Suffolk Coastal Local Plan Review Issues and Options, August 2017, Public Consultation

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1 Suffolk Coastal Local Plan Review Issues and Options, August 2017, Public Consultation Having reviewed the issues and options documents, the Society has made the following response: Part 1 - Strategic / Cross Boundary Issues for Ipswich Borough Council and Suffolk Coastal District Council Q2: What are the advantages of your area that should be protected through local plans? A high quality historic environment rich in designated and non-designated heritage assets including listed buildings, conservation areas and parks and gardens. The Suffolk Coast and Heaths is an Area of Outstanding Natural Beauty, a nationally designated landscape, and impacts of development on the AONB and its setting should be accorded full weight in the development plan. Q6: Which growth scenario should we plan for across the Ipswich Housing Market Area? SPS believes that the Baseline, Scenario A should be planned for. We believe that to aim for greater economic growth would require a substantial increase in the level of housing that would be undeliverable given the identified constraints on available housing land. Q13: Which distribution options do you think would be most appropriate to take forward? SPS considers that development should be concentrated within Ipswich (Option 5) and an increase in density would be preferable to erosion of countryside edge locations or encroaching into adjoining districts. Failure to concentrate in large urban areas will mean more greenfield sites need to be released which will reduce the viability of regeneration of urban brownfield sites. Q15: Should the spatial distribution of jobs growth align with housing growth or should we take a different approach which focuses on improving accessibility between homes and work places? To be truly sustainable SPS believes that jobs and homes should be proximate to minimise car journeys and safeguard the environment. Q17: Should the policy approach of maintaining the physical separation of villages from Ipswich be continued or should infill in gaps between settlements be considered a source of housing land? SPS would always seek to protect distinctive settlements and sensitive landscapes while recognising that in some instances sustainable locations should be brought forward in preference to encroaching into countryside. Q18: If development cannot be accommodated within Ipswich, should it be focused within the communities close to Ipswich or distributed within the larger Ipswich Housing Market Area? What criteria should guide its location?

2 SPS would always seek to protect distinctive settlements and sensitive landscapes while recognising that in some instances sustainable locations should be brought forward in preference to encroaching into countryside. Q19: Should Ipswich switch employment land to housing use, even though the Borough has a high jobs target? Where should the Council prioritise protecting employment land? Small town centre employment sites which may represent a risk to residential amenity could be released for housing while accessible larger employment sites along the A14/A12 corridors should be protected. SPS believes that Baseline housing and economic growth which could allow surplus employment land to be released for housing. Q20: Is there other land within Ipswich Borough which should be considered for residential development? Is the approach to protecting open space the right one? SPS considers that open space in urban areas is valuable to well-being and residential amenity and should be protected. Part 2 - Local Plan for Suffolk Coastal Rural Housing and Settlement Clusters Q42: Do you consider it appropriate for the Council to consider directing growth to a cluster of villages? Any housing policy must pay due regard to valued landscapes and heritage constraints when selecting growth clusters including impact on sensitive sites: listed buildings, conservation areas and non-designated heritage assets. Physical Limits Boundaries Q54: Should the physical limits boundaries be tightly defined around existing built development or more loosely defined to allow for small scale development in communities? SPS strongly opposes both the loosening of boundaries and the use of criteria based policies on the grounds that boundaries provide certainty especially where development pressure is intense. The loosening of boundaries equates to increased hope value and marginalised land. Furthermore it will result in the expansion of settlements at the expense of the development of vacant/ brownfield sites within current settlement boundaries. Q55: Can criteria based policies more appropriately deal with growth in the rural areas than physical limits boundaries? SPS strongly opposes both the loosening of boundaries and the use of criteria based policies on the grounds that boundaries provide certainty especially where development pressure is intense. The loss of boundaries equates to increased hope value and marginalised land. Furthermore it will result in the expansion of settlements at the expense of the development of vacant/ brownfield sites within current settlement boundaries.

3 Q56: Do all settlements require physical limits boundaries? SPS opposes physical limits boundaries within the countryside Conversion of rural buildings in the countryside Q58: How should the Council consider applications for the re-use of redundant buildings in the countryside? Whilst we support the reuse of traditional redundant farm buildings, it is important that full weight is given to the site s landscape designation in approving development in sensitive sites within the AONB which might result in a loss of tranquillity. Q59: Should the Council introduce a sequential approach to the re-use of redundant buildings with priority given to, for example employment or tourism use? Full weight must be given to the site s landscape designation in approving development in sensitive sites within the AONB which might result in a loss of tranquillity. Tourist Accommodation Q82: Should tourist accommodation be encouraged across the whole district or just in specific areas? Full weight must be given to the site s landscape designation in approving development in sensitive sites within the AONB which might result in a loss of tranquillity. Exceptional circumstances are required to justify major residential development within the AONB. Any such developments should be controlled by legal agreement to prohibit their use as tourist accommodation. High Quality Landscapes Q87: Do we need a different approach to tourism development in the AONB as opposed to areas outside the AONB? Full weight must be given to the site s landscape designation in approving development in sensitive sites within the AONB which might result in a loss of tranquillity. Exceptional circumstances are required to justify major residential development within the AONB. Any such developments should be controlled by legal agreement to prohibit their use as tourist accommodation. Renewable Energy and Sustainable Construction Q116: Should the Local Plan Review identify sites for renewable energy development across the district? Which areas across the district would be appropriate and for which types of technology? Any sites identified for renewable energy development must take into account heritage impacts, landscape constraints and the potential for effective mitigation.

