Comment from Mr C Fletcher – 18/01/19

I would like to make two constructive points about the NP and place them on the public record as follows:

1.       I know that it might be ‘desirable’ to retain commercial premises operated by businesses within the village, and especially along the High Street but I do believe that the issue of ‘change of use’ needs to be carefully studied so as not to be detrimental in the future. On the one hand, of course we want to keep the village commercially vibrant and active, but on the other, business owners are finding things incredibly difficult at the moment especially in retail and more so where business rates are being levied.

For property owners that are unable to continue running a business viably, and who may then face difficulties selling the same premises, either as a commercial property or mixed commercial/residential property because of the ‘change of the times’ scenario facing the High Street, burdening the property owner with additional future restrictions will prove very unhelpful.

By imposing restrictions on property ‘change of use’ and incorporating it into a NP seems to me to be incredibly short-sighted. The likelihood is, if the current shopping trends continue, and other villages follow suit, that we could face a situation where many prominent High Street premises remain empty and are unable to be sold and the country will therefore be blighted with empty High Street shops, which is far away from what you are actually wanting to achieve.

Furthermore, property owners often use proceeds from property sales to help them move into retirement. Your proposed NP is likely to cause, in some cases, incredible distress to people unable to realise either a reasonable price for their property or indeed a sale at all. Potentially, I foresee it could lead to litigation on the basis of unfairness.

I would urge the committee to think carefully about how the village can remain commercially vibrant and attractive without alienating business property owners or indeed causing them the prospect of future financial hardship and possible deprivation.

2.       The entrance to Orchard Brook via the Cock and Bell has been a talking point by residents for a very long time. I would like to raise the issue that there are no restrictions to parking ‘in and around the area’, either in the actual through way/road beside the pub or the entrances on either side. Surely, at the very least there should be yellow lines in place? I know that a very small minority of people (one in particular) actually regularly parks his car in the ‘through way’ whilst they sit and booze in the pub. I wonder how they are allowed to get away with it? Ignorance and Idiocy on the part of individuals is one thing, but that is why rules, laws and restrictions are made and imposed in the first place, to make people comply. So who is reckless enough to allow this to continue? Who is waiting for a child, an elderly person or anyone else for that matter to be injured or worse still killed in this dangerous spot? Is it not culpable on the part of those people that passed the entrance as ‘fit for purpose’,  to allow idiotic people to park where  they do without ensuring that sensible parking restrictions were put in place? The subject of proper and adequate parking restrictions, in my opinion, needs rectifying urgently and I would have thought could be included in any NP.

Colin Fletcher – 18th January 2019


Comment from West Suffolk CCG – 18/01/19

Dear Clerk of Long Melford Parish Council

Thank you for communicating with West Suffolk Clinical Commissioning Group (CCG) regarding the Long Melford Parish Council’s proposal to create a Neighbourhood Plan (NP). The CCG is encouraged by the amount of research that has gone into the healthcare assessment in the NP and that clear issues have been identified. The CCG and NHS England understand the issues around obtaining an appointment and will work with the practice to alleviate those issues. It is also refreshing to see that the practice identifies that lack of space is not the issue but recruiting enough staff to meet the demand and I can assure you that the CCG is working to recruit more GPs.

The CCG recognises that between 250 and 350 dwellings are proposed in the NP and mitigation might be sought through a Community Infrastructure Levy (CIL) from developments in the Parish to help the Surgery cope with increased demand from development.

The Neighbourhood Plan provides for up to 350 dwellings in the parish. West Suffolk CCG would like to make the Parish Council aware that smaller developments make it more difficult to gain mitigation through CIL or Section 106 for healthcare than larger developments done in one go. The number of residents will result in a significant increase of patients on the Long Melford Surgery (and its branch practice in Lavenham) patient list and options might need to be looked at to mitigate against the impact. Suffolk CCG would welcome the opportunity to discuss with the Parish Council potential solutions to ensure sustainable Primary Care services for the local community going forward.

If you have any queries or require further information, please do not hesitate to contact me.

West Suffolk Clinical Commissioning Group – 18th January 2019

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Comment from Highways England – 23/01/19

Thank you for your consultation. The following consultation has no severe impact on the strategic road network. We therefore offer no comments in this instance

Yours faithfully

Connor Adkins (Highways England)

Highways England – 23rd January 2019

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Comment from Natural England – 23/01/19

Natural England does not have any specific comments on this draft neighbourhood plan.

Yours sincerely

David Allinton (Consultations Team)

Natural England – 23rd January 2019

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Comment from Sport England – 23/01/2019

Thank you for consulting Sport England on the above neighbourhood plan.

Government planning policy, within the National Planning Policy Framework (NPPF), identifies how the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Encouraging communities to become more physically active through walking, cycling, informal recreation and formal sport plays an important part in this process. Providing enough sports facilities of the right quality and type in the right places is vital to achieving this aim. This means that positive planning for sport, protection from the unnecessary loss of sports facilities, along with an integrated approach to providing new housing and employment land with community facilities is important.

It is essential therefore that the neighbourhood plan reflects and complies with national planning policy for sport as set out in the NPPF with particular reference to Pars 96 and 97. It is also important to be aware of Sport England’s statutory consultee role in protecting playing fields and the presumption against the loss of playing field land. Sport England’s playing fields policy is set out in our Playing Fields Policy and Guidance document.

http://www.sportengland.org/playingfieldspolicy

Sport England provides guidance on developing planning policy for sport and further information can be found via the link below. Vital to the development and implementation of planning policy is the evidence base on which it is founded.

http://www.sportengland.org/facilitiesplanning/planning-for-sport/forward-planning/

Sport England works with local authorities to ensure their Local Plan is underpinned by robust and up to date evidence. In line with Par 97 of the NPPF, this takes the form of assessments of need and strategies for indoor and outdoor sports facilities. A neighbourhood planning body should look to see if the relevant local authority has prepared a playing pitch strategy or other indoor/outdoor sports facility strategy. If it has then this could provide useful evidence for the neighbourhood plan and save the neighbourhood planning body time and resources gathering their own evidence. It is important that a neighbourhood plan reflects the recommendations and actions set out in any such strategies, including those which may specifically relate to the neighbourhood area, and that any local investment opportunities, such as the Community Infrastructure Levy, are utilised to support their delivery.

Where such evidence does not already exist then relevant planning policies in a neighbourhood plan should be based on a proportionate assessment of the need for sporting provision in its area.

Developed in consultation with the local sporting and wider community any assessment should be used to provide key recommendations and deliverable actions. These should set out what provision is required to ensure the current and future needs of the community for sport can be met and, in turn, be able to support the development and implementation of planning policies. Sport England’s guidance on assessing needs may help with such work.

http://www.sportengland.org/planningtoolsandguidance

If new or improved sports facilities are proposed Sport England recommend you ensure they are fit for purpose and designed in accordance with our design guidance notes.

http://www.sportengland.org/facilities-planning/tools-guidance/design-and-cost-guidance/

Any new housing developments will generate additional demand for sport. If existing sports facilities do not have the capacity to absorb the additional demand, then planning policies should look to ensure that new sports facilities, or improvements to existing sports facilities, are secured and delivered. Proposed actions to meet the demand should accord with any approved local plan or neighbourhood plan policy for social infrastructure, along with priorities resulting from any assessment of need, or set out in any playing pitch or other indoor and/or outdoor sports facility strategy that the local authority has in place.

In line with the Government’s NPPF (including Section 8) and its Planning Practice Guidance (Health and wellbeing section), links below, consideration should also be given to how any new development, especially for new housing, will provide opportunities for people to lead healthy lifestyles and create healthy communities. Sport England’s Active Design guidance can be used to help with this when developing planning policies and developing or assessing individual proposals.

Active Design, which includes a model planning policy, provides ten principles to help ensure the design and layout of development encourages and promotes participation in sport and physical activity. The guidance, and its accompanying checklist, could also be used at the evidence gathering stage of developing a neighbourhood plan to help undertake an assessment of how the design and layout of the area currently enables people to lead active lifestyles and what could be improved.

NPPF Section 8:

https://www.gov.uk/guidance/national-planning-policy-framework/8-promoting-healthy-communities

PPG Health and wellbeing section:

https://www.gov.uk/guidance/health-and-wellbeing

Sport England’s Active Design Guidance:

https://www.sportengland.org/activedesign

(Please note: this response relates to Sport England’s planning function only. It is not associated with our funding role or any grant application/award that may relate to the site.)

If you need any further advice, please do not hesitate to contact Sport England

Sport England – 23/01/19

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Comment from Mr and Mrs Stafferton – 05/02/19

We wish to submit the following comments on the Draft Neighbourhood Plan:

There is a serious omission from Chapter 4, which is intended to give valuable background information and help influence decision making on future housing developments.

There is an additional major housing development which is currently missing from the overview of specific existing and planned housing developments in and around Long Melford. This needs to be taken into account in the final Plan.

A Scottish Development Company is proposing to build 122 homes on Stafford Park in Liston CO10 7HU, the former Bush Boake factory.The site straddles the boundaries of Suffolk and Essex. The proposed housing development will be a satellite for Suffolk, with a direct and significant impact on Long Melford, creating additional demand for school places, GP services and other facilities. There will also be a considerable increase in traffic, and Suffolk Highways have identified severe consequences for capacity and safety along Liston Lane, Long Melford, and the junctions of Little St Marys and Liston Lane and St Catherines Road.

Babergh District Council has delegated the planning decision to Braintree District Council, but is supporting the application, despite serious concerns and objections from Long Melford Parish Council, Suffolk Highways and other local organisations and residents. The planning process is at an advanced stage and it is likely that the planning application will be considered by Braintree District Council in the near future. Even if refused, it is likely that it would be challenged by the Developer, similar to the Skylarks bid.

Given the scale of the proposed development and it’s serious impact on the resources and character of Long Melford, Stafford Park should be included in the final Neighbourhood Plan.

