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

Land South-West of Rembrow Road, Capel St. Mary (Capel St Mary Garden Community)

Prepared by Strutt & Parker on behalf of M. Scott Properties Ltd.

September 2019

Land South-West of Rembrow Road, Capel St. Mary Site Name: (Capel St Mary Garden Community)

Client Name: M Scott Properties Ltd

Type of Report: Regulation 18 Local Plan Representation

Prepared by (S&P): Richard Clews BA(Hons) DipTP

Checked by (MSP): Richard Martin

Approved by (S&P): Richard Clews

Approved by (MSP): Rob Scott

Date: September 2019

COPYRIGHT © STRUTT & PARKER. This publication is the sole property of Strutt & Parker and must not be copied, reproduced or transmitted in any form or by any means, either in whole or in part, without the prior written consent of Strutt & Parker. The information contained in this publication has been obtained from sources generally regarded to be reliable. However, no representation is made, or warranty given, in respect of the accuracy of this information. We would like to be informed of any inaccuracies so that we may correct them. Strutt & Parker does not accept any liability in negligence or otherwise for any loss or damage suffered by any party resulting from reliance on this publication.

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

Table of Contents

INTRODUCTION ...... 1

1. OVERALL HOUSING NEED ...... 2

USE OF STANDARD METHOD...... 2 PROPOSED HOUSING REQUIREMENT ...... 2 CROSS BOUNDARY NEED ...... 3

2. SPATIAL DISTRIBUTION OF HOUSING ...... 7

SUITABILITY OF SETTLEMENTS TO ACCOMMODATE GROWTH ...... 7 INFRASTRUCTURE CORRIDORS ...... 8

3. WHY CAPEL ST MARY? ...... 2

THE A12 CORRIDOR ...... 2 SETTLEMENT HIERARCHY ...... 3 CAPACITY TO ACCOMMODATE PROPOSED AND ADDITIONAL GROWTH ...... 6

4. POLICY LA055 - LAND SOUTH-WEST OF REMBROW ROAD, CAPEL ST MARY ...... 7

EXISTING POLICY WORDING...... 7 ANALYSIS OF PROPOSED ALLOCATION ...... 8 INFRASTRUCTURE – NEW A12 JUNCTION ...... 8 DELIVERY OF HOUSING UP TO 2036 ...... 8 CIL CONTRIBUTIONS ...... 8 SUSTAINABILITY APPRAISAL ...... 9 AMENDMENTS TO LA055 POLICY WORDING ...... 12

NON-SITE-SPECIFIC MATTERS ...... 13

OVER RELIANCE ON WINDFALL SITES ...... 13 DELIVERY TEST ACTION PLAN ...... 14

SUMMARY ...... 14

Appendices

Appendix A: Location Plan Appendix B: A12 Settlement Sustainability Analysis

Introduction

The purpose of these representations is to support and refine specific areas of the emerging Local Plan (eLP), so that the eLP can be found sound.

These representations are submitted by Strutt & Parker on behalf of M Scott Properties Ltd (Scott Properties) 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 eLP and the proposed site allocation within the eLP: Policy LA055 - Land South-West of Rembrow Road, Capel St. Mary, which is from here onwards referred to as the Capel St Mary Garden Community (CGC) or Policy LA055.

CGC has been identified as suitable for inclusion within the Settlement boundary and allocated for approximately 550 dwellings and 5,000m2 employment floorspace, referred to as site Ref. SS0752 in the Plan-making process to date and policy LA055 within the eLP.

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1. Overall Housing Need

Use of Standard Method

1.1 We support the use of the Standard Method to calculate the starting point for the District’s housing requirements. The NPPF is clear (paragraph 60) that the Standard Method should be used, unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.

1.2 Planning Policy Guidance (PPG)1 is clear that the Standard Method identifies the minimum annual housing requirement. Other factors must then be considered to determine the number of homes that should be planned for. Such factors include unmet housing need within neighbouring areas, which we return to later within this representation.

1.3 We support the Local Plan Preferred Options (LPPO) proposal to set the housing requirement as a minimum – this is necessary to ensure conformity with the NPPF and its policies to ensure a significant boost to housing land supply is realised.

