by the Local Planning Authority. Reason: To ensure that roads/footways are constructed to an acceptable standard.

HW 1 - Condition: Prior to commencement of any works (save for site clearance and technical investigations) details of the highway improvements (including layout, levels, gradients, surfacing and means of surface water drainage), as indicated on Drawing No EX18/046/03/06-P1 shall be submitted to and approved in writing to the Local Planning Authority in consultation with Local Highway Authority. The details as agreed shall be delivered in accordance with a timetable for improvement which shall have been submitted to and agreed in writing by the LPA concurrent with the said details. Reason: To ensure that design highway improvements/footways are constructed to an acceptable standard.

ER 1 - Condition: Prior to commencement of any works, (save for site clearance and technical investigations) details of the estate roads and footpaths, (including layout, levels, gradients, surfacing and means of surface water drainage), shall be submitted to and approved in writing by the Local Planning Authority. Reason: To ensure that roads/footways are constructed to an acceptable standard.

ER 2 - Condition: No dwelling shall be occupied until the carriageways and footways serving that dwelling have been constructed to at least Binder course level or better in accordance with the approved details except with the written agreement of the Local Planning Authority in consultation with Local Highway Authority. Reason: To ensure that satisfactory access is provided for the safety of residents and the public.

P 1 - Condition: The use shall not commence until the area(s) within the site shown on 3908-07S for the purposes of manoeuvring and parking of vehicles has been provided and thereafter that area(s) shall be retained and used for no other purposes. Reason: To ensure that sufficient space for the on site parking of vehicles is provided and maintained in order to ensure the provision of adequate on-site space for the parking and manoeuvring of vehicles where on-street parking and manoeuvring would be detrimental to highway safety to users of the highway.

P 2 - Condition: Before the development is commenced, details of electric vehicle charging points and secure covered cycle storage shall be submitted to and approved in writing by the Local Planning Authority. The approved scheme shall be in accordance with Suffolk Parking Guidance 2019 and carried out in its entirety before the development is brought into use and shall be retained thereafter and used for no other purpose. Reason: To promote the use of sustainable travelling alternatives within the area and use of electric vehicles.

B 2 - Condition: Before the development is commenced details of the areas to be provided for storage and presentation of Refuse/Recycling bins shall be submitted to and approved in writing by the Local Planning Authority. The approved scheme shall be carried out in its entirety before the development is brought into use and shall be retained thereafter for no other purpose. Reason: To ensure that refuse recycling bins are not stored on the highway causing obstruction and dangers for other users.

HGV CONSTRUCTION - Condition: Before the development hereby permitted is commenced a Construction Management Plan shall have been submitted to and approved in writing by the Local Planning Authority. Construction of the development shall not be carried out other than in accordance with the approved plan. The Construction Management Plan shall include the following matters:  haul routes for construction traffic on the highway network and monitoring and review mechanisms.  provision of boundary hoarding and lighting  details of proposed means of dust suppression  details of measures to prevent mud from vehicles leaving the site during construction  details of deliveries times to the site during construction phase  details of provision to ensure pedestrian and cycle safety  programme of works (including measures for traffic management and operating hours)  parking and turning for vehicles of site personnel, operatives and visitors  loading and unloading of plant and materials  storage of plant and materials  maintain a register of complaints and record of actions taken to deal with such complaints at the site office as specified in the Plan throughout the period of occupation of the site. Reason: In the interest of highway safety to avoid the hazard caused by mud on the highway and to ensure minimal adverse impact on the public highway during the construction phase.

NOTES

The Local Planning Authority recommends that developers of housing estates should enter into formal agreement with the Highway Authority under Section 38 of the Highways Act 1980 relating to the construction and subsequent adoption of Estate Roads.

The works within the public highway will be required to be designed and constructed in accordance with the County Council's specification. The applicant will also be required to enter into a legal agreement under the provisions of Section 278 of the Highways Act 1980 relating to the construction and subsequent adoption of the highway improvements. Amongst other things the Agreement will cover the specification of the highway works, safety audit procedures, construction and supervision and inspection of the works, bonding arrangements, indemnity of the County Council regarding noise insulation and land compensation claims, commuted sums, and changes to the existing street lighting and signing.

Yours sincerely,

Samantha Harvey Senior Development Management Engineer Growth, Highways and Infrastructure

From: Chris Ward Sent: 08 June 2020 08:33 To: Daniel Cameron Cc: BMSDC Planning Area Team Blue ; Sam Harvey Subject: RE: MSDC Planning Consultation Request - DC/20/02129

Dear Daniel,

Thank you for consulting me about the proposed residential development at Land South East of Low Road in Debenham. On reviewing the application documents submitted, I have no comment to make as the development does not meet the threshold of requiring a Travel Plan in line with local and national guidance.

Kind regards

Chris Ward Travel Plan Officer Transport Strategy Strategic Development - Growth, Highways and Infrastructure Suffolk County Council Endeavour House, 8 Russell Road, Ipswich, IP1 2BX web : https://www.suffolk.gov.uk/planning-waste-and-environment/planning-and-development-advice/travel-plans/

-----Original Message----- From: [email protected] Sent: 05 June 2020 15:10 To: Chris Ward Subject: MSDC Planning Consultation Request - DC/20/02129

Please find attached planning consultation request letter relating to planning application - DC/20/02129 - Land South East Of, Low Road, Debenham, Suffolk

Kind Regards

Planning Support Team

26 June 2020

Daniel Cameron Mid Suffolk District Council Endeavour House 8 Russell Road Ipswich IP1 2BX

By email only

Thank you for requesting advice on this application from Place Services’ ecological advice service. This service provides advice to planning officers to inform Mid Suffolk District Council planning decisions with regard to potential ecological impacts from development. Any additional information, queries or comments on this advice that the applicant or other interested parties may have, must be directed to the Planning Officer who will seek further advice from us where appropriate and necessary.

