Babergh and Mid Suffolk District Council Local Plan Examination Matter Statement 9 Allocation Sites for Housing and Other Development and Settlement Boundaries Response on behalf of Pigeon Investment Management Ltd and their Landowners August 2021 Contents 1. Introduction 1 2. Matter 9 - Allocation Sites for Housing and Other Development and Settlement Boundaries 2 Appendix 1: Response Form to LA002: Land North of Church Lane, Barham 8 Appendix 2: Framework Masterplan for LA001 and LA002 9 Appendix 3: Outline Heritage Appraisal to Inform the Framework Masterplan 10 Appendix 4: Outline Landscape Appraisal to Inform the Framework Masterplan 11 Appendix 5: Response Form for LA001: Land East of Norwich Road, Barham 12 Appendix 6: Response Form for LA012: Land north of Burstall Lane and west of B1113, Sproughton 13 Appendix 7: Outline Landscape Appraisal for LA042: Land at Tye Farm, Great Cornard 14 Appendix 8: Concept Plan for LA042: Land at Tye Farm, Great Cornard 15 Appendix 9: Access Strategy and Network Capacity Review for LA042: Land at Tye Farm, Great Cornard 16 Appendix 10: Response Form for LA042: Land at Tye Farm, Great Cornard 17 Client Pigeon Investment Management Limited Our reference PIGC3025 August 2021 1. Introduction 1.1 This Hearing Statement has been prepared by Turley, on behalf of Pigeon Investment Management Limited (‘Pigeon’) and their Landowners, in respect of a number of land interests within both the Babergh and Mid Suffolk Districts. 1.2 Turley has previously submitted representations in response to the Babergh and Mid Suffolk District Councils’ (BMSDC) Joint Local Plan Consultation Document in August 2017, the Joint Local Plan Preferred Options in July 2019 (Regulation 18) and the Joint Local Plan Pre-Submission in November 2020 (Regulation 19) consultations. 1.3 A number of Pigeon’s sites are now included within the Plan as draft allocations. These are detailed below. Further details regarding the status of the sites and their proposed schemes are included in the representations that Pigeon made to the Regulation 19 Consultation (December 2020): LA042 - Land at Tye Farm, Great Cornard; LA012 - Land north of Burstall Lane and west of B113, Sproughton; LA001 - Land East of Norwich Road, Barham; and, LA002 - Land North of Church Lane, Barham. 1.4 Pigeon continues to support the thrust of the emerging Joint Local Plan, taken as a whole, but advocates a number of positive changes to strengthen the overall soundness and deliverability of the emerging Plan. In particular, the Councils’ housing requirement has increased considerably, therefore in order to significantly boost the supply of housing land and delivery in the two districts and support economic growth, the Plan needs to ensure that it identifies ‘deliverable’ sites, in sustainable locations. 1.5 This must be sufficient to provide a continuous delivery of new housing and employment land over the Plan period where there is an identified need. 1.6 Pigeon has therefore requested the right to participate in the relevant Matter 9 Hearing Session to further articulate the issues raised in this Hearing Statement with regard to the draft site allocations which they have a land interest in. 1 2. Matter 9 - Allocation Sites for Housing and Other Development and Settlement Boundaries 9.1 Are the sites allocated for housing and other development in policies LS01 (1-90) and LA001 – LA119 soundly-based; are the criteria and requirements set out in the relevant policies justified and effective; and is there evidence that the development of the allocations is viable and deliverable in the timescales indicated in the Housing Trajectory set out at Appendix 01 of the plan? 2.1 Pigeon consider that their four site allocations LA001, LA002, LA012 & LA042 are soundly-based and can be justified for inclusion in the emerging draft JLP. Each site allocation within the draft JLP has been assessed through the SHELAA process and tested as part of the spatial strategy through the Sustainability Appraisal (SA). The SHELAA and SA are however only two parts of the evidence base and other factors and evidence, such as site suitability and deliverability, the sustainability and other merits of individual sites and the opportunity to deliver much needed local infrastructure, have also been used to select the sites that best align with the preferred spatial option, acknowledging the different circumstances of each spatial strategy option. 2.2 This is reflected in the allocation of Pigeon’s sites, which bring forward land for new pre- schools and primary schools and land for community hubs to include uses such as health provision, village halls, retail and/or floorspace for small or start-up businesses in highly sustainable locations. 