Sue and Pete Stafferton

05/02/19

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Comment from Alpheton Parish Council – 06/02/19
 

Alpheton Parish Council met on the 5 February 2019.

The Long Melford draft Neighbourhood Plan (3) had been circulated to Cllrs ahead of that meeting.

Alpheton Parish Council have no objection to the Plan.

Yours sincerely,

Nicola Smith

Parish Clerk

Alpheton Parish Council

06/02/19

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Comment from Highways England 11/02/19
 

Dear Sir,

Long Melford Neighbourhood Plan consultation

Thank you for your consultation.

We welcome the fact that the promotion of sustainable development, provision of facilities and services and sustainable transport is promoted in your plan despite the challenges thrown up by the rural nature of your village.

The proposed level of development is modest and some what remote from the strategic road network. The traffic impact of the proposed development is picked up in, Babergh and mid Suffolk and the surrounding districts local plans and therefore should be within their evidence base and if necessary any adverse impact suitably mitigated

Yours faithfully

Mark Norman

Assistant Asset Manager Operations (East)

Highways England

11/02/19

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Comment from National Grid –  14/02/19
 

National Grid has appointed Wood to review and respond to development plan consultations on its behalf. We are instructed by our client to submit the following representation with regards to the above Neighbourhood Plan consultation.

About National Grid

National Grid owns and operates the high voltage electricity transmission system in England and Wales and operate the Scottish high voltage transmission system. National Grid also owns and operates the gas transmission system. In the UK, gas leaves the transmission system and enters the distribution networks at high pressure. It is then transported through a number of reducing pressure tiers until it is finally delivered to our customer. National Grid own four of the UK’s gas distribution networks and transport gas to 11 million homes, schools and businesses through 81,000 miles of gas pipelines within North West, East of England, West Midlands and North London.

To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect our assets.

Assets in your area

National Grid has identified the following high-pressure gas transmission pipeline as falling within theNeighbourhood area boundary:

                       •FM05 – Stowmarket to Braintree

From the consultation information provided, the above gas transmission pipeline does not interact with any of the proposed development sites.
 
Gas Distribution – Low / Medium Pressure

Whilst there are no implications for National Grid Gas Distribution’s Intermediate / High Pressure apparatus, there may however be Low Pressure (LP) / Medium Pressure (MP) Gas Distribution pipes present within proposed development sites. If further information is required in relation to the Gas Distribution network, please contact plantprotection@cadentgas.com

Electricity distribution

Information regarding the distribution network can be found at: www.energynetworks.org.uk

Key resources / contacts

National Grid has provided information in relation to electricity and transmission assets via the following internet link:

http://www2.nationalgrid.com/uk/services/land-and-development/planning-authority/shape-files/

Please remember to consult National Grid on any Neighbourhood Plan Documents or site-specific proposals that could affect our infrastructure. We would be grateful if you could add our details shown below to your consultationdatabase:

 

Lucy Bartley, Consultant Town Planner, Wood E&I Solutions UK Ltd, Gables House, Kenilworth Road, Leamington Spa, Warwickshire CV32 6JX

 

Spencer Jefferies, Development Liaison Officer, National Grid, National Grid House, Warwick Technology Park, Gallows Hill, Warwick CV34 6DA

n.grid@woodplc.com

box.landandacquisitions@nationalgrid.com

National Grid – 14/02/2019

________________________________________________________________________

Comment 1 from Rose Builders – 20/02/19

Dear Long Melford Parish Council,

I would like to submit this email in support of the allocation of land for residential development at Cordell Road (r/o the Bull PH, site A1). The redevelopment of this brownfield site is an opportunity to deliver a small number of homes in the centre of Long Melford and tidy up this redundant site. The site is clearly in a sustainable location with access to local services in Long Melford as well as access to nearby towns and villages via local bus routes.

Any plans would need to respect the amenity of nearby properties and the character and appearance of the conservation area in which it sits. Nevertheless, an innovative design could be produced for a small number of new homes. Given that the site scores well in this draft of the Neighbourhood Plan, it is recognised that the site has potential. Accordingly, its continued support through the LMNP will help to deliver these benefits.

Kind regards,

Will Vote

Rose Builders, Riverside House, Riverside Avenue, East Lawford, Essex CO11 1US

20/02/19 – Will Vote, Rose Builders

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Comment 2 from Rose Builders – 20/02/19

Dear Long Melford Parish Council,

I would like to submit this email in support of the allocation of land for residential development at Cordell Road (site L1). Constraints such as existing residential amenity and respecting the character and appearance of the Long Melford Conservation Area will need to be addressed. However, for a central site, this land is of a reasonable size and could accommodate a small number of new homes. These homes would be able to benefit from the full range of services and facilities available in Long Melford and close proximity to existing bus routes will enable future residents to access other nearby towns and villages by sustainable means. The redevelopment of this brownfield site will allow the improvement of a site that currently slightly undermines the conservation area, for something more appropriate. These benefits support the notion that this site should continue to be promoted through the LMNP.

Kind regards,

Will Vote

Rose Builders, Riverside House, Riverside Avenue, East Lawford, Essex CO11 1US

20/02/19 – Will Vote, Rose Builders

________________________________________________________________________

Comment 3 from Rose Builders – 20/02/19

Dear Long Melford Parish Council,

I would like to submit this email in support of the allocation of land for residential development at Land East of Rodbridge Hill (Policy LM-H7, site F1). The site is well located in relation to the services that Long Melford provides and by its location along a bus route, would be able to make the most of sustainable modes of transport.

The shape and size of the site is advantageous and would give a degree of flexibility on layout design. Accordingly, the site appears to have relatively few physical constraints to development and it is likely that the existing front hedge could remain largely intact, except for where a new access could be gained from Rodbridge Hill.

Given the obvious positives that the site offers, it is likely that the site could brought forward for redevelopment relatively early in the plan period.

Kind regards,

Will Vote

Rose Builders, Riverside House, Riverside Avenue, East Lawford, Essex CO11 1US

20/02/19 – Will Vote, Rose Builders

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Comment from Mr D Watson – 21/02/2019

This is an excellent plan.

As a long-term resident of Long Melford, I am very pleased to see its positive and constructive tone and agree with its conclusions.

Don Watson

21/02/2019 – Don Watson

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Comment from Anglian Water Services Ltd – 27/02/2019

Dear Sir/Madam

Thank for the opportunity to comment on the Long Melford Neighbourhood Plan. The following comments are submitted on behalf of Anglian Water.

I would be grateful if you could confirm that you have received this response.

Policy LM-H3, Allocation of Sites for Development: L1, Cordell Road

There is an existing foul sewer in Anglian Water’s ownership which crosses part of the proposed site. It is thereforeproposed that the following wording is included in the Neighbourhood Plan:

Policy LM-H3 –‘There is an existing sewer in Anglian Water’s ownership within the boundary of the site and the site layout should be designed to take this into account.’

Supporting text– ‘This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing sewer should be located in highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing asset may be required.’

Policy LM-H4, Allocation of Sites for Development: A1, Cordell Road, adjacent to rear of Bull Hotel

There is an existing foul sewer in Anglian Water’s ownership which crosses part of the proposed site. It is therefore proposed that the following wording is included in the Neighbourhood Plan:

Policy LM-H4– ‘There is an existing sewer in Anglian Water’s ownership within the boundary of the site and the site layout should be designed to take this into account.’

Supporting text– ‘This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing sewer should be located in highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing asset may be required.’

Policy LM-H6, Allocation of Sites for Development: K1,

Land west of High Street

There is an existing foul sewer and water main in Anglian Water’s ownership which cross the proposed site. It is thereforeproposed that the following wording is included in the Neighbourhood Plan:

Policy LM – H6 – ‘There is an existing sewer and water main in Anglian Water’s ownership within the boundary of the site and the site layout should be designed to take this into account.’

Supporting text – ‘This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing sewer and water main should be located in highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing assets may be required.’

Policy LM- H7, Allocation of Sites for Development: F1, Land west of Rodbridge Hill and opposite Ropers Lane

There is an existing foul sewer in Anglian Water’s ownership which cross the proposed site. It is therefore proposed that the following wording is included in the Neighbourhood Plan:

Policy LM -H7 – ‘There is an existing sewer and water main in Anglian Water’s ownership within the boundary of the site and the site layout should be designed to take this into account.’

Supporting text – ‘This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing sewer should be located in highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing asset may be required.’

Housing and employment development

It is noted that the Neighbourhood Plan includes a number of allocation sites for both residential and commercial development and the criteria to be applied to planning applications for residential development. Consideration should be given to including further criteria relating to both foul and surface water drainage infrastructure including the provision of Sustainable Drainage Systems as the preferred method of surface water disposal in the Parish. As the Development Plan is intended to be read as a whole any additional text should be considered in the context of theadopted and emerging Babergh Local Plan.

Where there is a relevant policy or policies included in the Local Plan which covers the issues we don’t consider it necessary to duplicate any requirements in the Neighbourhood Plan.

Should you have any queries relating to this response please let me know

.Regards,

Stewart Patience

Spatial Planning Manager

Anglian Water Services Limited

Mobile:

07764989051

27/02/19 – Anglian Water 

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Comment from Historic England – 27/02/19

Thank you for your correspondence dated 17 January 2019 inviting Historic England to comment on the Regulation 14 Pre-Submission Draft of the Long Melford Neighbourhood Plan.

We welcome the production of this neighbourhood plan, and are pleased to see that it considers the built and historic environments of Long Melford, and welcome the regard the plan has to the Babergh Heritage Assessment undertaken by Place Services Ltd. We note that the plan allocates a number of sites for development, some of which are in the conservation area and in the vicinity of other designated heritage assets. As you make reference to throughout your plan, Long Melford is a place of the highest levels of historic environment sensitivity. We therefore consider that it is likely that your neighbourhood plan will need to be screened for the necessity of undertaking a Strategic Environmental Assessment (SEA). We recommend contacting Babergh District Council regarding this, if you have not already.