4 Design Q119: How can we improve the design and quality of estate scale development? Use of Design Codes and guides, use of the Suffolk Design Review Panel and strengthening of local plan policy to promote locally distinct design and/or a strong sense of place. Q120: How can we improve design quality through planning policy? Through the production of Supplementary Planning Documents promoting high quality design, better use of Design Codes and guides and use of the Suffolk Design Review Panel. There should be a requirement for development to be locally distinct and/or create a strong sense of place. Q121: How do we promote locally distinctive design? Through the production of Supplementary Planning Documents promoting high quality, locally distinct design, better use of Design Codes and guides and use of the Suffolk Design Review Panel. Q122: Is it possible to secure high quality design which is locally distinctive through factory build development? Yes Q124: Should the principles of Building for Life 12 be used as a tool to improve the design quality of new development? Yes Housing Density Q125: Should local housing densities be set for new developments? Yes these should be dependent upon location urban/suburban/rural Q126: Should different design principles be applied to housing developments at high/low densities? For example, avoid using detached housing at higher densities in order to maintain sufficient space between buildings? Yes the use of terraces rather than detached houses is a more efficient use of space than detached housing, maximising public open space and landscape planting opportunities. Heritage Q129: What should be included in a positive strategy for the protection of heritage assets across the district? The Society recommends that the terminology used closely reflects that of the NPPF and includes reference to the terms significance, substantial and less than substantial harm, and

5 public benefit. We draw your attention to the policy below which the Society considers is a good example: Historic Environment Development that will lead to substantial harm to or total loss of significance of a listed building, conservation area, historic park or garden or important archaeological remains (including development that adversely affects the setting of heritage assets) will only be permitted in exceptional circumstances where the harm or loss is necessary to achieve substantial public benefits that outweigh the harm or loss. Where development will lead to less than substantial harm this harm should be weighed against the public benefits of the proposal. Development affecting the historic environment should seek to conserve and enhance the significance of the heritage asset and any features of specific historic, archaeological, architectural or artistic interest. In all cases there will be an expectation that any new development will enhance the historic environment or better reveal the significance of the heritage asset, in the first instance, unless there are no identifiable opportunities available. In instances where existing features have a negative impact on the historic environment, as identified through character appraisals, the Local Planning Authority will request the removal of the features that undermine the historic environment as part of any proposed development. The Local Planning Authority will request the provision of creative and accessible interpretations of heritage assets impacted by development. Conservation of the historic environment will also be ensured by: (i) Identifying, characterising, protecting and enhancing Conservation Areas; (ii) Protection and enhancement of existing buildings and built areas which do not have Listed Building or Conservation Area status but have a particular local importance or character which it is desirable to keep; (iii) Preserving and enhancing Listed Buildings, Scheduled Monuments, Historic Parks and Gardens, including their respective settings, and other features, which contribute to the heritage of the Borough; and (iv) Sites of archaeological interest will be clearly identified and protected, and sites that become known, whether through formal evaluation as part of a Planning Application or otherwise, will similarly be protected according to their importance. Heritage Statements and/or Archaeological Evaluations will be required for proposals related to or impacting on the setting of heritage assets and/or known or possible archaeological sites, and where there is potential for encountering archaeological sites so that sufficient information is provided to assess the significance of the heritage assets and to assess the impacts of development on historic assets together with any proposed mitigation measures. (Colchester Borough Council Draft Local Plan) Q130: What does the Council need to include in a positive strategy for the protection and enhancement of heritage assets? See answer to Q129 Q131: What level of protection should be given to non-designated heritage assets and locally listed buildings? The appropriate level of protection is set out in NPPF para 135.

6 Landscape Q132: Is a Landscape Character approach to considering the impact of development on the landscape preferable to retaining Special Landscape Areas for this purpose? While we do not object to the landscape character assessment approach, we consider that it efficacy relies upon a robust policy framework. The assessment is only of partial value because it is descriptive and analytical but lacks the weight of criteria based policies to protect the most vulnerable areas. SLAs are a little outdated but can perform well in areas of great development pressure. Q133 Other than those protected as part of the AONB and Heritage Coast, which other sensitive landscapes require special protection? Valued landscapes as defined by NPPF para 109. Q134 Should areas of tranquillity be identified and protected and if so, which areas should be considered? The tranquillity of the AONB should be protected. We refer you to the CPRE Dark Skies Map for areas of relative darkness which should be protected. Potential Land for Development Q143: Which sites do you consider appropriate for future consideration by the Council? SPS does not have available resources to examine and comment on sites listed and mapped. Therefore we reserve the opportunity to comment in more detail on the shortlisted sites at a later plan stage. That said, all sites should be assessed in accordance with their landscape and heritage impact, together with their proportionality to the host settlement. Fiona Cairns MRTPI IHBC Director 24 October 2017