Working Together Babergh Mid Suffolk Joint Local Plan 2018-2037 Pre-Submission Regulation 19 Paper Representations Form Pre-Submission Regulation 19 stage of Babergh Mid Suffolk Joint Local Plan public representations period runs from 12th November 2020 to 24th December 2020 (6 weeks). Regulation 19 - Town and Country Planning (Local Planning) (England) Regulations 2012 Representations must be received no later than 12 noon on 24th December 2020. Online facilities are available to draft and submit comments electronically. Alternatively, please completed this form and return via email: [email protected] or post to Babergh & Mid Suffolk Councils, Planning Policy Team, Endeavour House, 8 Russell Road, Ipswich IP1 2BX. If assistance is required, please contact the Council’s Strategic Planning Policy Team via email address stated above or by telephone on 0300 1234 000 option 5, then 4. This form has two parts: Part A for personal details and Part B for your representation. Please make clear what part of the Joint Local Plan you are responding to and complete a separate form for each representation you wish to make. Please note each representation must be signed and dated. All comments received will be made publicly available and may be identifiable by name / organisation. All other personal information provided will be protected in accordance with the Data Protection Act 2018. Babergh and Mid Suffolk Joint Local Plan Part A Section 1: Personal Details Title: First Name: Last Name: Job Title (where relevant): Organisation (where relevant): PETTAUGH PARISH COUNCIL Address: Postcode: Telephone: Email: Clerk Pettaugh Parish Council <[email protected]> Section 2: Agent Details (if applicable) Please supply the details below of any agent you have working on your behalf. Agent name: Address: Postcode: Telephone number: Email: Pre-Submission (Nov 2020) Paper Representations Form 2 Babergh and Mid Suffolk Joint Local Plan Part B Please fill in a separate form for each representation The Joint Local Plan will be examined by an independent inspector in order to assess whether the plan has been prepared in accordance with the legal and procedural requirements, and whether it is sound. Section 3: Section of Joint Local Plan Name or Organisation: PETTAUGH PARISH COUNCIL Client: (if relevant) To which part of the Joint Local Plan does this representation relate? 68) Pettaugh: Land west of Debenham Way – 10 dwellings Section and Paragraph: Policy SP03- Settlement Hierarchy Policy: Policy SP02 – Affordable Housing Mid Suffolk District Council Place Maps and Policies - Pettaugh Policies Map: Section 4: Legal Compliance & Duty to Cooperate Do you consider the Joint Local Plan is: (tick as appropriate) Yes (Support) No (Object) X 1. Legally and procedurally compliant: (a) Positively prepared X (b) Justified X 2. Sound: (c) Effective X (d) Consistent with national policy X 3. In Compliance with the Duty to Cooperate Pre-Submission (Nov 2020) Paper Representations Form 3 Babergh and Mid Suffolk Joint Local Plan Section 5: Details of Representation If you wish to support or object to the legal compliance or soundness of the Joint Local Plan or with the Duty to Cooperate, please use this box to set out and explain your comments. Please be as precise as possible, and provide a 100 word summary of each point. The arbitrary allocation of greenfield land that has been and is being cultivated and is in active agricultural use for the provision of 10 residential dwellings in a hamlet without any facilities and even basic infrastructure, adjacent to a very busy and dangerous highway junction, not only goes against the fundamental principle of planning, namely sustainable development, but is also improper, unreasonable and irrational. The draft Joint Local Plan does not provide any proper planning related reason for such a change to the settlement boundary and for the loss of best and most versatile agricultural land other than that the site is owned by MSDC and it has expressed an intention to develop it for 10 residential units. It is of utmost importance that the settlement boundary setting exercise does not allow unsustainable locations to be artificially fitted into the village eroding the overarching principle of sustainable development. The current proposal is not consistent with national policy. The proposed ‘safeguards’ in the draft JLP are ineffective and weak. Once a site is allocated according to policy SP03 ‘New allocations are included within the defined settlement boundaries. The principle of development is established within settlement boundaries, subject to the other policies in the Plan.’ The Parish Council notes that this policy wording was originally contained in Local Policy LP01 but has now been elevated to a Strategic Policy confirming its importance and decisive nature. Accordingly, the site allocation process becomes even more important including the scrutiny of the allocation criteria and the evidence base for the proposed allocations. The existing very serious highway issues at the A1120 junction including danger to all highway users, acute drainage problems and the complete lack of even basic local infrastructure in Pettaugh will not be addressed at the time of any planning application as the allocation of the site would carry great weight/become decisive and the constraints overcome by token mitigation measures. The Parish Council respectfully ask the Planning Inspector to carry out a site visit to the village as part of the examination in public/inquiry. The evidence base for the draft JLP is seriously flawed. The SHELAA, site reference SS0706, identifies some constraints such as highway access, footpath and infrastructure and impact on Protected Species. However, it does not identify the existing, not fit for purpose highway layout and its very concerning highway safety implications nor does it include the lack of facilities in the village. The suitability assessment criteria set out in Appendix A to the SHELAA is not consistently applied to the sites and in relation to SS0706 it has been misapplied. The Parish Council considers that the reasons identified for discounting sites equally applies to this site such as poor access to core services and facilities, not being consistent with the settlement pattern and predicted surface water flooding would affect a large proportion of the site The Topic Paper – Settlement Hierarchy Paper is also erroneous. The distance to the core village is over 2km from Pettaugh and the assessment to access to core services should be downgraded accordingly. The Parish Council notes that the draft JLP does not contain a policy, included in many other development plans in the country, requiring public land to deliver a minimum of 50 percent affordable housing. As the main justification for the inclusion of site in Pettaugh is that it is owned by MSDC and it intends to develop it the draft JLP must ensure that public land is used for the provision of much needed affordable housing. Policy SP02 should be amended as follows: Policy SP02 – Affordable Housing 1. A contribution of 35% affordable housing will be required on sites of ten or more dwellings Pre-Submission (Nov 2020) Paper Representations Form 4 Babergh and Mid Suffolk Joint Local Plan or 0.5ha or more or 50% for public sector land on all sites regardless of size. The Parish Council also encloses its original submissions dated September 2019 and they form part of the Parish Council’s current submissions. (Continue on a separate sheet if necessary. Please remember to include on any separate sheets the name/organisation and details of which section, paragraph, policy or element of the policies map your representation relates) Section 6: Proposed Modifications to the Joint Local Plan Please set out what modification(s) you consider necessary to make the Joint Local Plan legally compliant or sound, having regard to the test(s) you have identified above where this relates to soundness. (NB Please note that any non-compliance with the Duty to Cooperate is incapable of modification at examination) You will need to say why this modification will make the Joint Local Pre-Submission (Nov 2020) Paper Representations Form 5 Babergh and Mid Suffolk Joint Local Plan Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Please see section 5 above for details. In summary: removal of the proposed allocation of the site in Pettaugh west of Debenham Way and amendment of draft policy SP02 Affordable Housing (Continue on a separate sheet if necessary. Please remember to include on any separate sheets the name/organisation and details of which section, paragraph, policy or element of the policies map your representation relates) Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested modification, as there will not be a subsequent opportunity to make further representations based on the original representation at publication stage. After the representations period of the Pre submission Babergh and Mid Suffolk Joint Local Plan has closed, further submissions will only be at the request/invitation of the Inspector, based on the matters and issues debated at the examination. Section 7: Participation at the Examination Pre-Submission (Nov 2020) Paper Representations Form 6 Babergh and Mid Suffolk Joint Local Plan If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? (please select one answer with a tick) X Yes, I wish to participate at the oral examination No, I do not wish to participate at the oral examination If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: The Parish Council does not consider that local plan examination is suitable for written representations only.