Application: DC/20/02129 Location: Land South East Of Low Road Debenham Suffolk Proposal: Planning Application. Erection of 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road.

Dear Dan,

Thank you for consulting Place Services on the above application.

No objection subject to securing ecological mitigation and enhancement measures

Summary We have reviewed the Ecology Report (MHE Consulting Ltd, May 2020), provided by the applicant, relating to the likely impacts of development on designated sites, protected and Priority Species & Habitats.

We are satisfied that there is sufficient ecological information available for determination. This provides certainty for the LPA of the likely impacts on designated sites, Protected and Priority Species & Habitats and, with appropriate mitigation measures secured, the development can be made acceptable.

As a result, the mitigation measures identified in the Ecology Report (MHE Consulting Ltd, May 2020) should be secured and implemented in full. This is necessary to conserve Protected and Priority Species and should be outline via the provision Construction Environmental Management Plan (CEMP: Biodiversity). It is highlighted that this document will need to demonstrate clear pollution control measures during the construction phase for the tributary of the River Deben.

We also recommend that a Wildlife Friendly Lighting Strategy is implemented for this application. Therefore, technical specification should be submitted prior to occupation, which demonstrates

measures to avoid lighting impacts to foraging / commuting bats in line with the recommendations provided by the applicant’s ecologist.

In addition, it is highlighted that we are satisfied with the soft landscaping plan at a biodiversity perspective, as well as the proposed biodiversity enhancements measures proposed within the Landscape proposal and the Ecology Report (MHE Consulting Ltd, May 2020). Therefore, the aftercare and finalised biodiversity enhancements should be outlined within the Landscape and Ecological Management Plan and should be secured as a condition of any consent.

It is highlighted that the LEMP must include breeding and hibernating habitat for the Grass Snake. It should also demonstrate Hedgehog Friendly Fencing (13x13cm holes at the base of fencing) will be implemented were appropriative throughout the site. This is necessary to secure measurable biodiversity net gains, as outline under paragraph 170[d] and 174[d] of the NPPF. Furthermore, the LEMP Should include any further habitat creation within the watercourse required as part of the potential Water Vole Licence.

This will enable LPA to demonstrate its compliance with its statutory duties including its biodiversity duty under s40 NERC Act 2006.

Impacts will be minimised such that the proposal is acceptable subject to the conditions below based on BS42020:2013.

Submission for approval and implementation of the details below should be a condition of any planning consent.

Recommended conditions

1. PRIOR TO COMMENCEMENT: CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN “A construction environmental management plan (CEMP: Biodiversity) shall be submitted to and approved in writing by the local planning authority, following the Ecology Report (MHE Consulting Ltd, May 2020).

The CEMP (Biodiversity) shall include the following. a) Risk assessment of potentially damaging construction activities. b) Identification of “biodiversity protection zones”. c) Practical measures (both physical measures and sensitive working practices) to avoid or reduce impacts during construction (may be provided as a set of method statements). d) The location and timing of sensitive works to avoid harm to biodiversity features. e) The times during construction when specialist ecologists need to be present on site to oversee works. f) Responsible persons and lines of communication. g) The role and responsibilities on site of an ecological clerk of works (ECoW) or similarly competent person. h) Use of protective fences, exclusion barriers and warning signs.

The approved CEMP shall be adhered to and implemented throughout the construction period strictly in accordance with the approved details, unless otherwise agreed in writing by the local planning authority”

Reason: To conserve protected and Priority species and allow the LPA to discharge its duties under the Conservation of Habitats and Species Regulations 2017 (as amended), the Wildlife & Countryside Act 1981 as amended and s40 of the NERC Act 2006 (Priority habitats & species).

2. PRIOR TO COMMENCEMENT: SUBMISSION OF A COPY OF THE LICENCE FOR WATER VOLES “The following works to create the access to the site shall not in in any circumstances commence unless the local planning authority has been provided with either: a) a licence issued by Natural England pursuant authorizing the specified activity/development to go ahead; or b) a method statement supplied by an individual registered to use a Class Licence for Water Voles; or c) an appropriate statement in writing from the relevant licensing body or suitably qualified ecologist to the effect that it does not consider that the specified activity/development will require a licence.”

Reason: To conserve protected and Priority species and allow the LPA to discharge its duties under the Wildlife & Countryside Act 1981 as amended and s40 of the NERC Act 2006 and s17 Crime & Disorder Act 1998.

3. PRIOR TO OCCUPATION: LANDSCAPE AND ECOLOGICAL MANAGEMENT PLAN “A Landscape and Ecological Management Plan (LEMP) shall be submitted to, and be approved in writing by, the local planning authority prior occupation of the development.

The content of the LEMP shall include the following: a) Description and evaluation of features to be managed. b) Ecological trends and constraints on site that might influence management. c) Aims and objectives of management. d) Appropriate management options for achieving aims and objectives. e) Prescriptions for management actions. f) Preparation of a work schedule (including an annual work plan capable of being rolled forward over a five-year period). g) Details of the body or organisation responsible for implementation of the plan. h) Ongoing monitoring and remedial measures.