Proposed Housing Requirement

1.4 The table within Policy SP042 of the eLP confirms the number of homes being provided, in total, by category of settlement. This shows that across the plan area, the eLP proposes the following number of new homes:

New homes 2018-2036 Ipswich Fringe 3,160 Market Towns and Urban Areas 3,373 Core Villages 4,890 Hinterland Villages 821 Hamlets 309 ‘Windfall’ 1000 Total 13,553 Table 1: Number of new homes planned within the eLP

1.5 When added to the potential supply from outstanding planning permissions, the distribution is as follows:

1 Paragraph: 002 Reference ID: 2a-002-20190220 2 Page 40 – Joint Local Plan Preferred Option (Regulation 18) Consultation

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New homes 2018-2036 (total including sites with outstanding planning permission as at 1 April 2018) Ipswich Fringe 4,147 Market Towns and Urban Areas 5,829 Core Villages 7,898 Hinterland Villages 2,068 Hamlets 697 ‘Windfall’ 1000 Total 21,639 Table 2: Number of new homes including sites without outstanding planning permission (01/04/18)

Cross Boundary Need

1.6 Section 5 of the eLP concerns the Duty to Cooperate. Babergh and Mid Suffolk are two of the four authorities that are progressing joint work through the Ipswich Strategic Planning Board (previously the Ipswich Policy Area) on strategic cross-boundary issues affecting the four authorities of Ipswich Borough Council, Suffolk Coastal District Council, Mid-Suffolk District Council and Council. In particular, and with specific relevance to these representations, the authorities (following the Inspector’s Report in 2017 on the Examination of the now adopted Ipswich Local Plan) are working together in order to meet the housing need for the Ipswich Housing Market Area to agree the strategic distribution of development to meet that need.

1.7 In 2017 the Ipswich Local Plan Inspector reported as follows:

“28. Given my concerns about the robustness of the 13,550 OAN there is an urgent need for the Council to work with its neighbouring authorities to produce a fit-for-purpose objective assessment of need for new housing for the Ipswich Housing Market Area. This conclusion is consistent with my Interim Findings published in April 2016 following the initial Examination hearings but also has regard to the subsequently-published 2014-based household projections. Thus, and in line with the Memorandum of Understanding detailed in the assessment of the Duty to Co-operate, MM4 - MM6 (policies CS6 and CS7) commit the Council to working with its neighbours to prepare an updated OAN for housing for the HMA as a whole, a strategy for the distribution of it between the constituent districts and the adoption of joint or aligned local plans to deliver this by 2019. These modifications are thus necessary for the soundness of the plan, although I have amended MM4 – MM6 slightly, reflecting consultation comments, to correct a typographical error and in the interests of clarity.

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However, the Council contends that appropriate, available and deliverable housing sites within Ipswich itself would only deliver 9,777 dwellings during the plan period. Whilst with reference to specific sites there is some challenge to this figure, there is nothing to give confidence that substantially more than this number of dwellings can be delivered in the town to 2031. Based on all that I have read and heard, considered in the round and notwithstanding the 2014- based household projection figure, I conclude that it is highly likely that the forthcoming work will identify that the OAN for Ipswich for the period to 2031 is at least equivalent to the 9777 dwellings which the Council contends can be delivered in this period”

1.8 The key points arising from this ongoing strategic cross-boundary assessment regarding housing need across the Ipswich Strategic Planning Area are that the four authorities are presently planning to meet a housing need of some 39,000 (rounded figure) dwellings up to 2036. The submitted Statement of Common Ground (SoCG) recognises that “due to the close functional relationship between Ipswich Borough and the surrounding Districts, there is potential for cross-boundary issues relating to infrastructure provision, transport and highways and landscape/townscape as well as site selection where sites adjoin or cross the Ipswich Borough boundary”.

1.9 The authorities have prepared a Statement of Common Ground (SoCG Version 3) (December 2018) to address the strategic cross-boundary planning matters in the Ipswich Strategic Planning Area, which is part of the documentation supporting this consultation. Key extracts from that document regarding the approach to the delivery of the housing requirement are set out below:

“Housing

C. Agreeing the approach to delivery of the housing requirement

Background

The SHMA Part 1 identified the objectively assessed housing need (OAN) for the four local planning authorities. Subsequently, the Government proposed a national standard method for the calculation of housing need through the ‘Planning for the Right Homes in the Right Places’ consultation (September 2017). The Government has carried these proposals forward through the revisions to the NPPF and the Planning Practice Guidance.

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Paragraph 60 of the NPPF (July 2018) states that the standard methodology should be used as the basis for identifying the local housing need, unless there are exceptional circumstances that justify an alternative approach which also reflects current and future demographic trends and market signals

Paragraph 60 of the NPPF states that in establishing the amount of housing to be planned for, planning authorities should take into account any needs that cannot be met in neighbouring areas.

Evidence

The two key pieces of evidence relevant are the housing need and the housing supply.

The housing need as calculated under the national standard method is set out in the table below, alongside the objectively assessed housing need identified through the 2017 Strategic Housing Market Assessment:

The standard method calculated as per the current policy in the NPPF and Planning Practice Guidance is shown in the shaded boxes above.

