14 September 2018
Suffolk Coastal First Draft Local Plan, September 2018, Public Consultation
Having reviewed the final draft local plan policy documents, the Society has the following comments on the Site Specific Allocations and District Wide Strategic Planning Policies. These follow on from our response to the Issues and Options consultation in 2017.
Site Specific Allocations:
The Society has restricted its comments to sites which were not allocated in the Site Allocations and Area Specific Policies Development Plan (adopted January 2017). We have registered our objections and/ or comments on the following sites:
SCLP12.26 – South Saxmundham Garden Neighbourhood – Although Saxmundham is a sustainable location with scope to accommodate a degree of new housing with the required supporting infrastructure, the Society is concerned that the proposed development site is too large and will have detrimental impact on the landscape and heritage of the town. The landscape to the south of the town is undulating and we consider that a smaller development to the west of the railway line would be better contained within the landscape, would have a more limited impact on the historic landscape and heritage of the town and would be better related to the more recent development of the existing settlement.
We note that a masterplan approach to the development is to be followed, and the policy includes a list of issues which should inform the masterplan. However whilst we note an intention in para 12.209 to avoid coalescence of Saxmundham with Benhall Policy SCLP12.26 does not include this as a firm requirement of the development. In this regard it is of particular concern that the southern boundary of the site is currently undefined. The requirement for Saxmundham and Benhall to remain separate distinct settlements should be included within the policy, and we do not consider that a planted visual buffer will satisfactorily achieve this objective.
Furthermore, although also mentioned in the supporting text the policy should reference the Saxmundham Conservation Area immediately to the north of the site and the setting of Hurts Hall. These are both important issues which should inform the masterplan. The conservation area currently forms the gateway entrance to the town from the south which will be entirely altered by development of the land to the west of the B1121 and therefore would require particularly sensitive design. Hurts Hall lies prominently in parkland to the east of the B1121 which together with the agricultural land to the west of the B1121, characterises the historic landscape to the south of the Saxmundham. Policy SCLP12.26 should reflect an objective to limit the impact of new housing in Saxmundham on this sensitive landscape and the setting of Hurts Hall by restricting development to a smaller site to the west of the railway line, perhaps in conjunction with further sites in the town.
SCLP12.40 – Brandeston – This is a prominent gateway site which abuts the conservation area and therefore requires careful design which reflects the scale and density of the existing village. We would suggest that a development of significantly fewer than 30 dwellings could be supported and would be more appropriate.
SCLP12.42 – Campsea Ashe – The Society considers that this site for 12 dwellings is an important area of open space which currently provides a visual gap between the main village, to the West of the railway line, and the distinct cluster of historic buildings which includes the adjacent listed Old Rectory and St John the Baptist Church. Development of this site will bring this distinct cluster into the main settlement, altering its character as a rural hamlet, and should therefore be avoided.
SCLP12.43 - Charsfield – this site for approximately 20 houses to the north of a separate site which has planning permission appears to be well linked both to the recreation ground and through the new development to the rest of the village. We note that it is not a logical extension to the built up area of the village being bounded on three sides by agricultural land. Furthermore whilst existing hedges and trees will provide a degree of screening from close range, the site is on raised ground and may be prominent in longer views, we therefore welcome the reference to the setting of the grade I listed St Peter’s Church in the policy.
SCLP12.48 – Grundisburgh - the Society objects to the proposed site for 56 dwellings which is adjacent to another site for 24 houses (completed) in addition to a new village hall (yet to be constructed). The proposed site is more prominent as it is on rising ground. The development of this site would introduce a damaging urbanised character to the landscape and would be highly visible and overbearing on entering the village from the south and in long views from the village. The approach to the village from the south is characterised by treed screening of Grundisburgh Hall Park and Garden (SCDC registered) to the east and open far reaching views across agricultural land to the west. We consider that further encroachment of development into this landscape will be highly damaging.
SCLP12.54 - Otley – the Society considers that this site for 20 dwellings does not relate well to the existing village. The built up area is to the south and is characterised by a single plot linear pattern of individual houses in large plots to the west of Helmingham Road which ends at Ipswich Road. Listed Otley House and garden lie to the east. Ipswich Road therefore forms the natural edge of the built up area of the village and development beyond this will extend the village into the countryside and should be avoided.
