Babergh & Mid-Suffolk Joint Local Plan: Regulation 18 Consultation Representations - Babergh ...
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Land at Moores Lane
East Bergholt
Babergh & Mid-Suffolk District Council
Babergh & Mid-Suffolk Joint Local Plan: Regulation
18 Consultation Representations
September 2019
Revision Date Description
0.1 23.09.2019 First Draft
0.2 27.09.2019 Second Draft
0.3 27.09.2019 Final for Submission
+44 (0) 7723 916 638Contents
1 Introduction…………………………………………………………………………………………………………………. 3
1.1 Purpose of this Representation………………………………………………………………………………………. 3
1.2 Moore’s Lane Interest…………….………………………………………….…………………………………………. 3
1.3 Sections addressed by this Representation………………………………………………………………. 4
2 Housing Requirements – SP01……. …..……………………………………..…………………………………..… 4
3 Affordable Housing – SP02…..……………………………………………………………………………………….. 4
4 Settlement Hierarchy – SP03………………..……………………………………………………………………….. 5
5 Spatial Distribution – SP04……………………………………………………………………………………………. 5
6 Land North West of Moores Lane – LA060……………………………………………………………………. 5
7 Conclusion……………………………………………………………………………………………………..………………. 6
21. Introduction
1.1 Purpose of this Representation
1.1.1 This representation is submitted in response to the Babergh & Mid-Suffolk Local Plan
Consultation (Regulation 18) and has been prepared by Sphere 25 on behalf of
Countryside Properties.
1.1.2 The purpose of this representation is to positively contribute to the discussion around
the required amendments to the emerging joint Local Plan of Babergh & Mid-Suffolk
District Councils.
1.1.3 These representations are in support of the allocated site at Moores Lane, East Bergholt
with allocation reference LA060.
1.2 Moore’s Lane Interest
1.2.1 Countryside are promoting on behalf of a landowner, land at Moores Lane, East
Bergholt.
1.2.2 An application for part of the site was submitted in May 2015 and received a committee
resolution to approve in both March 2016 and August 2017. Following completion of a
S106 agreement the application was granted permission on the 23rd November 2017.
The description of the application is as follows:
Erection of 144 dwellings including 360sqm of single storey courtyard
development to contain 4 B1 (business) units, public open space, associated
landscaping and infrastructure…
1.2.3 It is anticipated that delivery of this scheme is likely to commence in the first quarter of
2021.
1.2.4 Countryside welcomes the allocation of this part of the site in the emerging Local Plan.
1.2.5 Countryside continues to propose that the settlement boundary should be amended to
include the additional land indicated by the enclosed site location plan, as a suitable
extension for further residential development and a sustainable location for the growth
of East Bergholt. This is further discussed below.
1.3 Sections addressed by this Representation
1.3.1 In view of the above, comments will be provided on the following sections as set out
within the Regulation 18 Consultation Draft:
• Housing Requirements – SP01
• Affordable Housing – SP02
• Settlement Hierarchy – SP03
• Spatial Distribution – SP04
• Land North West of Moores Lane – LA060
32. Housing Requirements – SP01
2.1 Babergh & Mid Suffolk Districts are within the Ipswich Housing Market Area. There
should therefore be an aim, as required by paragraph 60 of the National Planning Policy
Framework (NPPF) for cooperation with Ipswich Council to ensure that the entirety of
the housing market areas need can be met by all of the Council’s Local Plans – i.e.
Babergh, Ipswich, Mid Suffolk and the area of the former Suffolk Coastal District Council
(now included within East Suffolk). Given Ipswich is tightly bound and has fewer
development opportunities careful consideration needs to be given to any unmet
housing need arising during the plan period.
2.2 The Housing Delivery Test 2018 indicates that Babergh & Mid-Suffolk have been
continually failing to meet their housing needs.
Authority HDT: 2018 Measurement HDT: 2018 Consequence
Babergh 88% Action Plan
Mid Suffolk 81% Buffer
Ipswich 66% Buffer
Furthermore, with Ipswich significantly failing to meet its needs there is a requirement
for further assurances within the emerging Local Plan that this shortfall will recover and
will not reoccur during the next plan period for the Ipswich Housing Market Area. The
use of the word ‘minimum’ within Policy SP01 is therefore supported to ensure an
appropriate number of homes can be delivered.
2.3 The commitment within the supporting text to provide for a 20% additional homes
buffer is supported, however without the housing trajectory information it is difficult to
ascertain from the consultation documentation whether a 5 year land supply which
includes an appropriate buffer in accordance with the requirements of paragraph 73 of
NPPF is included at this stage.