The LEMP shall also include details of the legal and funding mechanism(s) by which the long- term implementation of the plan will be secured by the developer with the management body(ies) responsible for its delivery. The plan shall also set out (where the results from monitoring show that conservation aims and objectives of the LEMP are not being met) how contingencies and/or remedial action will be identified, agreed and implemented so that the

development still delivers the fully functioning biodiversity objectives of the originally approved scheme. The approved plan will be implemented in accordance with the approved details.”

Reason: To allow the LPA to discharge its duties under the Conservation of Habitats and Species Regulations 2017 (as amended), the Wildlife & Countryside Act 1981 as amended and s40 of the NERC Act 2006 (Priority habitats & species)

4. PRIOR TO OCCUPATION: WILDLIFE SENSITIVE LIGHTING DESIGN SCHEME “A lighting design scheme for biodiversity shall be submitted to and approved in writing by the local planning authority. The scheme shall identify those features on site that are particularly sensitive for bats and that are likely to cause disturbance along important routes used for foraging; and show how and where external lighting will be installed so that it can be clearly demonstrated that areas to be lit will not disturb or prevent bats using their territory.

All external lighting shall be installed in accordance with the specifications and locations set out in the scheme and maintained thereafter in accordance with the scheme. Under no circumstances should any other external lighting be installed without prior consent from the local planning authority.”

Reason: To allow the LPA to discharge its duties under the Habitats and Species Regulations 2017 (as amended), the Wildlife & Countryside Act 1981 (as amended) and s40 of the NERC Act 2006 (Priority habitats & species).

Please contact us with any queries.

Yours sincerely,

Hamish Jackson ACIEEM BSc (Hons) Ecological Consultant [email protected]

Place Services provide ecological advice on behalf of Mid Suffolk District Council Please note: This letter is advisory and should only be considered as the opinion formed by specialist staff in relation to this particular matter.

From: David Harrold Sent: 16 June 2020 08:56 To: BMSDC Planning Mailbox Cc: Daniel Cameron Subject: Plan ref DC/20/02129 Land South East Of, Low Road, Debenham. Environmental Health - Noise/Odour/Light/Smoke

Thank you for consulting me on the above application to erect 18 new dwellings.

I can confirm with respect to noise and other environmental health issues that I do not have any adverse comments and no objection to the proposed development.

Due to the existence of neighbouring noise sensitive premises, however, you may wish to control noisy building work on site and I would recommend the following condition to mitigate this impact:

“The working hours during construction shall be restricted to 0800 hrs to 1800 hrs Mondays to Fridays and 0800 hrs and 1300 hrs on Saturdays. There shall be no working hours on Sundays or Bank Holidays.”

Reason: To protect the occupiers of the neighbouring residential properties from suffering loss of amenity or nuisance.

I trust this advice is of assistance.

David Harrold MCIEH Senior Environmental Health Officer

Babergh & Midsuffolk District Councils t: 01449 724718 e: [email protected]

From: Peter Chisnall Sent: 23 June 2020 11:38 To: BMSDC Planning Area Team Blue Subject: DC/20/02129

Dear Daniel,

APPLICATION FOR PLANNING PERMISSION - DC/20/02129

Proposal: Planning Application. Erection of 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road.

Location: Land South East Of, Low Road, Debenham, Suffolk

Many thanks for your request to comment on the sustainability aspects of this application.

I have viewed the applicant documents and there is reference to the relevant Mid Suffolk sustainability policies within the Planning Statement Incorporating Design & Access Statement. In particular the sections relating to U values of the fabric, air tightness, thermal bridging mitigation and use of an Air Source Heat Pump to provide space and water heating.

I have no objection to the application and should the Planning Dept approve it I would suggest the following condition.

Prior to the commencement of development a scheme for the provision and implementation of water, energy and resource efficiency measures, during the construction and operational phases of the development shall be submitted to and approved, in writing, by the Local Planning Authority. The scheme shall include a clear timetable for the implementation of the measures in relation to the construction and occupancy of the development. The scheme shall be constructed and the measures provided and made available for use in accordance with such timetable as may be agreed.

The Sustainability & Energy Strategy must be provided detailing how the development will minimise the environmental impact during construction and occupation (as per policy CS3, and NPPF) including details on environmentally friendly materials, construction techniques minimisation of carbon emissions and running costs and reduced use of potable water ( suggested maximum of 105ltr per person per day).

Details as to the provision for electric vehicles should also be included please see the Suffolk Guidance for Parking, published on the SCC website on the link below: https://www.suffolk.gov.uk/planning-waste-and-environment/planning-and-development- advice/parking-guidance/

The document should clearly set out the unqualified commitments the applicant is willing to undertake on the topics of energy and water conservation, CO2 reduction, resource conservation, use of sustainable materials and provision for electric vehicles.

Clear commitments and minimum standards should be declared and phrases such as ‘where possible, subject to, where feasible’ must not be used.

Evidence should be included where appropriate demonstrating the applicants previous good work and standards achieved in areas such as site waste management, eg what recycling rate has the applicant achieved in recent projects to show that their % recycling rate commitment is likely.

Reason – To enhance the sustainability of the development through better use of water, energy and resources. This condition is required to be agreed prior to the commencement of any development as any construction process, including site preparation, has the potential to include energy and resource efficiency measures that may improve or reduce harm to the environment and result in wider public benefit in accordance with the NPPF.