On 26th October 2018 the Government launched a consultation titled Technical Consultation on Updates to National Planning Policy and Guidance. This proposes that as an interim measure housing need using the standard method should be calculated using the 2014-based household projections. For all authorities in the ISPA this approach results in housing need numbers less than or equal to the need calculated using the 2016-based projections. These figures are shown in the table above.”

1.10 and

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“Process of reaching outcomes and agreements

The Ipswich Strategic Planning Area Board provides a mechanism to discuss the authorities’ approach to housing requirements and to inform and guide the approach to be taken within each Local Plan.

1.11 While the Duty to Cooperate is referenced clearly in the eLP at Section 5, and paragraph 1.16 states that policies will make sufficient provision for all needs, ‘including any relevant cross boundary issues’, we remain concerned that the eLP reflects only infrastructure needs (through the IDP), but that housing needs arising from Ipswich are not being considered in sufficient detail. We consider it likely that the need arising from Ipswich will not be met through the Local Plans prepared by the four authorities, and that the Statement of Common Ground does not provide sufficient reassurance that these needs will be met. Further discussions with the neighbouring authorities should directly consider whether Babergh and Mid Suffolk can increase their housing delivery in order to assist with meeting the housing needs of the Ipswich Strategic Area, particularly towards the latter end of the Plan Period.

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2. Spatial Distribution of Housing

2.1 Whilst Table 2 above indicates that, cumulatively, the number of homes proposed to be provided in Core Villages actually exceeds the number proposed for Market Towns and Urban Areas, it is important to remember that there are 29 Core Villages but only 6 Market Towns / Urban Areas.

2.2 When one considers the number of dwellings proposed by the eLP per settlement within each settlement hierarchy, the eLP’s proposed strategy appears far less counter intuitive, far more sustainable, and it is clear that, overall, higher levels of growth are being directed to settlements higher in the settlement hierarchy. This is illustrated by the table below:

New homes identified in Total homes 2018-2036 the Plan 2018-2036 (per including outstanding settlement / geographical planning permission as at 1 area) April 2018 (per settlement / geographical area) Ipswich Fringe 3,160 4,147 Market Towns and 562 972 Urban Areas Core Villages 169 272 Hinterland Villages 12 29 Table 3: Summarised table from Policy 04 LPPO

Suitability of Settlements to Accommodate Growth

2.3 The Table contained within Policy SP04 of the eLP shows that not all settlements within each tier of the settlement hierarchy are proposed to accommodate the same level of growth. This is entirely appropriate.

2.4 As the LPPO recognises at paragraph 8.4, not all settlements within a particular category will be equally suitable / able to accommodate the same level of growth:

“It is important that development is proportionate to the provision of services and facilities within those settlements… However, all settlements within each category are not equal, and there will be some variance in levels of growth dependent upon a number of factors” 3

2.5 We support this view, and consider that it is imperative that the strategy for growth does not slavishly follow the settlement hierarchy, but rather considers the multitude of

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factors which can influence the level of growth that is sustainable and deliverable for an area.

2.6 Such considerations can include wider objectives and spatial strategy, local constraints and opportunities, transport considerations, and inter-relationships between particular settlements. It follows that a settlement may be suitable to accommodate more growth than another positioned higher, or at the same level, within the settlement hierarchy.

2.7 The following comments of the Planning Inspector appointed to examine the 2014 Uttlesford Local Plan supported such a view:

a. “Where it can be justified by relevant economic, social and environmental factors a case can sometimes be made to direct a greater or lesser amount of development to a settlement than would reflect its strict place in the settlement hierarchy. Some of the factors discussed during the hearing (eg locally identified demographic and other needs, local constraints and opportunities, patterns of bus services, and inter-relationships between particular settlements) can be relevant to such decisions and can be considered in taking the plan forward” (paragraph 3.25 of the Inspector’s Examination Conclusions 19 December 2014).

2.8 We note that the LPPO recognises the benefits of a spatial strategy which includes a focus of growth along the transport corridors of the A12, A14 and railway lines. We consider such an approach would be appropriate and justified.

Infrastructure Corridors

2.9 By focusing growth along the key infrastructure corridors (A12, A14 and railway lines), the social, environmental and economic benefits will not only be felt within the Joint District, but also have a positive impact on the settlements / Districts beyond the Joint District boundary.

2.10 The A12 stretches c. 9 miles within the District boundary and acts as a corridor between Colchester and Ipswich. There are a number of main junctions along this stretch of the A12 that offer the opportunity to join and leave the highway.

2.11 The A12 therefore represents a key opportunity to deliver growth in locations that would allow access to this highway corridor, and the various social and economic opportunities that lie at Colchester and Ipswich.