We regret that we are unable to provide further detailed comments at this time. We would refer you to our detailed guidance on successfully incorporating historic environment considerations into your neighbourhood plan, which can be found here:

<https://historicengland.org.uk/advice/planning/plan-making/improve-your-neighbourhood/>.

To avoid any doubt, this letter does not reflect our obligation to provide further advice on or, potentially, object to specific proposals which may subsequently arise as a result of the proposed plan, where we consider these would have an adverse effect on the historic environment.

Please do contact me, either via email or the number above, if you have any queries.

Yours sincerely,

Edward James

Historic Places Advisor, East of England

Historic England – 27/02/19

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Comment from Mr W Hyde Parker – 27/02/19 

Dear Sirs

Firstly, I would like to congratulate you on a very thorough document, it is clear that you have spent a great deal of time on the document, our main concern is in regard to your policy LM-H11–Whilst this is a good policy it slightly concerns us as currently there are very few sites that will accommodate affordable housing. We are aware that site K1 with the capacity of 30 dwellings is 100% affordable, but this is not agreat deal of social housing for a village of this size over the length of time that this Local Plan is due to be in place for. We hope that the village are aware that these smaller sites throughout the village will not include any social or affordable housing in line with your policy.

Another one of our concerns is that the site K1 is not blind tenure, meaning that all these social houses are in one area of the village not creating equality within the village, instead isolating those social houses to one end of the village, and on a site that is strategically furthest from the centre of the village.

We hope that you consider our points moving forward

Yours Sincerely

William Hyde Parker

W Hyde Parker – 27/02/19

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Comment from Melford Hall Estates/Hill Group- 28/02/19

The Neighbourhood Plan (NP) needs to accord with the strategic policies of the adopted Development Plan for the District. Policy CS2 of the Core Strategy (2014) identifies a settlement hierarchy with development to be directed sequentially to the most sustainable locations. At the top of the hierarchy are the towns and urban areas:

Sudbury and Great Cornard

Hadleigh

Ipswich Fringe

Next in the sequence, the next most sustainable locations for development, are the Core Villages. Long Melford is identified as a Core Village with a functional cluster of 10 smaller settlements in respect of which it acts as the focus for development. Policy CS11 and its supporting text sets out the approach that should be taken to identify an appropriate quantum of development for each of the villages. This includes an assessment of physical capacity with reference to environmental and heritage constraints, together with an assessment of local need. However, para. 2.8.5.4 cautions against dividing the identified housing requirement ‘. . .equally or randomly between the number of villages listed’.

This appears to be the approach adopted by the NP with reference to housing requirements. The identified housing need for the District has simply been disaggregated on the basis of Long Melford’s existing share of the population (4.01%). No regard has been had to the village’s position in the settlement hierarchy and the role it plays in the wider functional cluster of settlements.

The approach to housing need appears to be driven by what it is perceived the existing local population is prepared to tolerate, rather than an objective assessment of need and what is required to sustain the village in the longer-term. The approach to affordable housing is, at best, opaque and doesn’t address identified need.

The draft NP refers to the findings of a 2018 housing needs survey, undertaken by Community Action Suffolk, which identifies a need for 195 additional households among current households and non residents with a connection who want to return to Long Melford. The document has not been included as part of the NP evidence base and, as a consequence, it is unclear what this number represents. Is it the total locally generated need, or does it represent the need for affordable housing? There is also no timeframe associated with this need. Is it the current unmet need, or is it the need predicted over the NP period?

Whatever the 195 relates to, it is clear that the NP as currently drafted would not serve to address the NP’s own objective assessment of need. The six housing allocations identified would deliver an estimated 85 dwellings, of which only 47 would be affordable. Of these sites, the NP suggests that three may be considered to be in employment use and would therefore need to demonstrate that they were no longer required for that use. If unsuccessful, the housing allocations would be reduced to 61 (41 affordable), using the NP’s assumptions of capacity.

The evidence underpinning the NP appear to have had only a selective bearing on the NP strategy. Significantly, the evidence identifies an ageing population in the village. The proportion of those over 65 (26.8%) is significantly higher than elsewhere in Babergh (21.4%) or England (16.3%). The same is true of over-65 single occupant households. Despite identifying this, the NP provides no analysis of what this means for housing requirements in the village, the potential impact on supply and/or the need for specialist forms of housing.

The assessment of potential locations promoted as part of the call for sites exercise, appears to have been overly simplistic, failed to take account of Long Melford’s specific characteristics and was overly-reliant on untested analysis set out in Essex County Council’s Settlement Sensitivity Assessment. The latter document, doesn’t consider any part of the village further norththan Melford Hall.

Throughout the plan, reference is made to the importance of employment and commercial uses in the village. Despite this, the plan does little to address ongoing need or demand for additional space to maintain the economy of the village.

Tourism is addressed in a similarly dismissive manner. No connection is made between the desire to maintain economic activity and vibrancy and the need to accommodate those working in those industries, particularly when considered against the backdrop of an ageing population.

Overall, the plan lacks ambition and fails to identify or address specific needs. The approach is negative, and this is summed up by the vision for the village set out in the NP’s opening chapters:

‘There is also a sense that the character of Long Melford would change, for the worse, if significant additional development were to take place.’ (paragraph 3.18)

The plan has as its starting point, an assumption that development would be negative and this assumption guides the plan’s strategy. The plan should have set out to assess what is needed to address identifiable need across all sectors of the community and what is required to maintain the viability of local business and services, and to provide sufficient housing.

Having established these baseline requirements, an assessment could then be undertaken of how, and if, these needs could be met. However, the NP’s approach appears to have worked backwards from the assumption that new development should be minimise irrespective of need. This is exemplified by the difference in housing need identified by the CAS assessment and the arbitrary apportionment of Babergh’s putative housing requirements.

Melford Hall Estates / Hill Group – 28/02/19

_________________________________________________________________________

Comment from Gladman Land – 28/02/19 

1 INTRODUCTION

1.1 Context

1.1.1 Gladman specialise in the promotion of strategic land for residential development and associated community infrastructure. From this experience, we understand the need for the planning system to deliver the homes, jobs and thriving local places that the country needs.

1.1.2 These representations provide Gladman’s response to the current consultation on the presubmission version of the Long Melford

Neighbourhood Plan (LMNP) under Regulation 14 of the Neighbourhood Planning (General) Regulations 2012.

1.1.3 Through these representations, Gladman provides an analysis of the LMNP and the policy decisions promoted within the draft Plan.

Comments made by Gladman through these representations are provided in consideration of the LMNP’s suite of policies and its ability to fulfil the Neighbourhood Plan Basic Conditions as established by paragraph 8(2) of Schedule 4b of the Town and Country Planning Act 1990 (as amended) and supported by the Neighbourhood Plan chapter of the PPG1.

1.1.4 In accordance with the Neighbourhood Plan Basic Conditions, Neighbourhood Plan policies should align with the requirements of the National Planning Policy Framework (the Framework) and the wider strategic policies for the area set out in the Council’s adopted Development Plan. Neighbourhood Plans should provide a policy framework that complements and supports the requirements set out in these higher-order documents, setting out further, locally- specific requirements that will be applied to development proposals coming forward.

1.1.5 The LMNP should only be progressed if it meets the Neighbourhood Plan Basic Conditions, supported by a robust and proportionate evidence base.

1.1.6 The Framework is clear that Neighbourhood Plans cannot introduce policies and proposals that would prevent sustainable development opportunities from going ahead. They are required to plan positively for new development, enabling sufficient growth to take place to meet the development needs for the area and assist local authorities in delivering housing need. Policies that are not clearly worded or intended to place an unjustified constraint on further sustainable development from taking place are not consistent with the requirements of the Framework or the Neighbourhood Plan Basic Conditions.

1.1.7  The LMNP should not seek to include policies that have no planning basis or are inconsistent with national and local policy obligations. Proposals should be appropriately justified by the findings of a supporting evidence base and must be sufficiently clear to be capable of being interpreted by applicants and decision makers. Policies and proposals contained in the LMNP should be designed to add value to existing policies and national guidance, as opposed to replicating their requirements.

1.1.8 As the Steering Group is aware, Gladman are promoting land in the LMNP area for residential development, identified as ‘Skylark Fields’ in the consultation document. The site is in a suitable sustainable location and we have submitted a planning application on the site for 150 dwellings with associated community infrastructure. A planning appeal for non-determination will be heard on this site in June.

2 LEGAL REQUIREMENTS, NATIONAL POLICY & GUIDANCE

2.1 Legal Requirements

2.1.1 Before a neighbourhood plan can proceed to referendum it must be tested against a set of basic conditions set out in paragraph 8(2) of Schedule 4b of the Town and Country Planning Act 1990 (as amended). The Basic Conditions that the LMNP must meet are as follows:

a) Having regard to national policies and advice contained in guidance issued by the Secretary of State it is appropriate to make the neighbourhood plan;

d) The making of the neighbourhood plan contributes to the achievement of sustainable development;

e) The making of the neighbourhood plan is in general conformity with the strategic policies contained within the development plan for the area of the authority; and

f) The making of the neighbourhood plan does not breach, and is otherwise compatible with, EU obligations.

g) The making of the neighbourhood plan does not breach the requirements of Chapter 8 of Part 6 of the Conservation of Habitats and Species Regulations 2017.

2.2 National Planning Policy Framework, & Planning Practice Guidance

National Planning Policy Framework

2.2.1 The National Planning Policy Framework (the Framework) sets out the Government’s planning policies for England and how these are expected to be applied. In doing so it sets out the requirements of the preparation of Neighbourhood Plans within which locally-prepared plans for housing and other development can be produced.