Guidance can be found at the following locations: https://www.midsuffolk.gov.uk/environment/environmental-management/planning- requirements/

Regards,

Peter

Peter Chisnall, CEnv, MIEMA, CEnvH, MCIEH Environmental Management Officer Babergh and Mid Suffolk District Council - Working Together Tel: 01449 724611 Email: [email protected] www.babergh.gov.uk www.midsuffolk.gov.uk

Consultation Response Pro forma

1 Application Number DC/20/02129 Land South East of Low Road, Debenham 2 Date of Response 23/06/20

3 Responding Officer Name: Karolien Yperman Job Title: Heritage and Design Officer Responding on behalf Heritage Team of... 4 Summary and The proposal is considered to cause Recommendation (please delete those N/A) • a low level of less than substantial harm to the significance of Cherry Tree Farmhouse, because Note: This section must be it would fully surround the former farmstead with completed before the modern housing and largely remove the last response is sent. The remnant of its connection to the surrounding recommendation should be countryside. based on the information submitted with the application.

5 Discussion This application is for the erection of 18 dwellings in the Please outline the setting of the Grade II listed Cherry Tree Farmhouse. reasons/rationale behind Another Grade II listed building ‘20 Low Road’, is how you have formed the located further to the north along Low Road, however recommendation. the proposed development would be unlikely to affect its Please refer to any setting. The heritage concern therefore relates to the guidance, policy or material impact of the proposed development on the setting of considerations that have Cherry Tree Farmhouse, which contributes to its informed your significance. recommendation. This application follows pre-application discussions. Note the Heritage comments at pre-application stage: The application site is located adjacent to the grounds of Cherry Tree Farmhouse to the south-west. Cherry Tree Farmhouse is noted in the listing description as being an early-C16 former farmhouse. Historic OS maps show the farmhouse and a collection of outbuildings to the south-west, most of which appear to still exist today.

Cherry Tree Farmhouse and its outbuildings formed a small contained farmstead at the southern edge of the historic core of Debenham, which is a predominantly linear village along the High Street. Large scale modern development has spread between Low Street and Gracechurch Street in the second half of the C20, connecting Cherry Tree Farmhouse to the built-up area of Debenham. The immediate setting of the listed

Please note that this form can be submitted electronically on the Councils website. Comments submitted on the website will not be acknowledged but you can check whether they have been received by reviewing comments on the website under the application reference number. Please note that the completed form will be posted on the Councils website and available to view by the public.

building was also altered through the erection of two modern dwellings, Clayhithe and The Orchard, in the 1970s and 1980s respectively, and the conversion of its former barn to a dwelling in the 1990s. Additionally, the Deben Rise cul-de-sac has encroached on the former farmstead from the south-east. As a result, the connection between Cherry Tree Farmhouse and the surrounding open countryside has been drastically reduced.

The application site and the field adjoining it to the south are allocated as sites for housing in the Debenham Neighbourhood Plan. The development of these sites would fully surround the former farmstead, eliminating the last remnant of its historic setting still intact. In principle, this would likely be considered to cause a level of less than substantial harm to the designated heritage asset. Therefore, if a scheme is to be successful, a demonstration of the public benefits would need to be provided in an application and an assessment of these would need to be considered by the Planning Department when making a decision.

In order to reduce the current level of harm, the Heritage Team recommends reconsidering the layout, particularly around the boundary with Cherry Tree Farmhouse and perhaps reducing the number of dwellings. The current site layout appears quite cramped, especially the dwellings in the north-eastern corner as they are located right against the boundary. Soft landscaping should also be reinforced on this boundary to provide a buffer and a sense of open space between the adjacent listed building and the proposed new housing development.

In conclusion, development on this site would likely be considered to cause a low level of less than substantial harm to the significance of Cherry Tree Farmhouse, because it would fully surround the former farmstead with modern housing and largely remove the last remnant of its connection to the surrounding countryside.

This current application has reduced the number of dwellings from 25 to 18, however the layout and density of dwellings appears very similar on the northern end of the site, closest to the listed building. The former farmstead would still be surrounded by modern development, which would be located quite close to its south-western boundary. The heritage implications of

this application are therefore very similar to those discussed at pre-application stage.

The proposed development would still be considered to cause a low level of less than substantial harm to the significance of Cherry Tree Farmhouse. The proposal would therefore not meet the requirements of section 66 of the P(LBCA)A 1990, nor the policies within the NPPF or the Local Plan.

The choices of facing and roofing materials would not add to or reduce the harm identified. As the principle of development is considered harmful, it is very unlikely that this harm could be removed entirely, however further landscaping could be provided on the boundary with Cherry Tree Farmhouse, as discussed previously, to provide a soft buffer.

6 Amendments, Decision-takers should be mindful of the specific legal Clarification or Additional duties of the local planning authority with respect to the Information Required special regard to the desirability of preserving the listed (if holding objection) building or its setting or any features of special architectural or historic interest which it possesses, as If concerns are raised, can set out in section 66 of the Planning (Listed Buildings they be overcome with and Conservation Areas) Act 1990. changes? Please ensure any requests are proportionate

7 Recommended conditions

-----Original Message----- From: BMSDC Public Realm Consultation Mailbox Sent: 22 June 2020 14:56 To: BMSDC Planning Area Team Blue Subject: RE: MSDC Planning Consultation Request - DC/20/02129

The Public Realm Team consider that the amount of public open space within this development is sufficient and therefore do not object to this proposed development. It is noted that the future management of this open space is to be transferred to a resident owned management company and this is welcomed.