2.3 The remaining elements of question 9.1 are set out below in response to each of these allocations. LA001: Land East of Norwich Road, Barham & LA002: Land North of Church Lane, Barham 2.4 Sites LA001 and LA002 are adjoining parcels of land within the same landownership within the parish of Barham, north-west of Ipswich and positioned in the Ipswich Fringe. 2.5 LA002 has the benefit of a Resolution to Grant Planning Permission, subject to the signing of a S106 and conditions made by Mid Suffolk District Council on 27 January 2021 (ref: 1856/17). In accordance with draft Policy LA002, the hybrid planning application secures delivery of up to 269 new homes including affordable homes together with associated access and spine road including works to Church Lane, land for shop(s)/ community uses, amenity space including an extension to the Church of St Mary’s and St Peter’s grounds and reserved site for Pre-School and two form entry Primary School. The scheme also incorporates PROW improvements, a significant quantity of landscaping and ecological habitat along with new footpaths and cycle ways to link to the existing village of Claydon and local facilities and a highways package of improvements for the village. 2.6 The Site has been marketed by Pigeon in recent months and it has received an extremely positive response, with a number of parties interested in progressing the Site through a 2 Reserved Matters Application and construction. The strong market response to this Site demonstrates that the allocation is viable and a commercially attractive Site to house- builders. 2.7 Given this response and the Resolution to Grant Outline Planning Permission, Pigeon consider that the Site can start to deliver housing completions earlier than indicated in the Housing Trajectory at Appendix 01 of the Plan, which is set at 2027/28. Pigeon consider that the first completions could be expected in 2023 if a Reserved Matters Application is determined in a timely manner. Thereafter, the expected number of completions per year are expected to be nearer to the national average of between 40 - 50 homes per sales outlet per year, rather than 33, so completion of the Site is likely by 2029. 2.8 Whilst Pigeon are supportive of Policy LA002, in order to make the policy effective and in line with national planning policy, Pigeon has previously set out in their Regulation 19 Representations, specific changes to a number of criteria (including the point raised in question 9.5 below) to ensure that there is no ambiguity in the future when the policy is applied by the decision maker. These specific changes are provided at Appendix 1 of this Statement for completeness. 2.9 LA001 is within the same landownership as LA002 and is envisaged to come forward as a coordinated and comprehensive scheme with LA001, which provides a continuity of approach as shown within the Framework Masterplan at Appendix 2 of this Statement. 2.10 To inform the Framework Masterplan, Pigeon sought detailed landscape and heritage advice for LA001. The landscape and heritage appraisals can be found in full at Appendix 3 and 4 of this Statement. These appraisals have demonstrated that whilst the Site does have the ability to accommodate new development, it should ideally be precluded on the eastern parcel of land, nearest the Public Right of Way (PRoW). This is because of glimpsed views between Shrublands Hall and the Church at Barham. Using the ‘north/south’ hedgerow in this part of the Site to frame the glimpsed views which are ideally to be retained reduces the opportunity to bring forward new homes in this area. 2.11 If it is concluded that the glimpsed views are to be maintained, then Pigeon would like to put forward to the Inspectors and the Council the option to realign the northern boundary of LA001. 2.12 The realignment of this boundary (within the same landownership) assists in providing a layout which would be comparable to the illustrative scheme on LA002 and comply with the requirements of Policy LA001. As with the illustrative scheme on LA002, the future layout of LA001 can identify individual areas where new homes will be designed to respond to the characteristics of that part of the Site and its surrounding area. Design Coding, as adopted for LA002, will also be used to assist this process and the delivery of LA001. 2.13 As demonstrated in the Framework Masterplan at Appendix 2, the alternative boundary largely follows the existing LA001 boundary to the north east, using the existing established hedgerow line. To the north-west, the Masterplan proposes a boundary which reflects the existing field patterns to define the extent of the allocation, with a 20m tree belt introduced along the length of the northern boundary. This approach is 3 in keeping with the character of the area and will assimilate the scheme into the local context. The proposed extension to the north-west boundary has been identified as suitable, given the land is situated on lower ground and adjacent to Norwich Road, where landscape and heritage effects are limited.