2.2.2 In 2018, the Minister of Housing, Communities & Local Government (MHCLG) introduced the first changes to the Framework (the Revised Framework) which has since brought about fundamental changes to the planning system. In relation to the preparation of Neighbourhood Plans, paragraph 13 of the Revised Framework states:

“The application of the presumption has implications for the way communities engage in neighbourhood planning. Neighbourhood plans should support the delivery of strategic policies contained in local plans or spatial development strategies; and should shape and direct development that is outside of these strategic policies.”

2.2.3 Further guidance on how the Presumption interacts with Neighbourhood Plans is provided in paragraph 14 of the Revised Framework.

2.2.4 The Revised Framework sets out how neighbourhood planning gives communities the power to develop a shared vision for their area in order to shape, direct and help deliver sustainable development. However, neighbourhood plans should not promote less development than set out in the strategic policies for the area, or undermine those strategic policies contained in higher order documents.

Planning Practice Guidance 

2.2.1 It is clear from the requirements in the Framework that neighbourhood plan policies should be prepared in general conformity with the strategic requirements for the wider area, as confirmed in an adopted Development Plan. The requirements set out in the Framework are also supplemented by the Government’s suite of Planning Practice Guidance (PPG). In relation to the preparation of the LMNP, the PPG on Neighbourhood Planning is of particular relevance.

2.2.2 The PPG also emphasises that; 

“…blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence”

2.2.3 With further emphasis that;

“…. All settlements can play a role in delivering sustainable development in rural areas– and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence.”

2.2.4 Accordingly, the SNP will need to ensure that it takes into account the latest guidance issued by the SoS so that it can be found to meet basic conditions (a) and (d).

2.3 Strategic Environmental Assessment

2.3.1 In accordance with PPG ID: 11-027, the preparation of Neighbourhood Plans may fall under the scope of the Environmental Assessment of Plans and Programmes Regulations 2004 (SEA Regulations) that require a Strategic Environmental Assessment (SEA) to be undertaken where a Plan’s proposals would be likely to have significant environmental effects.

2.3.2 The SEA is a systematic process that should be undertaken at each stage of a Plan’s preparation. It should assess the effects of a Neighborhood Plan’s proposals and whether they would be likely to have significant environmental effects and whether the Plan is capable of achieving the delivery of sustainable development when judged against all reasonable alternatives.

2.3.3 The decision making and scoring of the SEA should be robust, justified and transparent and should be undertaken through a comparative and equal assessment of each reasonable alternative. Too often SEA flags up the negative aspects of development whilst not fully considering the positive aspects which can be brought about through new opportunities for housing development and how these can influence landscape issues, social concerns and the economy.

2.3.4 Whilst Gladman note that it is the intention to demonstrate how the LMNP meets with the requirements of relevant EU legislation through the Basic Conditions statement at the Submission stage, it is currently unclear whether the LMNP has been subject to SEA Screening, or whether a SEA is required in this instance. Given the nature of the LMNP’s proposals, Gladman suggest that there may be a requirement to undertake a full SEA to support the LMNP’s preparation.

 
3 DEVELOPMET PLAN

3.1 Adopted Development Plan

3.1.1 To meet the requirements of the Framework and the Neighbourhood Plan Basic Conditions, neighbourhood plans should be prepared to conform to the strategic policy requirements set out in the adopted Development Plan.

3.1.2 The adopted Development Plan relevant to the preparation of the Long Melford Neighbourhood Plan, and the Development Plan which the LMNP will be tested against, consists of the Babergh Core Strategy (2014) and the saved policies of the Babergh Local Plan (2006). The Babergh Core Strategy sets out the vision, objectives, spatial strategy and overarching policies to guide development in the Babergh up to 2031.

3.2 Emerging Development Plan

3.2.1 Babergh District Council are currently in the process of preparing a new Joint Local Plan, alongside Mid Suffolk District Council, that will supersede the policies of the Babergh Core Strategy and Local Plan once adopted.

3.2.2 An initial Issues and Options consultation was held in late 2017. The Parish Council should be mindful of this document as it emerges and draft the policies within the LMNP as flexibly as possible to minimise any potential conflicts with the emerging

Joint Local Plan.

3.2.3 The housing requirement in the Joint Local Plan will be based upon the new standardised methodology for calculating local housing needs using the methodology as published in the PPG. It must be noted that this is only an interim position. The Government has stated it will consider adjusting the methodology, to be consistent with ensuring that 300,000 homes are built per year by the mid-2020s. It is not known what impact this will have for the future housing requirement in the Joint Local Plan, but this will almost certainly be higher than the figure proposed in the latest Strategic Housing Market Assessment (SHMA) for the District.

3.2.4 The emerging Joint Local Plan proposes to carry forward the designation of Long Melford as a Core Village and consulted on a number of options for the percentage of the districts growth that would be appropriate in these settlements. The level of growth that these settlements are required to deliver is yet to be determined and as such the LMNP should be as flexible as possible regarding the level of development proposed.

4 LONG MELFORD NEIGHBOURHOOD PLAN POLICIES

4.1 Context

4.1.1 These representations are made in response to the current consultation on the pre-submission version of the LMNP, under Regulation 14 of the Neighbourhood Planning (General) Regulations 2012. This chapter of the representation highlights the key points that Gladman raise with regard to the content of the LMNP as currently proposed.

4.2 Neighbourhood Plan Policies

4.2.1 This section of the representations provides Gladman’s comments on the draft LMNP’s policies. As currently proposed, Gladman believe that a number of the LMNP’s policies require further modification/amendment, before they can be considered consistent with the Neighbourhood PlanBasic Conditions.

Policy LM-H1 Growth and Sustainable Development

4.2.2 Gladman welcome that this policy sets out support for sustainable development in Long Melford. However, we raise serious concerns with the quantum of development that is proposed in the LMNP and the proposed allocations that make up this housing requirement. Without a robust assessment of housing need, translated through to a housing requirement, it is unclear how the strategy proposed can be demonstrated to be appropriate. A higher level of housing need would adjust the balance when considering the suitability of sites for allocation and as such the proposed allocations may need revisiting.

4.2.3 Recognising that the Steering Group has sought to determine a housing requirement for the LMNP, this is at a time of uncertainty for assessing housing needs in the neighbourhood area. Policy CS11 of the adopted Core Strategy requires housing need to be based upon a locally identified housing need however the Core Strategy is now over 5 years old and policies will need to be reviewed to see whether they will need updating, in line with Paragraph 33 of the revised Framework. Due to the complexity of trying to determine locally identified housing need Gladman do not consider this policy to accord with the revised Framework and this policy will need updating through the emerging Joint Local Plan. This is because the revised Framework now requires strategic- policy making authorities to provide designated neighbourhood areas a housing requirement and where this is not possible, to provide an indicative figure where requested.

4.2.4 The consultation document currently estimates housing need from three sources, none of which are considered to be appropriate following the changes to national policy and guidance. The first approach appears to be based upon the formula set out in the Planning for the Right Homes for the Right Places consultation however in its response to this consultation the Government stated that it is not proposing to take forward this approach and as such there is no reference to this formula in the revised NPPF. Use of the SHMA, whilst reference is useful for context, would also be inappropriate as this will not form the basis for assessing housing needs moving forward in the Joint Local Plan.

4.2.5 As one of the most sustainable core villages in the district, the neighbourhood plan would be better placed planning for a figure representative of Long Melford in the settlement hierarchy. As the Council is yet to determine the quantum of development that the Core Villages will be allocated, the current options range from between 15 and 35% of the housing requirement, the Steering Group would be better placed requesting an indicative figure from the Council, as set out in Paragraph 66 of the Revised Framework. It is highly likely that the housing requirement will be higher than the level currently proposed within the LMNP and further housing allocations will be required.

4.2.6 Alongside this the Steering Group should ensure that the policy framework of the LMNP is sufficiently flexible, aligning with the emerging Joint Local Plan where possible, to ensure the longevity of the neighbourhood plan and removing the necessity to review the LMNP upon adoption of the Joint Local Plan.

LMNP Policies LM-H2–LM-H7, Allocation of Sites for Development

4.2.7 Gladman has concerns regarding a number of the proposed housing site allocations and their deliverability. Several of the site allocations are either within the Conservation Area or are currently in employment use.

4.2.8 Land off Station Road, subject to appeal (Reference: APP/W3520/W/18/3214377) would make a suitable allocation within the LMNP either alongside, or instead of current proposed allocations. The principle of development in this location is accepted by the Steering Group through Policy LMH9 and the adjacent proposed allocation of land west of Rodbridge Hill. Land off Station Road is in a more accessible location to key services and facilities than this allocation yet is not allocated for development.

4.2.9 Recognising that land west of High Street is a proposed allocation as a rural exception site for 100% affordable housing this site is some distance from services and facilities. Land off Station Road can deliver more affordable housing, alongside market housing, in excess of the affordable housing proposed on this rural exception site, in a more accessible location. As stated above, Policy LM-H9 recognises that the principle of development on this site is acceptable and the benefits of delivering development at this scale should be fully explored through a SEA.

4.2.10 Further, the allocation of sites currently in employment use may conflict with the adopted Core Strategy and undermine the delivery of strategic policies in seeking to support job growth in the District. In this regard, Policy CS3 states that existing sites and premises will be protected from other types of development to accommodate a range of employment development. As this approach will need reviewing through the emerging Joint Local Plan to see if it needs updating, Gladman suggest the Steering Group discuss these potential allocations with Council with careful consideration of the impacts of a change of use from employment use to residential and how this may affect delivery of strategic policies of the Core Strategy.

Policy LM-H8, Contingent Allocation of Sites, Northern Fringe of Sudbury

4.2.11 Policy LM-H8 appears to be a statement of fact rather than a land use policy and would be better served as background text to the housing section.

Policy LM-H9, Contingent Allocation of Sites, Site off Station Road, known as Skylark Fields or Big Field, Chapel Farm

4.2.12 Gladman support that this policy accepts the principle of development on land off Station Road. The development proposal could be delivered in line with many of the policies proposals, the main conflict being the quantum of development. However, as drafted these proposals are not requirements and the policy is currently more like a community aspiration.