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2.12 Appendix C represents an analysis of the opportunities to accommodate growth within existing settlements along the A12 this analysis is a layered approach, which first seeks to map 1km from each junction and then overlays the AONB. The rationale for using 1km, is land / settlements within this isodistance would represent the most sustainable development in accordance with access to key infrastructure.

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3. Why Capel St Mary?

3.1 Before providing comments in direct relation to the eLP and the supporting evidence base, it is felt appropriate to set the scene with paragraph 72 from the NPPF:

“The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. Working with the support of their communities, and with other authorities if appropriate, strategic policy-making authorities should identify suitable locations for such development where this can help to meet identified needs in a sustainable way. In doing so, they should: a) consider the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for net environmental gains; …

The A12 Corridor

3.2 The A12 corridor is a critical part of the spatial strategy for the eLP, with significant economic and housing proposals that are central to the spatial strategy of the Plan. This is recognised in the eLP at: paragraph 2.4 as providing strategic transport connectivity with main road links from London to Felixstowe and Cambridge; at Table 1 as a Key Planning Issue for Housing and Employment; and at paragraph 9.5 as allocations of strategic importance to the delivery of the Joint Local Plan.

3.3 As detailed within this document and the supporting information, Capel St. Mary is the only opportunity to deliver a significant number of new homes on a site which is both within 1km of the A12 and outside of the Dedham Vale Area of Outstanding Natural Beauty.

3.4 The exclusion of sites within the AONB is consistent with the ‘Sieving Criteria’4 used within the Sustainability Appraisal:

“Exclusionary criteria – e.g. flood risk areas, areas of outstanding natural beauty (AONB) and green belt (taking into account Section 9 of the NPPF

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(paras 79-92)) and areas outside the pattern of development set out in the strategy.”

3.5 Given the economic and social opportunities within Ipswich and Colchester, Capel St Mary presents a unique opportunity to provide the most accessible location to Colchester and Ipswich within the Babergh District; 8 and 3 miles respectively, without impacting the rural character and associated road network of the hinterland villages.

3.6 This approach accords with the eLP:

“The transport corridors of the A12, A14 and railway lines within the area represent a strong effect upon market forces and demand for both housing and employment land. Compatible growth along these areas can help to reduce the need to travel by ensuring closer location of where people live, relative to shops, services and employment.” 5

Settlement Hierarchy

3.7 We support the Council’s recognition that Capel St Mary (Core Village) represents a unique opportunity for additional growth within the District through the allocation of a minimum of 792 homes. However, the methodology of assessing and scoring settlements within the Topic Paper – Settlement Hierarchy Review July 2019 (SHR) does not reflect this.

3.8 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.

3.9 Crucially, as explained below, the scoring system used is crude and does not seem to reflect more subtle but still material factors that certain settlements play within the District (as per paragraph 78 of the NPPF6); for example, the proximity of smaller settlements to larger settlements (such as Capel St Mary).

3.10 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

5 Paragraph 09.06 Joint Local Plan – Preferred Options (Reg 18) – July 2019 6 “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.” Paragraph 78, NPPF.

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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.

3.11 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 comprehensive 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. This is as important for Core Villages (where there is planning infrastructure investment, as per the Infrastructure Delivery Plan) in proximity to lower-category villages as it is for those lower category villages in proximity to higher category settlements.

b. Distances to neighbouring settlements are not always appropriate in a rural district where travel times are likely to be more meaningful in assessing relative connectivity (given the constraints of the rural road networks and public transport). It is recommended that a score is based on travel time, potentially dropping the 5km distance entirely – as example of such can be seen below, which has used a 5 minute drivetime, along with associated speed limits and tested this with Raydon and Capel St Mary.

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Figure 1: 5-minute drivetime analysis; Capel St Mary (red) and Raydon (blue).

c. The scores of different facilities should not hold the same weight. In the absence of a consultation on the scoring, a rational assessment of the relative importance of facilities would provide a more wholistic 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 between them in the scores. 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 their importance in defining a settlement.

d. The value of local employment, as well access to key economic centres, should be given much greater weight to reflect their importance in creating balanced communities and reducing the need to travel.

3.12 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

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distance. This should include settlements outside of Babergh and Mid Suffolk, such as Colchester and Ipswich, and not be limit to proximity to settlements within the district.

3.13 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 larger, better serviced settlements with a strong hinterland of villages to accurately recognise and benefit from the services offered locally.

3.14 Other scoring elements, such as the availability of superfast broadband, can also be misconstrued. Currently, Ofcom consider superfast broadband to be any speed above 50Mb (download), not 74Mb as set out in the Hierarchy. Capel St. Mary currently benefits from the provision of very good internet speeds. A quick study online shows that speeds of up to 80mb (ranked as superfast fibre) are available within Capel St. Mary.