Regards

Dave Hughes Public Realm Officer

-----Original Message----- From: [email protected] Sent: 05 June 2020 15:11 To: BMSDC Public Realm Consultation Mailbox Subject: MSDC Planning Consultation Request - DC/20/02129

Please find attached planning consultation request letter relating to planning application - DC/20/02129 - Land South East Of, Low Road, Debenham, Suffolk

Kind Regards

Planning Support Team

MID SUFFOLK DISTRICT COUNCIL

MEMORANDUM

TO: Daniel Cameron - Planning officer

From: Sacha Tiller - Strategic Housing Team

Date: 20.06.2020

SUBJECT: - Application Reference: DC/20/02129

Proposal: Planning Application. Erection of 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road.

Location: Land South East Of, Low Road, Debenham, Suffolk

Key Points

1. Background Information

A development proposal for sixteen (18) affordable residential dwellings submitted by Mid Suffolk District Council.

The policy position is for 35% affordable housing to be provided and therefore this site should provide 6.3% affordable housing. The proposal is for 6 affordable housing dwellings.

2. Housing Need Information:

2.1 The Ipswich Housing Market Area, Strategic Housing Market Assessment (SMHA) document, updated in 2019, confirms a continuing need for housing across all tenures and a growing need for affordable housing. A new SHMA is currently being written but outcomes are not available at the time of this consultation.

2.2 The 2019 SHMA indicates that in Mid Suffolk there is a need for 127 new affordable homes per annum.

2.3 The Council’s 2014 Suffolk Housing Needs Survey shows that there is high demand for smaller homes, across all tenures, both for younger people, who may be newly forming households, and also for older people who are already in the property-owning market and require different, appropriate housing, enabling them to downsize. Affordability issues are the key drivers for this increased demand for smaller homes.

2.4 The Council’s Choice Based Lettings system currently has circa.690 applicants registered for affordable housing in Mid Suffolk at January 2020

2.5 The Council’s Choice Based Lettings system currently has 16 applicants registered for affordable housing, who have a local connection to Debenham as at of June 2020, with 6 applicants aged over 55. The highest need is for 2, 3 and 1 bed respectively. As this scheme is proposed to meet district wide housing needs, 690 applicants on the GTHC register is the relevant figure to consider.

2.6 The Debenham Neighbourhood Plan (NDP) has been through Examination and Public Referendum and was subsequently adopted in March 2019. Therefore, the content of this plan should be taken into consideration and its preferred framework for housing given adequate consideration and weight.

3. Proposed mix for Affordable Housing (Total 6) 3 x 1 bed 2 person @ 50sqm (Plots 7,8 and 9) 3 x 2 bed 4 person @ 80sqm (Plots 4,5 and 6)

4. Preferred mix for Affordable Housing (Total 6)

Affordable rented = 4 • 2 x 2 bedroom 4 person houses @ 79sqm • 2 x 3 bedroom 5 person houses @ 93sqm

Shared Ownership = 2 • 2 x 2 bedroomed 4 person houses @ 79 sqm

4.1 There is strong need for home more suited to the over 55 age brackets within the district and the supply of single storey dwellings or 1.5 storeys has been very limited over the last 10 years in the locality. Mid Suffolk and the county as a whole faces a large increase in the population of over 65-year olds so we need to ensure there are suitable housing choices for older people to remain in their communities.

4.2 There is growing evidence that housebuilders need to address the demand from older people who are looking to downsize or right size and still remain in their local communities.

4.3 Broadband and satellite facilities as part of the design for all tenures should be standard to support.

4.4 All new properties need to have high levels of energy efficiency.

4.5 Details of the mix of type and size of the all the dwellings to be submitted to and approved in writing by the local planning authority.

5. Other requirements for affordable homes:

• Properties must be built to current Homes England National Housing Standards March 2015.

• The council is granted 100% nomination rights to all the affordable units on first lets and 100% on subsequent lets.

• Any Shared Ownership properties must have an initial share limit of 70%.

• The Council will not support a bid for Homes England grant funding on the affordable homes delivered as part of an open market development. Therefore, the affordable units on that part of the site must be delivered grant free.

• The location and phasing of the affordable housing units must be agreed with the Council to ensure they are integrated within the proposed development according to current best practice.

• (a) not Occupy or permit Occupation of more than fifty per cent (50%) (rounded up to the nearest whole Dwelling) Market Housing Units in each Phase until fifty per cent (50%) of the Affordable Housing Units for that Phase have been constructed and are ready for Occupation and have been transferred to the Registered Provider; and

• (b) not Occupy or permit Occupation of more than eighty per cent (80%) (rounded up to the nearest whole Dwelling) Market Housing Units in each Phase until all of the Affordable Housing Units for that Phase have been constructed and are ready for Occupation and have been transferred to the Registered Provider

• On larger sites, the affordable housing should not be placed in groups of more than 15 units

• Adequate parking provision is made for the affordable housing units and cycle storage and bin stores.

• In addition to the mix and NDSS, any ground floor 1 bedroomed flats to have a level access shower in the bathroom instead of a bath. Applicant to confirm if the dwellings will meet Part M (4) Cat.2 of the Building Regulations.