District Wide Strategic Planning Policies:
SCLP11.5 – Conservation Areas – the policy should be amended to specify that it applies to development within a conservation area or its setting. The Society also considers that the supporting text should set out a requirement for applications for outline planning permission within a conservation area or its setting to provide sufficient detail to fully consider the effects of the proposal on the conservation area.
Enabling Development –paras. 3.67 to 3.69 set out the council’s stance with regard ‘enabling development’ whereby an exception to planning policy is permitted in order to allow for development that will provide sufficient public benefit such as retaining a heritage asset, enhancement of sports facilities, coastal defences and flood adaptation measures. We object to this definition of enabling development as it is not supported within the National Planning Policy Framework which defines enabling development solely in terms of its benefit to heritage assets and does not extend to other public benefits (paras 79 and 202).
If the council continues to pursue a wider definition of enabling development, we consider the granting of planning permission contrary to policy should be ‘wholly exceptional’ and there should be a requirement to clearly demonstrate that the public benefits are necessary, supported by the local community and could not be achieved through alternative means.
Policy SCLP5.11: Affordable Housing on Exception Sites – the Society supports the exception site policy but the policy wording should make clear the identified local need is for the host settlement and not a wider need.
Policy SCLP11.1: Design Quality – the Society considers that the council should be positively encouraging increased engagement between developers and the Suffolk Design Review Panel where appropriate. The local plan should reflect this objective.
Policy SCLP10.3 Landscape Character –the policy gives AONB landscapes the same policy status as locally sensitive landscapes of rural river valleys, historic park and gardens, coastal, estuary and heathland. This is contrary to NPPF para 171 which requires local plan to distinguish between the hierarchy of international, national and local designations. This is a failure to acknowledge the national importance of AONBs and the policy should specifically refer to paras 171 and 172 of the NPPF. These specify that great weight should be given to conserving the landscape and scenic beauty of AONBs, the scale and extent within these designated areas should be limitedand major development should only be permitted in exceptional circumstances (para 172).
Phrases such as ‘will be expected’, ‘where possible’ and ‘should’ lack rigour. Also the policy states that only developments with less than a significant adverse impact will be allowed. However a significant adverse impact is a very high degree of harm on the spectrum of landscape harm. Most developments will be in the area of less than a significant adverse impact and the policy must require these applications (other than minors) to be accompanied by comprehensive landscape appraisals, LVIA and landscape mitigation schemes.
Policy SCLP11.3: Historic Environment – para 11.19 of the supporting text to the policy states that the Council intends to pursue a policy approach that incorporates a positive strategy for the protection and enhancement of the District’s heritage assets in line with NPPF para 185. However policy SCLP11.3 falls well short of the definition of a positive strategy as set out in NPPG para 004 (reference id 18a-004-20140306) which states that Such as a strategy should recognise that conservation is not a passive exercise. In developing their strategy, local planning authorities should identify specific opportunities within their area for the conservation and enhancement of heritage assets. This could include, where appropriate, the delivery of development within their settings that will make a positive contribution to, or better reveal the significance of, the heritage asset. The delivery of the strategy may require the development of specific policies, for example, in relation to use of buildings and design of new development and infrastructure. Local planning authorities should consider the relationship and impact of other policies on the delivery of the strategy for conservation. NPPF para 185 explains that a positive strategy for the conservation and enjoyment of the historic environment should include heritage assets most at risk through neglect, decay or other threats. The strategy should take into account: a) the desirability of sustaining and enhancing the significance of heritage assets, and putting them to viable uses consistent with their conservation; b) the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; c) the desirability of new development making a positive contribution to local character and distinctiveness; and d) opportunities to draw on the contribution made by the historic environment to the character of a place.
Policy SCLP11.3 currently lacks both detail and rigour, fails the NPPF requirement to set out a “positive” strategy, and should be amended accordingly. Furthermore it is poorly drafted, using the phrase "to conserve and enhance the historic environment” twice in the same sentence.