Capacity to accommodate proposed and additional growth

3.15 Direct conversations with the key service providers within Capel St Mary confirm that they either currently have available capacity or can expand their existing site to accommodate growth. Some of these services have been explored already in the eLP and IDP.

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4. Policy LA055 - Land South-West of Rembrow Road, Capel St Mary

Existing Policy Wording

4.1. Site Size - 26 ha

Approximately 550 dwellings and 5,000m2 of employment floorspace (with associated infrastructure).

The development shall be expected to comply with the following: a. The relevant policies set out in the Joint Local Plan; b. Design, layout and landscaping sympathetic to the heritage assets within and immediately adjacent to the site; c. Trees covered by Tree Preservation Orders are retained; d. Public rights of way through the site are retained and / or enhanced; e. Provision of land for public open space and for community use; f. Highway mitigations at the London Road/The Old Street Junction and enhancement to the northern bound slip road onto the A12; g. Contributions, to the satisfaction of the LPA, towards educational provision; h. 0.1ha of land on the site to be reserved for a new pre-school setting; and, i. Contributions, to the satisfaction of the LPA, towards healthcare provision.

Figure 2: Settlement Boundary for Capel St. Mary as set out in the Regulation 18 JLP, which includes site LA055.

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Analysis of proposed allocation

Infrastructure – new A12 junction

4.2. The Infrastructure Delivery Plan acknowledges, through dialogue with Suffolk County Council and Highways , that the A12 junction improvement associated with the development of LA055 will cost in the region of £5m - £10m.

4.3. Whilst the site is allocated for 550 homes with the additional employment, the junction has the ability to accommodate in excess of 800 homes. Whilst this level of accommodation exceeds what could be feasibly delivered on LA055 in its current form, there may be an opportunity to increase housing delivery through expanding the allocation area to a logical defensible boundary (such as Pound Lane) in order to reduce the reliance on an arbitrary Windfall allowance within the eLP, which has a much lower probability of delivery.

Delivery of housing up to 2036

4.4. Development of Policy LA055 is predicted to be completed by 2031. Given the unmet need associated with neighbouring authorities, the previous under-delivery / lack of delivery with proposed allocations (Lady Lane, Hadleigh for example) and unnecessary reliance on Windfall sites, it would seem an appropriate strategy to maximise proposed allocations and potential sustainable extensions to these allocations in order to boost housing delivery towards the end of the plan period.

4.5. A clear example of the above is land to the west of Policy LA055. This land has a strong defensible boundary in Pound Lane, which also presents another link into the settlement.

CIL Contributions

4.6. 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.

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4.7. 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.

4.8. It is recommended that the survey data and methodology backing up this recommendation is benchmarked against other local authorities within the , in order to ensure the contributions and CIL, combined with any abnormal costs, do not become excessive. We note that CIL can be applied to strategic sites individually and we would be willing to work with the Council to identify whether this approach would be suitable for Capel St. Mary. Should onerous contributions be expected, it may deter such proposals coming forward.

Sustainability Appraisal

4.9. There are elements within the Sustainability Appraisal (SA) which do not accurately reflect Site LA055 and have consequently led to an inaccurate assessment. The SA assessment in respect of Site LA055 has been reproduced below. An additional column - ‘Commentary (S&P)’, has been added to the SA7 in order to give clarity on inaccurate items. The ‘Commentary (S&P)’ is coloured to reflect the scoring system against the Key Questions8 in the SA as shown below in Table 4 for ease of reference.

Possible Impact Explained + Positive ? Uncertain / Unknown 0 Neutral impact - Negative Table 4: SA Scoring System

SA Objectives Key LA055 Qu. Impact Timescale Permanence Commentary (Council) Commentary (S&P) Environmental 1. To improve 1.1 0 Short- Permanent Development of the site Proposals include the health and long term would not result in the loss additional open space – wellbeing of the of open space. land is being made population available for the extension overall and of local sports fields, as

