Responses to Beccles Neighbourhood Plan Regulation 16 Publicising a Neighbourhood Plan Publicity period: 14 December 2020 to 8 February 2021 Published February 2021 Responses to Beccles Neighbourhood Plan | Regulation 16 | Responses East Suffolk Council ........................................................................................................ 1 Alan Keeley ..................................................................................................................... 3 Alison Woodstock .......................................................................................................... 4 Anglian Water Services Ltd ............................................................................................ 5 Beccles Society ............................................................................................................... 6 Beccles Twinning Association ........................................................................................ 7 Broads Authority ............................................................................................................ 8 Bungay Cherry Tree Angling Club ................................................................................ 12 C Bickmore ................................................................................................................... 19 David Bennett .............................................................................................................. 20 Environment Agency .................................................................................................... 21 Historic England ........................................................................................................... 24 Janet Lloyd ................................................................................................................... 25 Kelvin Allen ................................................................................................................... 26 Larkfleet Homes ........................................................................................................... 27 Marine Management Organisation ............................................................................. 36 Martin Thompson ........................................................................................................ 37 Michael Ellwood ........................................................................................................... 38 Michelle Golding .......................................................................................................... 39 Natural England............................................................................................................ 40 Norfolk County Council ................................................................................................ 41 RSPB ............................................................................................................................. 42 Suffolk County Council ................................................................................................. 44 Suffolk County Council Archaeology ............................................................................ 45 Suffolk Wildlife Trust .................................................................................................... 46 Sustrans ........................................................................................................................ 48 Theatres Trust .............................................................................................................. 49 Waveney Lower Yare & Lothingland Internal Drainage Board .................................... 50 www.eastsuffolk.gov.uk/neighbourhoodplanning Responses to Beccles Neighbourhood Plan | Regulation 16 | What is the purpose of this document? Beccles Town Council submitted their Neighbourhood Plan to East Suffolk Council ahead of it being submitted for independent examination. East Suffolk Council publicised the Plan and invited representations to be forwarded to the examiner for consideration alongside the Plan. This document contains all representations received during the publicity period of 14th December 2020 to 8th February 2021. www.eastsuffolk.gov.uk/neighbourhoodplanning Responses to Beccles Neighbourhood Plan | Regulation 16 | 1 East Suffolk Council A well written plan with very good content. We have some detailed comments to make as set out below. Para 8.1 is a strong introduction to this section, which sets the bar for design quality. The use of two separate policies, one for general design principles and one for the design of streets and public spaces, is a useful distinction. BECC8 A., a. – delete bracket after ‘Waveney Local Plan’. BECC10: General Design Principles Part C of BECC10 could refer back to the Heritage Policy BECC5 for clarity. D. – the requirement to meet the technical standards for Nationally Described Space Standards should be supported with evidence to comply with national planning policy and meet the Basic Conditions. BECC12: Multi-Value Sustainable Drainage Systems, Biodiversity and Flood Risk A. – this part states that it does not apply to householder developments. Is householder development also exempt from the other parts of the policy (parts B-E)? Most parts do not seem to apply easily to householder development. D. - This part of the policy is supporting a sequential approach to layout of development on sites which feature some risk of flooding. This sequential approach is already set out in national planning policy (para. 163 of the NPPF). The general thrust of this part of the policy is supported, but the wording varies from the NPPF and it is not quite clear exactly how both this policy and the NPPF should be applied to development. Given the content of the NPPF, it is perhaps not necessary to include this in the plan. 9 Policies Map This maps on pages 56 and 57 refer to ‘Waveney District’ Planning Authority (which no longer exists), rather than East Suffolk Council Planning Authority. Heritage Comments Previous comments noted that having Heritage as a sub-section in the ‘Community and Tourist Infrastructure and Facilities’ section would not give it the weight that it deserves. Given that the town has such a strong historic character, it should be reconsidered to give www.eastsuffolk.gov.uk/neighbourhoodplanning Responses to Beccles Neighbourhood Plan | Regulation 16 | 2 Heritage a separate section, or to include it in a Built Environment section with Design. The NP is not proposing to add new NDHA’s to the list. It is useful that the wording of 4.30 includes the potential for NDHA’s to be identified outside the Conservation Area. The wording does not reference the ESC NDHA identification criteria or Historic England guidance, which would be useful. Figures 4.1 and 4.2 showing the key designated and non-designated heritage assets are very useful. The section ‘Examples of suitable materials that reflect the local distinctiveness of Beccles’ could be read as a design guide, however in combination with the photographs on the next page it is a useful illustration of some of the historic features that characterise the town. This supports the Policy well. Policy BECC5 is still titled ‘Heritage and Design’. This is somewhat confusing as there is a separate Design section. Keeping the Policy title as is would be an argument for including Heritage in a ‘Built Environment’ section, or perhaps the Heritage section should be titled as ‘Heritage and Design’. Otherwise the policy is well-written. Good use of ‘enhancement of significance’ and ‘local distinctiveness’, and emphasis on the importance of setting and context as well as design and materials. The earlier photographs are a useful evidence base for illustrating what the NP means by local distinctiveness. The inclusion of Community Actions for Heritage is welcomed. This is a pro-active way of promoting continued interest in conservation strategies. Please note these comments are made at Officer level and do not prejudice any future decision made by the Council. www.eastsuffolk.gov.uk/neighbourhoodplanning Responses to Beccles Neighbourhood Plan | Regulation 16 | 3 Alan Keeley Tourist Facilities I'm glad to see that the Quay is recognised as the gateway to the Broads and one of the main tourist attractions for the area as well as a location enjoyed by local people. However I feel that the ambitions for this area falls short. To make this area succeed there is a need to remove the industrial aspect of the location to a more suitable location. The area utilised by Travis Perkins should be part of the tourism area and would be better served as a residential or community area. The added benefit would be to reduce the no of HGV's delivering to Travis Perkins. Trasvis Perkins would be more suited to the Industrial areas of Beccles. Furthermpore, there is a need to create a safe route between the town centre and the Quay. The most popular route, Northgate, has narrow pavements, often blocked by illegally parked vehicles. Numerous busses use this road which is unsuitable for their use, as is the old Beccles Bridge. I would welcome a review of these areas as part of the vision for Beccles Hertage and Design I'm pleased to see that Heritage and Design are key factors in the vision for Beccles. I would welcome some incentive to reinstate the original front boundaries to some of the estrablished roads in Beccles. In particular Station and Denmark road where front boundaries have been replaced