Gladman has set out above that future housing needs for Long Melford are uncertain and likely to change in the near future. The preparation of the LMNP is the community’s opportunity to plan for future housing needs whilst setting out what policy requirements would make development on this site at the scale proposed acceptable to the community in this regard. It may be possible to deliver facilities sought by the community on this site that could not be delivered through the other proposed allocations of the LMNP.

4.2.13 Without a SEA assessment to test the varying scales of development on the site, seeking to restrict the size of development of the site would is not based on a robust assessment of the sustainability, instead based on community preference for smaller scale developments. This approach does not accord with the Framework. Reasonable alternatives, such as allocating the development proposal as submitted, will need to be tested for the LMNP to meet EU Obligations and therefore the basic conditions. This issue is compounded by the fact that the assessment of land off Station Road, C1 of the site assessment is a larger site than the development proposal submitted.

4.2.14 Further, seeking to restrict the scale of development on this site would not be an efficient use of the land at a time when there is an anticipated shortage of land for meeting housing needs; conflicting with Paragraphs 122 and 123 of the Revised Framework.

Having accepted the principle of development on this site, the submitted planning proposal makes the optimal use of the potential of the site.

Policy LM- H10, Size and Character of Developments

4.2.15 This policy states that there is a strong community preference for smaller development schemes. As we have set out above, this development strategy should be tested through the SEA to ensure that seeking to restrict the scale of developments is most sustainable option when considering environmental impacts.

4.2.16 Reference in this policy to the completion of a CS11 assessment checklist unnecessarily repeats the requirements of the Babergh Core Strategy and CS11 Supplementary Planning Document. As we have set out above that we consider this element of the Core Strategy will need updating in light of the revised Framework to ensure the longevity of the LMNP, Gladman suggest that this element of

the policy is deleted.

Policy LM-H11, Affordable Housing

4.2.17 Gladman note that the requirements of this policy largely duplicate the contents of Babergh Core Strategy Policy CS19.

In this respect, as set out in paragraph 16(f) of the Revised Framework, it is not necessary for a Neighbourhood Plan to repeat policies already set out in other Development Plan documents, and we therefore suggest that this policy is removed from the LMNP.

4.2.18 The Core Strategy policy also allows for a flexible approach to affordable housing tenure based on established needs. This approach is considered more suitable than the proposed LMNP policy approach. Should the Parish Council wish to continue to propose a tenure split this will need to be supported by an adequate and robust evidence base. Gladman suggest that the tenure preferences expressed in this policy are discussed with the Council’s housing team or affordable housing officer, to ensure they align with the borough’s Council’s emerging affordable housing policies.

Policy LM-H12, Housing Reserved for Local People

4.2.19 Policy LM-H12 is not a land use policy and would be better served as an appendix to the neighbourhood plan which contained other non-land use policies in accordance with the PPG.

Policy LM-H15, Local Green Space

4.2.20 This policy seeks to designate an extensive parcel of land as Local Green Space (LGS). Paragraph 76 of the Framework sets out the role of local communities seeking to designate land as LGS and makes clear that this designation should be consistent with the local planning of sustainable development in the wider area. It states that: “Local communities through local and neighbourhood plans should be able to identify for special protection green areas of particular importance to them. By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances. Identifying land as Local Green Space should therefore be consistent with the local planning of sustainable development and complement investment in sufficient homes, jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed and be capable of enduring beyond the end of the plan period.”

4.2.21 Further guidance is provided at paragraph 77, which sets out three tests which must be met for the designation of LGS.

It states that: “The Local Green Space designation will not be appropriate for most green areas or open space. The designation should only be used:

– where the green space is in reasonably close proximity to the community it serves;

– where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and

-Where the green area concerned is local in character and is not an extensive tract of land.”

4.2.22 Taking the requirements of the Framework and PPG into account, it is essential that when allocating LGS, plan makers can clearly demonstrate that the requirements for its allocation are met in full and that they are capable of enduring over the plan period and beyond.

4.2.23 Paragraph 4.50 states that the proposed Local Green Space is designated to:

•Check the unrestricted expansion of Sudbury and to prevent it from merging with surrounding villages;

•To preserve the setting and special character of communities north of Sudbury; and

•To assist in safeguarding the countryside from encroachment.

4.2.24 It is clear that this proposal directly conflicts with PPG4 which states that ‘blanket designation of open countryside adjacent to settlements will not be appropriate. In particular, designation should not be proposed as a ‘back door’ way to try to achieve what would amount to a new area of Green Belt by another name.’

As the justification at Paragraph 4.50 makes direct reference to objectives and purposes of Green Belt, it is clear that this designation is simply seeking to propose new Green Belt by the back door and this policy should be removed.

4.2.25 The parcel proposed is nearly the size of the settlement of Long Melford, clearly an extensive tract of land.

5 LAND OFF STATION ROAD, LONG MELFORD

5.1 Development Proposals

5.1.1 As the Steering Group will be aware, Gladman are promoting land off Station Road for residential development. A planning application has been submitted on the site for 150 dwellings which will be subject to appeal (Reference: APP/W3520/W/18/3214377) in June 2019. The planning application (DC/18/00606) is accompanied by a full suite of technical planning documents available on the Councils website.

5.1.2 The development proposal includesthe following:

•Up to 150 residential dwellings (including 35% affordable housing delivered in accordance with current adopted planning policy);

•Structural landscape planting and the retention and positive management of key landscape features;

•2.78 ha of formal and informal open space (over 33% of the gross outline area);

•Improved connectivity to and potential upgrading of footpaths;

•New access arrangements including footway/cycle links and highways improvements to Station Road; and

•A comprehensive surface water drainage scheme including an infiltration basin.

5.1.3 The site will be able to deliver many of the community aspirations as set out in Long Melford neighbourhood plan including market and affordable housing in a sustainable location.

5.1.4 A location plan is attached as Appendix 1.

6 CONCLUSIONS

6.1.1 Gladman recognises the Government’s ongoing commitment to neighbourhood planning and the role that such Plans have as a tool for local people to shape the development of their local community. However, it is clear from national guidance that the LMNP must be consistent with national planning policy and the need to take account of up-to-date housing needs evidence and the direction of growth outlined in the emerging Joint Local Plan.

6.1.2 The Steering Group must ensure that the policies within the LMNP allow for sufficient flexibility and are based on robust and justified evidence.

6.1.3 The key concerns identified within this submission are as follows:

• The current lack of a SEA assessment to support the policy choices demonstrating why the choices are the preferred approach when considered against the reasonable alternatives.

•The proposed scale of development proposed at a time of uncertainty regarding housing needs for the neighbourhood area, housing needs are likely to be greater in Long Melford than currently proposed.

•Potential conflicts with the adopted Core Strategy in regard to the reallocation of existing employment sites for residential.

•Seeking to restrict the scale of development of sustainable sites.

Attached in original–Appendix 1 (map of land east of Station Raod)

28/02/19 – Gladman Land

_________________________________________________________________________

Comment from The Environment Agency – 28/02/19

Thank you for your consultation dated 17 January 2019. We have inspected the Regulation 14 Draft Long Melford Neighbourhood Development Plan, as submitted, and have highlighted key environmental constraints, as detailed below, which should be considered during the development of the Plan.

Our principle aims are to protect and improve the environment, and to promote sustainable development, we:

Act to reduce climate change and its consequences.

Protect and improve water, land and air.

Work with people and communities to create better places.

Work with businesses and other organisations to use resources wisely.

You may find the following document useful. It explains our role in the planning process in more detail and describes how we work with others; it provides:

An overview of our role in development and when you should contact us.

Initial advice on how to manage the environment impact and opportunities of development.

Signposting to further information which will help you with development.

Links to the consents and permits you or developers may need from us.

Our role in development and how we can help:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/289894/LIT_2745_c8ed3d.pdf

Natural Capital Studies have shown that natural capital assets such as green corridors and green amenity spaces are important in climate change adaptation, flood risk management, increasing biodiversity and for human health and well-being. An overarching strategic framework should be followed to ensure that existing amenities are retained as well as enhancements made and new assets created wherever possible.

We are pleased to see within the Plan, Policy LM-H15–Local Green Space. The designation of ‘local green spaces’ is an important method of protecting natural capital assets. We recommend the protection of these spaces, and encourage enhancements to be made to them to help support biodiversity and varied habitats that will help improve the ecological footprint of any development locations in the parish. And so whilst we welcome the two policies LM-V2 and LM-V3 relating to public open spaces, through protecting existing and incorporating provision of new green spaces within future developments, we consider the plan would be improved with a focus and further elaboration to develop on these policy objectives with specifics of how they will be delivered.

Designating green spaces is a positive approach, but through improving existing spaces and incorporating native species and varied habitats into designs of new areas will encourage net gains in biodiversity and wildlife links/corridors and deliver the best possible environmental outcomes. Enhancement to existing habitats should where possible feature within any conservation plans in development, and the National Planning Policy Framework paragraph 170, sub section d) states planning policies and decisions should contribute to and enhance the natural and local environment by: ‘minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures’.

We note that the site boundary to site allocation Policy LM-H6, Location K1, Land west of High Street, currently includes a small pond. There is an opportunity to create enhancements to the natural capital existing on site already and to build ecological assets into any design of development on this site to protect key habitats and improve biodiversity and wildlife corridors.

Development management will guide the provision of green infrastructure which should be delivered in a collaborative approach between developers, councilors and the local community. Sustainable Drainage Systems (SuDS) are often part of building green infrastructure into design. For more information please visit:

https://www.susdrain.org/delivering-suds/using-suds/background/sustainable-drainage.html

Flood Risk

Our data maps show that the designated Main Rivers; River Stour, River Glem and the Chad Brook all flow through the Parish and areas within Long Melford Parish fall within Flood Zone 2 and 3 as defined by thePlanning Practice Guidance.