3. Affordable Housing – SP02
3.1 It is welcomed that the Councils’ have recognised the need for affordable housing and
have set out a minimum requirement.
3.2 It is also welcomed that there is an understanding within the wording of Policy SP02
that viability can affect the level of affordable housing that can be provided on a
scheme. However, we would suggest an amendment to the Policy that removes the
words “In exceptional circumstances”.
44. Settlement Hierarchy – SP03
4.1 The Settlement Hierarchy policy SP03 is broadly supported as having provided a basis
to designated settlements within the hierarchy which helps to assess appropriate levels
of development for each Settlement.
4.2 The policy identifies East Bergholt as a Core Village which is supported. East Bergholt is
a village that is capable of both supporting and being supported by future development
due to the range of facilities and services.
5 Spatial Distribution – SP04
5.1 The spatial distribution of housing set out which seeks to secure a balance to growth in
the strategic transport corridor areas, as well as ensuring that other market towns and
rural communities benefit from appropriate growth is broadly supported.
5.2 The recognition that Core Villages which include East Bergholt can take significant
growth is welcomed.
5.2 However, it is suggested that assumption for windfall rates should be justified.
6 Land North West of Moores Lane – LA060
6.1 The allocation of the Land north west of Moores Lane, East Bergholt (LA060), is
welcomed and supported.
6.2 East Bergholt has been identified as a Core Village that is readily able to support further
development but would also benefit from development too. Making best use of the
available sites in this village would ensure that housing numbers can be met whilst
delivering sustainable homes.
6.3 It is worth noting that the Settlement Hierarchy Topic Paper (July 2019) produced in
support of the emerging Local Plan scores East Bergholt within the top 35% of Core
Villages with regard to existing services and facilities.
6.4 It is therefore recommended that the surrounding land as indicated within the enclosed
site location plan would be a suitable extension for further residential development and
a sustainable location for further growth within East Bergholt.
6.5 The site is considered to be in a sustainable location for residential development and
has no unsurmountable delivery constraints as proven by planning application
B/15/00673/FUL. Based on an approximate low-end density of 20 dwellings per hectare
(similar to the planning application) the additional site area surrounding the already
approved land can accommodate approximately 220 new dwellings, open space,
associated landscaping and infrastructure. This additional land has the ability to be
incorporated into a sustainable development site that has the benefit of planning
permission rather than an alternative greenfield site elsewhere which would not benefit
from the cumulative development benefits.
56.6 Development of the additional land will provide an excellent sustainable opportunity to
contribute towards the locally identified need for both affordable and market housing.
The site is owned by a single landowner and can be made available immediately for
development (subject to planning processes) as it is being promoted by leading
developer Countryside Properties.
6.7 The entirety of the site was submitted in response to the call for sites in August 2016.
This entire site was given the site reference EBER03 within the Draft Babergh & Mid
Suffolk Joint SHLAA – May 2016 and included the entire 19.9ha of land. It was suggested
that the south-western aspect of the site should be recommended for development.
6.8 The Babergh & Mid Suffolk Joint Local Plan: Consultation Draft included the entire
19.9ha as site reference SS0181. However, there is no further commentary on the
reduction of this area to the 8.80 hectares within the current consultation.
6.9 The Draft SHELAA (July 2019) included just the 8.80 hectares (Reference SS0181) which
form the basis of the site allocation reference LA060. However – it should be noted that
this continues to include the text included within the May 2016 SHLAA which references
the south western aspect of the site. We would request that the Draft SHELAA is
updated to reflect the entire site promoted through the Local Plan.
6.9 Providing additional land within this sustainable location, provides a genuine
opportunity to further provide both infrastructure and social benefits to East Bergholt.
6.10 Countryside has an award-winning track record for place making and creating genuinely
landscape led schemes. It is understood through the published Infrastructure Delivery
Plan that East Bergholt currently has a deficit of amenity green space, and park and
recreation grounds. Through extending the settlement boundary to include some if not
all of the additional land beyond the existing permitted scheme an opportunity arises
to deliver additional community benefits alongside the provision of much needed
market and affordable homes.
7 Conclusion
7.1 Overall, we generally support the emerging Local Plan but believe that the Councils’ will
benefit from ensuring that their housing number requirements are set to the
appropriate levels with enough available land allocated to ensure that there will be a
continued change pattern of housing delivery in the area.
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