• It is preferred that the affordable units are transferred to one of the Council’s partner Registered Providers – please see www.baberghmidsuffolk.gov.uk under Housing and Affordable Housing for full details.

Consultation Response Pro forma

1 Application Number DC/20/02129

2 Date of Response 26/06/2020

3 Responding Officer Name: Hannah Bridges Job Title: Waste Management Officer Responding on behalf Waste Services of... 4 Recommendation (please delete those N/A) No objection subject to conditions

Note: This section must be completed before the response is sent. The recommendation should be based on the information submitted with the application.

5 Discussion Ensure that the development is suitable for a 32 tonne Please outline the Refuse Collection Vehicle (RCV) to manoeuvre around reasons/rationale behind attached are the vehicle specifications. how you have formed the recommendation. Please refer to any OLYMPUS - 8x4MS Wide - Euro 6 - Smooth Body RCV Data Sheet_20131030.pdf guidance, policy or material considerations that have informed your See the waste guidance on new developments below. recommendation.

SWP Waste Guidance v.21.docx

The road surface and construction must be suitable for an RCV to drive on.

Please provide plans with each of the properties bin presentations plotted of approval.

6 Amendments, Clarification or Additional Information Required (if holding objection)

If concerns are raised, can they be overcome with changes? Please ensure

any requests are proportionate

7 Recommended Meet the conditions in the discussion. conditions

From: Planning Department Sent: 19 June 2020 11:27 To: BMSDC Planning Area Team Blue Subject: RE: APPLICATION FOR PLANNING PERMISSION - DC/20/02129

FAO Daniel Cameron Sustainable Communities Babergh and Mid Suffolk District Councils

Dear Mr Cameron,

Thank you for inviting comments from the East Suffolk Drainage Board’s Engineer for the proposal set out below (your reference DC/20/02129).

Planning Application: Erection of 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road. Proposal: Land South East Of, Low Road, Debenham, Suffolk

This development site is outside the boundary of East Suffolk Internal Drainage District. The watercourse along the northern boundary of the site is designated main river and is therefore not regulated by the Internal Drainage Board.

After careful consideration therefore, East Suffolk Drainage Board has no comments to make regarding this application.

Kind regards,

Philippa

Philippa Noon

Sustainable Development Officer t: +44 (0)1553 819623 | e: [email protected] | e: [email protected]

Water Management Alliance Kettlewell House, Austin Fields Industrial Estate, King’s Lynn, Norfolk, PE30 1PH, UK t: +44 (0)1553 819600 | f: +44 (0)1553 819639 | e: [email protected] | www.wlma.org.uk

Consisting of Broads Drainage Board, East Suffolk Drainage Board, King's Lynn Drainage Board, Norfolk Rivers Drainage Board and South Holland Drainage Board in association with Pevensey and Cuckmere Water Level Management Board

The information in this e-mail, and any attachments, is confidential and intended solely for the use of the individual or entity to whom it is addressed. The views expressed in this e-mail may not represent those of the Board(s). Nothing in this email message amounts to a contractual or legal commitment unless confirmed by a signed communication. All inbound and outbound emails may be monitored and recorded.

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Police Station, Old Nelson Street, Lowestoft NR321PE Telephone: 101 or 999 in an emergency Fax: 01473 613737 (24 hrs) Calls may be monitored for quality control, security and training purposes.

Direct Dial: 01986 835276 Date: 15/06/2020

PLANNING APPLICATION: DC/20/02129

Proposal: Planning Application. Erection of 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road.

Location: Land South East of Low Road, Debenham, Suffolk

Officer: Daniel Cameron

The crime prevention advice is given without the intention of creating a contract. Neither the Home Office nor Police Service accepts any legal responsibility for the advice given. Fire Prevention advice, Fire Safety certificate conditions, Health & Safety Regulations and safe working practices will always take precedence over any crime prevention issue. Recommendations included in this document have been provided specifically for this site and take account of the information available to the Police or supplied by you. Where recommendations have been made for additional security, it is assumed that products are compliant with the appropriate standard and competent installers will carry out the installation as per manufacturer guidelines. Suppliers of suitably accepted products can be obtained by visiting www.securedbydesign.com.

Dear Mr Cameron

Thank you for the opportunity to comment on the above planning application.

Having reviewed the DAS it is documented that there are 18 dwellings with 6 affordable dwellings comprising of a mixture of single and two storey 1, 2, or 3 bed dwellings. The development is being looked at in 3 Phases though currently there is still some consultation around the access point. Parking will be provided in either single garages, in-curtilage parking, some block parking and some visitor parking spaces throughout the development. Secure Cycle storage is to be provided for each dwelling, however as this stage this has not been specifically outlined. I could not find any reference to Crime Prevention through Environmental Design (CPTED) or Secured by Design Principles being utilised in the layout or physical standards of the dwellings but there was acknowledgement that the design was in accordance with “Suffolk Design Guide Standards” on page 18 Point 4.27 of the DAS. The “Design Expectations Validation Requirement Form” does mention that security levels were “not unusual” but that of “domestic security levels” but no reference to what those levels are (point 55 page 15).

The design layout has some good points which are in line and recommended within Secured by Design Homes 2019 and Crime Prevention through Environmental Design principles. Those being it has one vehicular way in and out and only two pedestrian/cycle routes in and out (reduced permeability). The parking provided for Plots 9,8,7 is ideal in that it is to the front of the dwellings where there is optimum surveillance, which will help to reduce car crime, ASB and Criminal Damage. Parking is either in single garages or in-curtilage of the dwelling and visitor parking has good surveillance to it as well.