We note that the Plan proposes a number of site allocations for built development, and whilst the majority appear to have been sequentially sited outside of the flood zone areas, Policy LM-H5, site allocation D1, Land in Borley Road is located within flood zones 2 and 3 that fall in small areas within the site boundary.

Section 4.37 ‘Justification for Policy LM-H5’ states the site is outside Flood Zones 2 and 3. However, from the site boundary shown in Map 4E our data maps actually show small flood zone sections overlapping the boundary to the north-west and south-west areas. The sequential approach should be applied to this siteallocation for any development applications submitted.

Sequential Approach

The sequential approach should be applied within specific sites in order to direct development to the areas of lowest flood risk. If it isn’t possible to locate all of the development in Flood Zone 1, then the most vulnerable elements of the development should be located in the lowest risk parts of the site.

All future development proposals within the Fluvial Flood Zone of the River Stour and its tributaries (which includes Flood Zones 2 and 3, as defined by us), or elsewhere outside Flood Zones 2 and 3 involving sites of 1ha or more, must be accompanied by a Flood Risk Assessment (FRA).

For any other minor development extensions that may be proposed over the plan-period, that fall within flood zones 2 or 3, our Flood Risk Standing Advice should be followed.

Contaminated Land

For land that may have been affected by contamination as a result of its previous use or that of the surrounding land, sufficient information should be provided with any planning application to satisfy the requirements of the NPPF for dealing with land contamination. This should take the form of a Preliminary Risk Assessment (including a desk study, conceptual model and initial assessment of risk), and provide assurance that the risk to the water environment is fully understood and can be addressed through appropriate measures. This is because Long Melford Parish is in groundwater source protection zones 1, 2 and 3, as well as on a principal Bedrock Aquifer. For any planning application the prior use should be checked to ensure there is no risk of contamination.

Please note that the views expressed in this letter by us are a response to the proposed Neighbourhood Development Plan only and do not represent our final views in relation to any future planning or permit applications that may come forward. We reserve the right to change our position in relation to any such applications.

Please contact me on the details below should you have any questions or would wish to contact any of our specialist advisors. Please continue to keep us advised on the progress of the plan.

We trust that this advice is useful.

The Environment Agency – 28/02/19

____________________________________________________________________________________________

Comment from Babergh District Council – 28/02/19

General

Generally, the Long Melford Neighbourhood Plan (LMNP) is positively prepared. However, many of the policies need re-drafting as set out further below.

• FYI, guidance on policy writing can be found on Locality’s website at:

https://neighbourhoodplanning.org/toolkits-and-guidance/write-planning-policies-neighbourhood-plan/

• The Plan needs to include a Policies Map.

• We ask that the policy numbering be simplified so that all have the ‘LM’ prefix and are then numbered sequentially, e.g. LM1, LM2, LM3 etc. (rather than LM-H1 etc). This will greatly assist us in the identification and use of these policies for development management purposes.

• The overall level of growth proposed seems appropriate given local heritage and environmental constraints. However, previous developments (e.g. Bull Lane) met earlier identified need and should not all be counted towards future growth.

• Heritage Team colleagues note that, while site allocation policies mention the constraints of the Conservation Area, no reference is made to the listed buildings or their settings, or any relevant Scheduled Ancient Monuments.

 

1.5

Suggest last sentence read: “Babergh and Mid Suffolk District Councils are currently working on an updated Joint Local Plan.”

 

1.10

The Joint Local Plan period will be (1 April) 2018 to (31 March) 2036. We suggest that the LMNP use the same period. If 2019-2036 is used, this would be a 17-year period.

 

1.17

Stage of Plan: This section will need updating each time the LMNP moves from stage to stage. Perhaps it would be better to simply identify (in a bulleted list) what has been done and what still needs to be done, accompanied by short introductory sentence.

 

Map 2A

The map appears stretched and needs reformatting.

 

2.3

Amend the text to reflect the fact that, although Long Melford is within the Dedham Vale & Stour Valley Project Area, it is not within the area currently being considered as an extension to the AoNB. The latter only extends as far as the south side of Sudbury. The Project Area itself is defined for the purposes of countryside management and does not, of itself, have any planning policy weight.

The text also refers to ‘(Figure 2B)’ but this should read ‘(Map 2B)’

 

2.4

As above, text refers to Figure 2C but should read ‘Map 2C’

 

Maps 2C, 2D & 2F

No reference is made to maps 2C, 2D and 2E in the supporting text. The map source is also missing from 2D and 2E.

 

3.7

Local Green Space is a specific designation as set out in para’s 99 and 100 of the NPPF. We therefore suggest that this sentence be deleted.

A settlement boundary policy should protect the area surrounding the village.

 

3.15

Qstn: Is there any specific evidence that shows that higher house prices are a result of growth?

Growth can also help to sustain services and facilities (this is recognised later in the Plan at paragraph 4.16).

 

3.19

Clarification is required on the definition of heritage assets and what is meant by ‘historic private houses’. The definition provided appears to contradict itself in the same paragraph stating that they ‘are open to visitors’, which is not the case for all heritage assets. Presumably the reference is to Kentwell and Melford Hall.

 

3.20

The last sentence refers to ‘off-road’ routes. Would it be better to refer to ‘non-motorised off-road routes’?

 

3.27

“secure our valuable natural environment” – We previously advised that the use of green spaces for recreational use and enjoyment may be in conflict with maintaining green space for their natural environment. We suggested these could appear as separate objectives.

‘Character and atmosphere’ referred to in point d) would perhaps relate better to point a) where reference is made to protecting and enhancing heritage assets. Amenities in point d) should be a separate point.

 

4.11

The advice from Locality is that the proposed approach to ‘design issues’ can only be addressed through the group modifying the LMNP at a later stage, i.e., it / they cannot do this via a Supplementary Planning Guidance document (SPD). In reality that would also mean repeating the process from this Reg 14 Pre-submission stage through to Independent Examination and, dependent on whether the modification is seen as ‘major’ or ‘minor’, the possibility of a second local referendum. [NB: Locality currently offer a Design Codes technical support package that the Group may be eligible for] It would, however, be possible for the District Council to adopt design guidance as an SPD.

 

4.14

The situation has moved on somewhat since last October’s draft document and only 4.14 sub-paragraph 3 is now relevant. The rest can be deleted. It is still unclear if these figures take into account Long Melford’s role as a Core Village.. Nevertheless, the level of growth proposed may be appropriate given the heritage and environmental constraints.

 

4.17

Capacity is not the same as existing commitments, and is determined by a variety of factors. The first sentence should read “Existing commitments and the potential for additional sites are now examined”

Any completions at base date would not count towards the provision during the plan period.

 

4.25 (4th bullet point)

It may be better to refer to this ‘a physical separation’ between settlements rather than ‘Local Green Space’ in view of the particular NPPF definition. (See also comments under 3.7 above).

 

4.26

May be useful to identify where “Skylark Fields” is.

Qstn: What is the evidence of support this and how does this link to the suggestion that part of the site should be allocated?

 

4.28

See comments under 1.10 above re plan period. Base date should be 1 April 2018.

 

4.29

Say “provision made” rather than “capacity”

 

4.30 Line 6

It would be helpful to say what the fourth site is–D1

 

4.30 (Map 4a)

BMSDC’s Heritage Team have expressed major concerns over the following sites: Q1, K1, H8, H1, H7, H6, H10, A1, L1, R1, G1, H9, J1, P1, C2, H4, SS1028

•• Development in these locations could result in a high level of less than substantial harm to the designated heritage assets and therefore all aspects of the proposal would be of concern i.e. location, scale, massing, density, articulation, detailed design etc. 

 

The Heritage Team has less concern over the following sites: H5, W1, W2, F1, SS0557

•• Development in these locations could result in less than substantial harm to the designated heritage assets and proposals would therefore be primarily subject to scale, density and location.

 

The Heritage Team has a very limited concern over the following sites: N1, H2, C3, F2, M1, D1, S1, H3,C1, SS0811, SS0967

•• Development in these locations would probably result in a negligible level of harm to the designated heritage assets.

 

4.31 Lines 7 and 8

May be better just to allocate the site for affordable housing. Exception sites are sites that are not allocated. Cross reference to LM-H6.

 

4.32 

Qstn: Where is the evidence to support the statement that development of a small part of C1 is acceptable?

 

LM-H1

As currently worded, this is a statement rather than a planning policy. It is a given that development will be in accordance with the Joint Local Plan and NP. It would be better if this first policy in the NP were re-worded along the following lines:

“This Plan provides for around XX dwellings to be developed in the Neighbourhood Plan Area between 2018 and 2036. This growth will be met through:

  i  The allocation of the following sites as identified in separate Policies in the Plan and on the Policies map:

     Site 1 (Name and NP Policy number)

     Site 2 (Name, etc)

 ii Small ‘windfall’ sites and infill plots of one or two dwellings within the Built-Up Area Boundary that come forward during the Plan Period and are not identified in the Plan; and

 iii  Conversions and new development opportunities outside the Built-Up Area Boundary in accordance with paragraph 79 of the NPPF.”

 

LM-H2(Spicers Lane)

The first paragraph is reasoned justification, and not planning policy. Normally we would not allocate sites for single dwellings as they could come forward through the normal development management process as a site within the BUAB. IT is also not appropriate to provide for a personal consent through planning policy. This can only be done through the development management process and a planning agreement. If it is to be kept as an allocation the Policy should be reworded as follows:

“Land at Spicers Lane as identified on the Policies Map is allocated for a single dwelling subject to there being:

  i No detrimental impact on the conservation area

 ii No detrimental impact on neighbouring properties

iii Satisfactory access.”

 

LM-H3(Cordell Road)

Much of this is reasoned justification rather than planning policy. 