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reduce health well as additional open inequalities space within the Site. 1.2 + Short- Permanent If access is provided onto No comment. long term Rembrow Road, then four or more core services within 800m of the site (with established footpaths): primary school, village shop, doctor surgery, public library and bus stop with peak-time services to and from Hadleigh, Colchester 2. To maintain 2.1 N/A N/A N/A This criterion is No comment. and improve considered a policy levels of consideration only. education and Impacts will be identified skills in the at the ‘whole plan level’ population related to overall overall infrastructure in consideration of sites and policy together. 2.2 N/A N/A N/A This criterion is No comment. considered a policy consideration only. Impacts will be identified at the ‘whole plan level’ related to overall infrastructure in consideration of sites and policy together. 2.3 + Short-long Permanent Fibre or wireless No comment. term broadband available or underway to be completed by December 2019 3. To reduce 3.1 ? Short-long Permanent Site is over 2000m from The site is allocated for poverty and term nearest main employment 5,000m2 of employment, social exclusion area which will provide access and ensure to additional employment access to jobs opportunities. and services 3.2 ? Short-long Site is over 2000m from No comment. term Local Enterprise Zone Social 4. To meet the 4.1 N/A N/A N/A Development of this site The site proposes to meet housing will be expected to deliver a policy compliant level of requirements of a quantum of affordable affordable housing. the whole housing and a mixture of community dwelling types and tenures; however, there is not a comparable level of information available to assess the site against this objective. 4.2 N/A N/A N/A Development of this site The site proposed to will be expected to deliver provide a variety of types a quantum of affordable of housing to meet housing; however, there is various groups of the not a comparable level of community in accordance information available to with the NPPF. assess the site against this objective. 4.3 N/A N/A N/A A suitable housing mix No comment. can be expected to be delivered; however, there is not a comparable level of information available to assess all sites against this objective. 5. To conserve 5.1 ? Short-long Permanent Site within 100m from The site is within 100m and enhance term nearest water source from the nearest water water quality source. and resources 5.2 + Short-long Permanent Site is not within a No comment. term groundwater source protection zone Economic 6. To maintain 6.1 + Short-long Permanent Site is not within 35m of Part of the site is within and where term the central reservation or 35m of a main A Road, possible centre of main A Road but an air quality improve air assessment has provided quality and mitigation measures to reduce noise address concerns. pollution 6.2 + Short-long Permanent Site is over 250m from No comment. term existing mineral extraction site

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7. To conserve 7.1 - Short-long Permanent The site is grade 2 No comment. soil and mineral term agricultural land therefore resources development would result in the loss of valuable agricultural land 8. To promote 8.1 N/A N/A N/A Effects regarding waste No comment. the sustainable generation can be management of neutralised through waste ensuring appropriate areas are incorporated into developments for refuse storage to maximise recycling, however this criterion is considered a policy consideration only. 9. To reduce 9.1 N/A N/A N/A There is not a comparable No comment. contribution to level of information climate change available to assess all sites against this objective – features that would reduce contributions to climate change would only be known at the proposal/ application stage 10. To reduce 10.1 + Short-long Permanent Site is within FRZ1 A foul and surface water vulnerability and term strategy has been increase produced, which resilience to demonstrates that both extreme elements can be weather events addressed effectively. and flooding 10.2 + Short-long Permanent Site is at very low risk No comment. which may be term from surface water caused by flooding climate change 11. To conserve 11.1 ? Short-long Permanent Site is within HRA RAMS No comment. and enhance term 13km ZOI therefore contributions will be sought. Tree Protection Orders along the north boundary of the site which would need consideration. 11.2 + Short-long Permanent Development would not No comment. term have an impact on any NNRs, LoWSs, LNRs, CWS or ancient woodland due to being suitably distanced 11.3 N/A N/A N/A This criterion is The site will seek to meet considered a policy 10% biodiversity net gain. consideration only. Impacts will be identified at the ‘whole plan level’ related to overall infrastructure in consideration of sites and policy together. 11.4 + Short-long Permanent Development would not No comment. term have an impact on any Regionally Important Geological/ Geomorphological Sites due to being suitably distanced 12. To conserve 12.1 ? Short-long Permanent Site approx. 43m from Heritage Impact and where term Grade II listed building Statement confirms that appropriate Capel Grove there will not be a enhance areas significant impact on the and assets of setting of the listed historical and building. archaeological importance and their settings 13. To conserve 13.1 + Short-long Permanent Low sensitivity to change Council’s assessment in and enhance term accordance with the quality and Landscape and Visual local Impact Assessment for distinctiveness the Site. of landscapes 13.2 + Short-long Permanent No TPOs on site TPOs are present on the and townscapes term Site, but none of these trees will be affected. 13.3 ? Short-long Permanent Approximately 50% No comment. term brownfield/greenfield