Making Suffolk a safer place to live, work, travel and invest www.suffolk.police.uk

However, there are some areas of concern that could be addressed at this stage in order to reduce the opportunity for crime and therefore reduce the demand on police resources and to make the development a secure, safe and desirable development for residents to live in.

SUMMARY: Areas of concern relate to layout of garages, surveillance to parked vehicles in drives, increase in natural surveillance opportunity, rear access path security and the public open space area (all detailed further below). Suffolk Police would not object to this application if these concerns were addressed at this stage.

It is strongly advised that the applicant applies for ADQ and Secured by Design accreditation for the residential dwellings and I would be pleased to work with the agent and/or the developer to ensure the proposed development incorporates the required elements. Building to the physical security of Secured by Design, which is the police approved minimum security standard, will reduce the potential for burglary by 50% to 75% and achieve ADQ.

SECURE BY DESIGN (SBD) An early input at the design stage is often the best way forward to promote a partnership approach to reducing the opportunity for crime and the fear of crime. Secured by Design aims to achieve a good overall standard of security for buildings and the immediate environment. It attempts to deter criminal and anti- social behaviour within developments by introducing appropriate design features that enable natural surveillance and create a sense of ownership and responsibility for every part of the development. These features include secure vehicle parking, adequate lighting of common areas, control of access to individual and common areas, defensible space and a landscaping and lighting scheme which when combined, enhances natural surveillance and safety. Experience shows that incorporating security measures during a new build or a refurbishment project reduces crime, fear of crime and disorder.

Secured by Design is a national crime prevention initiative based upon the principles of "designing out crime" or crime prevention through environmental design and incorporates the latest security standards to address emerging criminal methods of attack. Secured by Design has been proven to reduce the opportunity for crime and the fear of crime, creating safer, more secure and sustainable environments.

Crime Levels: I am currently unable to give crime levels for the area.

The following proposals are recommended and in line with Secured by Designs Homes 2019 (SBDH 2019) in order to prevent the potential for additional crime in the area:

1. GARAGES AND VEHICLE PARKING: Plot 16 garage is of concern as it is located away from the dwelling and has limited surveillance to it. Plot 17 and 18 are also away but are offered some surveillance from the dwellings opposite (Plots 13/12). SBDH 2019 Section 16. 1 and 16.2 stipulates that the entrance should be easily observed from the street and neighbouring dwellings. SBDH 2019 Section 16.6 states that where parking is designed to be adjacent to or between units, a gable end window should be considered to allow residents an unrestricted view over their vehicles.

2. GABLE END WINDOWS: Most of the dwelling designs do not allow for surveillance from the gable ends and those that do have them gable end windows, the surveillance is not positioned from an “active room” but located in a stairwell, or en-suites or bathrooms. The only Plots with appropriate gable end windows are Plots 16, 17 and 18. It is important not to create windowless elevations and blank walls immediately adjacent to public spaces. See SBDH 2019 12 for guidance. Also see SBDH 2019 16.6 for guidance on parking and window offering surveillance to vehicles parked adjacent to or between units.

3. LONG ACCESS PATH: Plots 9 and 8 have a shared access path which has no surveillance to it. These types of paths also allow access to the rear gardens of other properties (ie Plot 10 and not just those they are intending to allow access to). Research studying the distribution of burglary in terraced housing with open rear access footpaths has shown that up to 85% of entries occurred at the back of the house. See SBDH 2019 Section 13 in regards to full guidance on long access paths. To avoid this Plot 9 could have access to their garden from the side of their dwelling (remove the hedging/planting at the side and install fencing along the whole of the side) at the front and access only for Plot 8 could be located from a gate that is in line with the front of Plot 9 and Plot 10’s garage. All gates should be lockable from the both sides.

4. PUBLIC OPEN SPACE and LEAP Areas: Within the areas of Public Open Space/Communal Areas attention should be paid to the sighting and fixing of Gates, Fences, Seats and Pathways. There is concern for Plots 12 and 11 (see SBD H 2019 Section 9.3.4. and 9.3.3) as they are adjacent to the Play Area which has no formal surveillance to the area. This could lead to a gathering area for ASB, causing distress for resides in those dwellings. For guidance please SBDH 2019 Section 9, under the heading “Communal Areas”. It is recommended that at least one of the dwellings should face the communal and play area and that staggered railings or bollards are used to prevent opportunity for easy access of motorcycles/scramblers to the open space area, which will eventually provide cycle/footpath onto neighbouring sites. It is important to also ensure that vehicles are not able to gain access to the area for additional parking with some form or curb/knee rail fencing.

5. STREAM/WATER AREAS: It is recommended that these areas are protected with a secure boundary in order to protect children and pets from danger or use of signage stating water. Please also see Section 9 SBDH 2019 in regards to reducing the potential for ASB and Criminal Damage issues in these areas.

6. CAR PARKING LIGHTING: Communal parking facilities must be lit to the relevant levels as recommended by BS 5489:2013 and a certificate of compliance provided. See section 16.7 SBDH 2019 for the specific lighting requirements as well as Section 16 completely for recommendations for communal parking areas.