If the site is to be allocated the NP should make the case for the change of use from employment rather than leave it to be dealt with at the planning application stage. The NP would need to be supported by evidence that employment is not viable and meets the tests set out in Local Plan policy EM24. We also remind you that the adjacent site was very controversial due to concerns about traffic along Cordell Road.

If the site is to be retained as an allocation in the NP, the Policy should be reworded along the lines suggested for LM-H2 above.

 

LM-H4(rear of Bull Hotel)

The same comments as for LM-H3 around reasoned justification apply.

This is a sensitive location and is constrained in terms of highways, parking and access. Again, a loss of employment site.

If the site is to be retained as an allocation in the NP, the Policy should be reworded along the lines suggested for LM-H2 above.

 

LM-H5(Borley Road)

The same comments as for LM-H3 around reasoned justification apply. Also:

•• Flooding might also be an issue here.

•• Seems to develop the village in an odd direction. Poorly located to village centre.

•• Highway concerns, incl’ lack of existing footways and road safety issues

If the site is to be retained as an allocation in the NP, the Policy should be reworded along the lines suggested for LM-H2 above.

 

LM-H6 (Land W of High Street)

The same comments as for LM-H3 around reasoned justification apply. See also our comments against 4.30 above.

This is a very sensitive location and BMSDC’s Heritage Team place this site in the category of ‘major concern’ where development in [this] location could result in a high level of less than substantial harm to the designated heritage assets and therefore all aspects of the proposal would be of concern i.e. location, scale, massing, density, articulation, detailed design etc. In this instance, perhaps a linear development addressing the street could be considered, due to the morphology of the historic development throughout the village. It also stands on the outer periphery of the village and so a gentle approach into the built-up area should be maintained, rather than a large housing development which would appear largely atypical. A green buffer to the western boundary should be maintained between potentialdevelopment to the east of the site and the designated park and garden of Kentwell Hall to the west, as well as referencing the former allotment gardens evident on historic OS maps.

If this site is allocated in the NP it is not an exception site. If the scheme is to meet local housing needs then it may be better not to allocate the site and deal with this through the rural exception policy. Highways concerns would also need to be addressed, e.g. lack of footways on either side of the carriageway.

 

LM-H7 (.. opp Ropers Lane)

As worded, this is a mixture of reasoned justification, policy and context. See also our comment above under 4.11 re ‘design stage’.

The Policy should be reworded along the lines suggested for LM-H2 above. See also heritage comments referred to under 4.30 above.

 

4.40

The numbers in the table may need to be re-addressed subject to how the group action the comments above re various site allocations.

 

LM-H8

This is a statement and not a policy. It should therefore be included as part of the text of the Plan rather than a policy.

 

LM-H9

This is a mixture of statement and policy. The part of the site that the Parish Council supports should form a proper allocation. It would then be clear which part of the site was considered suitable for development.

 

LM-H10

This is a mixture of statement and policy. The part of the site that the Parish Council supports should form a proper allocation. It would then be clear which part of the site was considered suitable for development.

As drafted, this policy appears to be trying to do a number of things which results in confusion, i.e., the policy should be more specific in its requirements. In particular:

 The first three para’s read as preamble. The policy itself starts at the fourth para’ with the words “ All proposals …”.

 It may be best to omit the third paragraph altogether given that this is at odds with allocations made elsewhere. The Supporting text at 4.44 also discusses a desire for max 20 unit schemes.

 Delete the reference to the ‘CS11 Checklist’ as this may be time limited. It is better for the LMNP to set out its own checklist.

 The requirements of this policy could be viewed as being too onerous. The level of supporting information required should be proportionate to the scale of development proposed.

 The last paragraph should refer to “major developments” rather than “all developments”

 

LM-H11

Needs to be in line with NPPF and include reference to sites of 0.5ha or more (irrespective of no. of units). Note also that this policy may not be necessary if it duplicates NPPF or (Joint) Local Plan policy

 

4.45

Suggest you state which AMR, i.e., include a date reference

 

LM-H12

The policy is not clear and the illustrative calculation is wrong, i.e., 10% of 35 affordable units is 3.5 homes not 10 homes. We also suggest adding the following sentence at the end of the policy: “These restrictions should be delivered through a legal agreement attached to the planning consent.”

 

LM-H13

This reads as an aspiration and not a policy. Qstn: What is a meant by ‘significant proportion’?

Would be helpful to give a % similar to other neighbourhood plan policies?

 

LM-H14

This reads as a statement not a policy. We suggest the NP avoid phrases such as pastiche.

 

LM-H15 (Local Green Space)

This reads more like a buffer policy to prevent coalescence with Sudbury. It also does not meet the criteria for a Local Green Space as set out in in the NPPF, in particular para 100 c) which refers to extensive tracts of land.

It might be worth exploring the idea further but, perhaps, this issue would be better dealt with by reinforcing the settlement boundaries. Qstn: Is the reference to ‘all development’, or just ‘residential development’?

Also, with reference to the phrase “generally not supported”- surely as green space worthy of protection, it should be protected from all development not required for its long-term protection?

 

LM-H16

This reads more as a statement than a policy and in any event would not comply with the regulations.

 

Map 5A

There appears to be no cross-reference to this map within the supporting text.

 

5.53

Suggest delete “which was part of the preparation of the Plan“ as this is a given.

 

LM-T1

The policy should be specific on where assessments are required and cannot say where considered to be appropriate by the Parish Council. While addressing the threshold for residential development, no threshold is given for commercial development. You may want to do so, based on floorspace.

 

LM-T2 (Parking Guidelines)

The policy should refer simply to SCC Parking Guidelines as these may be updated in the future. The policy wording stop after the web link. The rest is just detail.

 

LM-T3 (EV Charge Points) 

Qstn: Is this an Electric Vehicle Charging Point or the infrastructure to support such that, if required in the future, it could be installed?

We suggest the following alternate wording: “All new residential developments should provide options for EV charging”

 

Comm Action LM-TCA1

References here to Cordell Road conflict with the two allocations for housing close to the junction with Bull Lane, and highlights the difficulties of these two allocations.

 

LM-V1

This is covered by CIL and does not need a policy. If it were to be a policy there should be evidence to support it. Note that you cannot require a contribution to be directed to a specific location.

 

Map 6A

There appears to be no cross-reference to this map within the supporting text.

 

LM-V2 (Protection of Green Spaces)

These Green Spaces are different to the larger “Local Green Space” – which we have commented on under LM-H15. There should also be an explanation as to how the proposed local green spaces meet the criteria set out in para’s 99 & 100 of the NPPF.

Qstn: Has a Green Space Appraisal been undertaken?

Note also that any allocated ‘local green space’ must be shown on the Policies Map

 

LM-V3

This reads a statement rather than a planning policy.

 

LM-V4 (Amenities)

Suggest this could be linked to the allocation policies. However, developers are unlikely to agree to contribute to off-site provision as this is already part of the CIL payment that they have to pay.

 

LM-V5 (Allotments)

Should be linked to specific allocations or locations where the principle of residential development is acceptable. The second paragraph is a statement and not policy.

 

LM-B1

Avoid referring to plans and policies which may be out of date soon.

 

LM-B2 (Res. to Employ.)

This could be summarised by stating that where these have minimal impact on existing neighbour amenity they could be encouraged, as all considerations stated would already be considered if such an application arose. We suggest you delete the first bullet point as, for example, small home-based businesses may need to employ one or two people from elsewhere. Each application would also need to demonstrate adequate parking in order not to impact on neighbour amenity.

 

LM-B3 (Employ. to Res.)

This policy contradicts allocations made elsewhere in the Plan (e.g. LM-H3 & LM-H4). It seeks to protect employment and mirrors existing BDC policy EM24 but goes on to offer the opportunity for “counter-vailing benefit”. Once employment opportunities are lost, they rarely return and local employment will be supportive of the wider concerns regarding traffic and transport sustainability that are emphasised throughout the document.

 

LM-B4 (Nethergate Brewery)

This needs to be tightened up. Qstn: What sort of retail is considered appropriate here? Must it be linked to the Brewery?

It may be better simply to support a use ancillary to the existing brewery business, or an alternative compatible commercial use thatdoesn’t impact on the town centre. Housing here would be a bad neighbour for the brewery!

 

Comm Action LM-BCA1

We suggest simply as a comment that some of the parking issues are within the PC’s own gift to deliver. The car park is underutilised but much of the street parking is by High Street businesses. Suggest that businesses park and walk to their shop leaving the High Street bays for customers. An alternative would be to introduce time limits for street parking in trading hours.

 

8.4

You could add to the end of the paragraph “… and other decision makers, for example, when planning appeals are considered.”

Babergh District Council – 28/02/19

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Comment from Babergh District Council Strategic Housing – 28/02/19

4.31 (Site K)

 (See also comments below re LM-H6). We would recommend this not being allocated otherwise it will not be a rural exception site. Whilst the site in terms of net size could provide for up to 30 dwellings, Iam aware of this site and some of the planning constraints on the level of development, such that a linear development which reflects the existing pattern of development is more likely to be supported and is the current advice provided to the RP that has been working with the PC.

 

Policy LM-H6

The advantages of this site are that it is owned by a charity willing to make the land available on terms which enable 100% affordable housing; the owner is working with a suitable developer. The constraints are its distance from village facilities, heritage concerns, and its location beyond but adjacent to the built-up area boundary.

 We would disagree that the site “should be developed to optimise its use”. A RES net development should reflect the Local Housing Needs recommendations in terms of the number of dwellings needed to meet local need and also be guided by any planning constraints. So if the LHNS states there is a need for 15 AH dwellings and the site is capable of supporting that number, then 15 would be the number of homes proposed.

 As referred to above, the number of homes on a RES is not based on the overall density that a site can take, so 30 would not be the applicable number and would be deemed as too big for a true RES development.