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13.4 + Short-long Permanent The site is outside but No comment. term adjacent to the existing development limit. 14. To achieve 14.1 0 Short-long Permanent The proposal is for The site is proposed for sustainable term residential development mixed use to include levels of and unlikely to create employment land. prosperity and additional employment economic land. growth 14.2 0 Short-long Permanent The site is not currently No comment. throughout the term employment land, plan area therefore there would be no loss of such land. 14.3 0 Short-long Permanent The site is not currently No comment. term employment land and is proposed for residential use. 15. To revitalise 15.1 0 Short-long Permanent The site is proposed for No comment. the District’s term residential use. town centres 15.2 0 Short-long Permanent The site is proposed for No comment. term residential use. 15.3 0 Short-long Permanent The site is proposed for No comment. term residential use. 16. To 16.1 + Short-long Permanent The site offers good Amendment to wording encourage term relationship to wider requested – ‘the site is efficient transport networks as the located within 1km of the patterns of site is located within 2km slip road to access the movement and of the slip road to access A12.’ the use of the A12. sustainable 16.2 + Short-long Permanent A12 experiences peak A transport assessment methods of term capacity during the AM accompanies the travel in support peak hour. However, representations that of economic mitigation options are details highways capacity growth available. issues can be adequately mitigated. Commentary The site is proposed for residential development and has a good relationship to A number of assessments the wider transport network. The site is within the HRA RAMS 13km ZOI have been made on the therefore contributions will be sought of any residential development. TPOs are basis that additional present along the north boundary of the site which would need consideration. information has not been The site approx. 40m from Grade II listed building. A heritage impact provided to Place assessment would be required to understand the impact of the development on Services, who undertook the heritage assets. The site is recorded as being Grade 2 agricultural land the SA. The ‘Commentary therefore development would result in the loss of high quality soil. Site within (S&P) has sought to 100m from nearest water source. address these inaccuracies by providing the necessary clarity / information.

Amendments to LA055 Policy wording

4.10. CGC is allocated as site ref. LA055 in the eLP. The existing text (found in the site allocations document9) has been duplicated in the sections below and requested changes to the policy have been shown highlighted yellow.

4.11. “An extension to Capel St Mary CEVCP School is required to facilitate growth planned through the Joint Local Plan for the Capel St Mary catchment area. A new pre-school on a 0.1ha site will be required on site LA055. An expansion to Capel St Mary health surgery will be required to mitigate against impact of cumulative growth, for which land is already available on the existing site. Site LA055 will be expected to provide a new

9 https://www.midsuffolk.gov.uk/assets/Strategic-Planning/JLP-Reg18-2019/BMSDC-Joint-Local-Plan-July-2019-Part-3-BDC- Place-Maps-Settlements-A-H.pdf

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link road to the A12, which will limit the highways impact of the new development on the village centre and adjoining residential housing estates.”

4.12. Site Size - 26 ha

Approximately 550 dwellings and 5,000m2 of employment floorspace (with associated infrastructure).

The development shall be expected to comply with the following:

a) The relevant policies set out in the Joint Local Plan; b) Design, layout and landscaping sympathetic to the heritage assets within and immediately adjacent to the site; c) Trees covered by Tree Preservation Orders are retained; d) Public rights of way through the site are retained and / or enhanced; e) Provision of land for public open space and extension to existing playing fields; f) Highway mitigations at the London Road/The Old Street Junction and enhancement to the northern bound slip road onto the A12; g) Contributions, to the satisfaction of the LPA, towards educational provision; h) 0.1ha of land on the site to be reserved for a new pre-school setting; and, i) Contributions, to the satisfaction of the LPA, towards healthcare provision.

Non-Site-Specific Matters

Over reliance on Windfall sites

4.13. At present the eLP is making provision for 1,000 dwellings to be delivered through ‘Windfall developments’. 1,000 dwellings is excessive and inappropriate given the District’s role in meeting cross-boundary needs.

4.14. It is believed that strategic developments, such as LA055, could support the delivery of additional dwellings if adjoining land was considered, provided it did not place a strain on infrastructure which could not be mitigated.

4.15. In addition to the above, and without repeating this representation and its supporting documentation, Capel St Mary is a unique opportunity of strategic importance, and therefore, such an opportunity should be maximised in order to support the effective delivery of key economic goals within the eLP.

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Delivery Test Action Plan

4.16. 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).

4.19. Points made at paragraph 3.4, under the heading of general recommendations, set out the extensive strategies for ensuring 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.

4.20. This approach is supported and in relation to Capel St. Mary we would be keen to continue working with the Council to ensure that development is able to progress promptly upon the adoption of the local plan or the determination of a planning application.

Summary

4.21. The allocation of LA055 is strongly supported. The allocation is supported by the evidence base and is the result of ongoing, detailed work with the Local Planning Authority to identify the most appropriate and sensitive approach to delivering development on this site with benefits to Capel St. Mary. The site has been shown to have limited constraints and to provide benefits to the vitality of Capel St. Mary as a location that is fully capable of supporting significant growth within the District over the plan period. Providing the suggested changes are made, as detailed within this representation, we agree with the assessment and evidence base work undertaken to support the Regulation 18 eLP.