7. GATES/FENCING: Recommendation is for all gates to be locking gates as per Section 10 SBDH 2019. All divisional fencing should consist of a 1.8 m close board privacy panel and then 1.5 m close board fencing with 300 ml trellis topping to allow for additional natural surveillance. Rear Fencing should also 1.5 m close board with 300 ml trellis topping. Currently there are no specifications around fencing and boundary treatments.

8. STREET LIGHTING: A lighting plan should conform to Section 18.1 SBDH 2019. Lighting should conform to the requirements of BS 5489:2013. A luminaire that produces a white light source (Ra>59 on the colour rendering index) should be specified but luminaires that exceed 80 on the colour rendering index are preferred.

9. LANDSCAPING: I note that some of the trees and hedging will remain within the boundary and these along with any new planting should conform to Section 17 SBDH 2019. Trees should allow, when mature, crown lift with clear stem to a 2-metre height. Similarly, shrubbery should be selected so that, when mature, the height does not exceed 1 metre, thereby ensuring a 1 metre window of surveillance upon approach whether on foot or using a vehicle. Ensure that there is a maintenance and management plan for Landscaping. Defensive planting should be implemented around those dwellings who windows abut public foot paths. See SBDH 2019 section 8.

10. CYCLE STORAGE: It was noted in the DAS that there would be secure cycle storage provided for all dwellings. This should conform to SBDH 2019 Section 56.

The following legislation is relevant to this application:

Section 17 of the ‘Crime and Disorder Act 1998’

This part of the CDA places a duty on each local authority: ‘to exercise its various functions with due regard to the likely effect of the exercise of those functions on, and the need to do all that it reasonably can to prevent crime and disorder in its area to include anti-social behaviour, substance misuse and behaviour which adversely affects the environment’. National Planning Policy Framework.

National Planning Policy Framework:

Paragraph 91b. Planning policies and decisions should aim to achieve healthy, inclusive and safe places which are safe and accessible, so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion – for example through the use of clear and legible pedestrian routes, and high-quality public space, which encourage the active and continual use of public areas. Paragraph 127(f). Planning policies and decisions should ensure that developments create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.

Further information on SBD can be found at www.securedbydesign.com

I would be happy to work with the developer and architect to assist with the above Secured by Design and Crime Prevention through Environmental Design recommendations.

Partnership working at this stage is the most efficient way to ensure that every opportunity to reduce crime and the fear of crime has been taken

Jackie Norton Designing Out Crime Officer Eastern Area Suffolk Police

4 -

7 July 2020

Daniel Cameron Planning Officer Mid Suffolk District Council Endeavour House, 8 Russell Rd, Ipswich, IP1 2BX

Dear Mr Cameron,

DC/20/02129 Planning Application. Erection of 18no dwellings (including 6no affordable dwellings). Construction of new vehicular access off Low Road. Land South East of Low Road Debenham Suffolk

I am writing on behalf of the Suffolk Preservation Society (SPS) to object to aspects of the above application for the erection of 18 dwellings on a greenfield site due to the proposed access from Low Road and the impact of the proposed layout on Cherry Tree Farmhouse, a designated heritage asset.

Low Road Access

SPS supports the principle of developing this site which is allocated in the 2019 Debenham Neighbourhood Plan. However, the Plan is clear in policy DEB4 that access should be from the south and not from Low Road and therefore development of the site is dependent on the adjacent larger site being brought forward. Para 3.34 clearly sets out the existing problems regarding traffic on Low Road and concludes that it has inadequate scale and structure to accommodate increased traffic. Therefore, bringing this site forward in advance shows a lack of regard for the wishes of the local community and risks seriously undermining the neighbourhood planning process. Moreover, in addition to the capacity concerns the loss of mature hedgerow to accommodate the proposed access and visibility splays will result in a significant loss of rural character on Low Road.

The NPPF is clear at para 14 that where the Neighbourhood Plan is recently made and includes allocations and housing policies, the adverse impact of allowing development that conflicts with the neighbourhood plan is likely to significantly and demonstrably outweigh the benefits. Moreover, para 109 sets out that development should be refused if the residual cumulative impacts on the road network would be severe.

Impact on Cherry Tree Farmhouse

Cherry Tree Farmhouse (grade 2 listed) together with its collection of curtilage listed outbuildings are adjacent to the north east boundary of the site. The proposed development will result in the

farmstead being completed surrounded by more recent housing, removing the last existing connection between the listed farmhouse and its agricultural setting. The proposed layout and landscaping do not demonstrate any attempt to soften the impact of the development on the heritage assets through setting back the houses on this boundary or through additional tree planting; merely relying on existing planting on the neighbouring land to maintain a visual barrier. Historic England guidance on cumulative impact (The Setting of Heritage Assets Good Practice Advice in Planning Note 3 (Second Edition)) sets out that where the significance of a heritage asset has been compromised in the past by unsympathetic development affecting its setting, to accord with NPPF policies consideration still needs to be given to whether additional change will further detract from, or can enhance, the significance of the asset. Negative change could include severing the last link between an asset and its original setting. SPS would suggest reducing the build density in this part of the site and introducing a planted buffer area on the boundary is required to mitigate the impacts of the negative change resulting from the scheme.

We trust that you will find these comments helpful in the consideration of this application and request that we are consulted on any forthcoming amendments to the scheme.

Yours sincerely,

Bethany Philbedge BSc (Hons) MSc (Town Planning) Planning Officer

Cc: Debenham Parish Council Phil Butler, SPS Mid Suffolk District Heritage Team