4.22. We provide recommendations for the Settlement Hierarchy Review that we consider would better reflect the conditions of certain settlements and we would be willing to discuss these further with the Council.

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4.23 We recommend that the expansion of the settlement boundary for Capel St. Mary is fully justified by the Council 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 this Core Village. This will support the growth of Capel St. Mary in a manner that is in line with the spatial strategy set out in Policy SP04. Further to this we would support the production of a design guide to ensure high quality design is achieved through each phase of the proposed development.

4.24 The delivery of employment space within the site, represents an ideal location for office space to support communities along the A12 corridor and outside of Ipswich. The proposed scale of development is supported and will enable Capel St. Mary to contribute towards the employment demands of the district.

4.25 Given the above, we would therefore request the Council:

a. Provides additional clarity regarding the cross boundary need, and how Babergh and Mid Suffolk plan to address the unmet need of Ipswich; b. Amend methodology for assessing settlements within the settlement hierarchy; c. Review Capel St Mary’s ability to accommodate further growth (other what has already been allocated in the eLP) to meet the needs of the District later in the eLP period; d. Review LA055 ability to accommodate further growth if point c) indicates it appropriate; e. Amend the sustainability appraisal so that it accurately reflects LA055; and f. Amend LA055 Policy wording as suggested within these representations.

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47.2m

The Orchard Last Won

1

19 5 17 609750.000E Appleton 238250.000NHouse THE OLD STREET Bats Capel Cottage Russell Cottages

THE STREET Middlebit 4 1 11

Pine 1 Trees Driftway

Posts Craig

12 Cottage

2 23

WHITE HORSE ROAD 28 1 Chantry White Horse 16 Glade

Driftway End 21 16 Posts Brimfield 21 15 House 10 1 3

Posts 1 1 1

MOWLANDS New House

4 13

Swakeleys 1 5 El HOMEFIELD

Path (um) 17

LITTLE GULLS 2 Sub Sta

21 8 6

1 Aysgarth 1 18 The

COOMBERS Chestnuts Skene House 18 1 5

1 Acorns LONDON ROAD 5

PLAYFIELD ROAD

11 20 BUSHEY CLOSE 1 1 El

5 10

9 Sub Sta 22

7 22

7 STOCKMERS

1 SMITHERS CLOSE 19

9 Fir Trees

6 17 1 24

13 END 15

REMBROW ROAD 8 Path (um) 4 REMBROW ROAD 2

13 1

16 LONG PERRY

22 1

5 4 CHALKNERS 3

1 15 14 Stoneland

House 7 Kilmorie Lattinford CLOSE

4 2

4 RED SLEEVE 3

SAWYERS CL The Pines Gidan 10 Maigemo

1 Les Viviers

Sandhome 1

3 13

3 7

2 4 LITTLE GROVE 12

11 18 2

3 Tennis Courts 12

10 Hill Crest Development Site Avalon

Garden 26.253ha 10 Centre House 64.873ac 47.9m Playground Mast

FRIARS 8

6 19

The Bungalow 1

Pond 22

Playing Field Hedgerows Garden Centre

LONDONLONDONROMAN ROADROAD ROAD Bowling Green

Track

Pond A12

RED LANE Pond 47.9m

609113.980E 237775.570N

The Gate House Capelgrove

48.5m

Path (um)

A12

Leaping Wells

SCALE 1/2500 0m 25m 50m 75m 100m 125m

Depot

Lay-by 608500.000E CONTRACTORS HEALTH & SAFETY ASSESSMENT 237500.000N SCHEME - ACCREDITED CONTRACTOR

A 12 REVISIONS Client: Job Title: Filling Rev Date ASD - ORIGINAL. 05.03.18 Station PROPOSED DEVELOPMENT LAND: A12 OFF LONDON ROAD, ENGINEERING CAPEL ST MARY, SUFFOLK. Drawing Title: ASD Engineering is part of the ASD Consultants group

ASD Consultants RED LINE PLAN Tel: 01986 872250 Reproduced from Ordnance Survey 16A Bridge Street Fax: 01986 872228 Superplan Data© Crown Copyright 2016 Halesworth DX 51201 Halesworth Ordnance Survey, (c) Crown Copyright 2016. All rights reserved. Licence number 100022432 Suffolk Website: www.ASD-consultants.co.uk Licence No. 100022432 Drawn By: Checked By: IP19 8AQ E-mail: [email protected] For Client For Planning Rev. Scale: 1/2500 (A2) Date: 05 MARCH 2018 Drawing Status: For Comment For Construction Drg No. 1332/LAN/002