 If the site is allocated it is unlikely to end up as a RES development as an adopted plan with site allocations will undoubtedly have the effect of increasing the land value and will make a RES unviable. In addition if it was allocated and then brought forward by a private developer, any affordable homes brought forward would not be allocated/prioritised for local needs.

There is certainly support for this site to come forward as a RES development but would suggest not to allocate. It could as an alternative to a RES the PC could consider a Community-led housing scheme and consider setting up a CLT– we can provide advice on this.

 

LM-H11, Affordable Housing

Qstn: What evidence have the NP group used to come up with a 50:50 split between rented and shared ownership? What did the LHNS results and recommendations say?

The current AH SPD states that affordable housing tenure will be 75% rented and 25% shared ownership. Of course the July 2018 NPPF introduces more Affordable housing products so it may be that any of the market led sites within this draft submission could include other products that would be in conformity with the NPPF and the AHSPD.

 

LM-H12, Housing Reserved For Local People

This policy does not conform with the Councils existing Local Connection criteria for the allocation of affordable housing which we would expect the NP to be in conformity with. 

Re “ People with full-time local employment” : This discriminates against those who are working part-time, which may include mothers/fathers with school age children/disabled people/carers

Re “People with dependent relations living locally”: This needs clarifying.

Qstn: What constitutes dependants?

An applicant may not want to move in to LM with dependent relatives living locally but may need to move there to receive support.

Babergh District Council Strategic Housing – 28/02/19

_________________________________________________________________________________________

 

Comment  from Suffolk County Council – 28/02/19

Thank you for consulting Suffolk County Council (SCC) on the Pre Submission version of the Long Melford Neighbourhood Plan.

SCC is not a plan making authority, except for minerals and waste. However, it is a fundamental part of the planning system being responsible for matters including:

  • Archaeology
  • Education
  • Fire and Rescue
  • Flooding
  • Health and Wellbeing
  • Libraries
  • Minerals and Waste
  • Natural Environment
  • Public Rights of Way
  • Transport

This response, as with all those comments which SCC makes on emerging planning policies and allocations, will focus on matters relating to those services.

In this letter we aim to highlight potential issues and opportunities in the plan and are happy to discuss anything that is raised. Where amendments to the plan are suggested, proposed additional text will be in italics and proposed deletions will be in strikethrough.

 

Archaeology

Use of and reference to the Historic Environment Record in outlining the background of the Village is welcome, as is reference to the richness of archaeological remains in the parish. It would be helpful if this is reiterated in the ‘Key Characteristics, Key Challenges and Vision’ section of the plan (the Historic Character sub-section seems most appropriate). In particular it should be emphasised that there is a high archaeological potential throughout the whole parish. Text should also recommend that applicants should contact the SCC Archaeological Service at the earliest possible time. Below is some suggested text:

“The whole village has a high potential for archaeology due to the density of Roman and Medieval Occupation. Archaeological evaluation should be carried out at the earliest possible time and applicants for planning permission within areas of high archaeological potential should contact the Suffolk County Council Archaeological Service at the earliest possible time.”

A desktop level assessment of sites allocated within the plan has led to the following recommendations to be included within the site policies. For the majority of sites archaeology can be addressed through planning conditions. There are two sites, noted below, where we would recommend additions to the site allocation policies.

Policy LM-H6, Allocation of Sites for Development: K1, Land west of High Street: Due to this site’s size and location on the Medieval town road front it is recommended archaeological evaluation takes place prior to the granting of planning permission. SCC would recommend that this is included in the site allocation policy.

Policy LM-H7, Allocation of Sites for Development: F1, Land west of Rodbridge Hill and opposite Ropers Lane: Due to this sites size and location near a Roman Villa and a possible site for burials near the Roman Road it is recommended archaeological evaluation takes place prior to the granting of planning permission. SCC would recommend that this is included in the site allocation policy.

 

Education

Early Years: Early years provision within Long Melford is on the school site, as mentioned in paragraph 6.9. Early years still requires some consideration by SCC and details will be provided to the parish council as soon as possible.

Primary: The catchment Primary is Long Melford Church of England Primary School, and the background information within the plan on the capacity and forecast pupil role in paragraph 6.12 is correct

In isolation the neighbourhood plan growth can be accommodated at the school based on current forecasts. When combined with pending planning decisions (122 dwellings at Stafford Works-15/00565/OUT, and 150 dwellingseast of Station Road–DC/18/00606 currentlyawaiting appeal) the school would be over capacity. There is a potential option to expand the school to 315 places to address additional need. SCC will continue to monitor pupil forecasts and housing development in order address education demands it Long Melford.

Secondary: The catchment secondary school is Ormiston Sudbury Academy. Ormiston Sudbury Academy is experiencing housing growth within the catchment. SCC will consider this growth, including the proposed growth in the neighbourhood plan, in addressing the provision of secondary school places.

 

Flooding

It would be helpful if the plan could include a description of flood risks within the parish. While paragraph 4.37 indicates that flooding from rivers (fluvial flooding) has been taken into account in the site selection process there is no indication that surface water issues (pluvial flooding) have been considered.

It is helpful to highlight flooding as a potential constraint to development. This can then enable development to be directed away from these areas or to justify betterment of surface water conditions from development. There are flooding and drainage issues in Long Melford that the plan positively address through policy.

Long Melford is affected by both fluvial (from rivers) and pluvial (surface water) flood risk, which are shown on the maps accompanying this response. The parish centre mainly drains into the River Stour either directly or via ordinary watercourse. There are significant issues with the capacity of the Anglian Water sewer system and the private sewers that discharge to the river if additional water is allowed to drain into this uncontrolled.

Comment should be sought from Anglian Water as to whether the neighbourhood plan affects these capacity issues. If there is an issue, other forms of drainage, such as infiltration, or retention of water on site would need to be considered. As the Lead Local Flood Authority SCC recommends that the neighbourhood plan strongly encourages drainage through infiltration into the ground or water storage on site.

It is noted from the document ‘Appendix 3: Call for Sites’ that fluvial flood zones were accounted for, but pluvial flood risk was not. In order to help the neighbourhood plan identify flood risks, maps of flood risk and events accompany this response. SCC can offer further advice if this is required.

Policy LM-H5: The supporting text should note that there is risk of surface water flooding in the vicinity of this site, however this would not necessarily prevent the site from coming forward.

 

Health and Wellbeing

The plan contains detailed information on the village’s demographics and highlights that a significant proportion of the population is over 65. The Suffolk Joint Strategic Needs Assessment (JSNA) Healthy Aging Needs Assessment published in July 2018 highlighted that the proportion of the population over 65 will significantly increase over the next 20 years(1).

Housing Types: Due to this there is an increasing need for housing with care across the county. Housing with care is a phrase, in this context, used to discuss a range of housing types for people with a range of with care needs. This ranges from sheltered housing (which has limited care) up to residential care or nursing homes (which is care intensive). SCC are keen to promote extra care housing as it can cater to a wide range of care needs.

Neighbourhood Plans can positively contribute to addressing the housing and care need of older people by allocating land for housing with care or promoting this type of use through policy. It is recognised that Policy LM-H13 has attempted to promote bungalows for people with impaired mobility. SCC is not able to provide specific information on what numbers of different types of housing with care are required and so would recommend a flexible approach in planning policy. Simply favouring schemes with bungalows does not necessarily address the wide ranges of need that aging people, and other people with care needs, can require.

It is recommended that the policy is reworded to be more flexible in providing housing for older people and others with care needs. Suggested wording for the policy amendment is below.

“ Proposals for housing with care within category will be supported. In particular Extra Care Housing is encouraged to provide for a wide range of care needs”

 

Minerals and Waste

SCC is the mineral and waste planning authority for Suffolk. This means the county makes planning policy for minerals and waste and determines planning applications for sites with these activities. The current relevant policy documents are the Core Strategy for Minerals and the Core Strategy for Waste. There is also an emerging document which will replace both of these documents, the Suffolk Minerals and Waste Local Plan (SMWLP). This plan is currently awaiting examination in public, however it is expected that it will be adopted later this year.

It is recommended that these documents are also mentioned as part of the local development plan in paragraph 1.6.

Minerals: The Minerals Core Strategy and the SMWLP contain policies that safeguard minerals resources across the county. In Suffolk this is mainly sand and gravel, which is used as aggregate. Areas of potential mineral resource are identified in the plans within a Minerals Consultation Areas (MCA). The MCAs in the Minerals Core Strategy and the SMWLP differ.

Following review of the plan it has been determined that there are no minerals safeguarding issues.

Waste:  The Waste Core Strategy and the SMWLP contain policies to prevent waste facilities being prejudiced by new development. There is one waste site within Long Melford which is the Anglian Water waste water treatment plant to the west of the parish. No development is proposed near this facility so there are no safeguarding issues to raise.

 

Natural Environment

Ecology: As part of its aspiration to be the greenest county SCC would encourage inclusion of a policy which can enable gains for biodiversity where possible. Paragraph 174 of the NPPF states that plans should “identify and pursue opportunities for securing measurable net gains for Biodiversity”

The following is suggested wording which could be used as a policy in the plan to provide benefit for wildlife through development.

“Development proposals that incorporate into their design features which provide gains to biodiversity will be supported. Landscaping and planting should encourage wildlife, connect to and enhance wider ecological networks, and include nectar rich planting for a variety of pollinating insects. Divisions between gardens, such as walls and fences, should still enable movement of species, such as hedgehogs, between gardens and green spaces. Existing ecological networks should be retained”

Area of Outstanding Natural Beauty (AONB): It is appropriate that he plan notes Long Melford is in the project area for the Dedham Vale and Stour ValleyAONB, however for clarity it should be noted that it isn’t the whole of this project area that is considered for the extension of the AONB. The extension area would extend the AONB up the Stour Valley and stop just to the south of Sudbury

Local Green Space: The principle of maintaining a green gap is understood, however use of the of Local Green Space designation to achieve this in policy LM-H15 is inappropriate as it is contrary to national policy. Paragraph 100 states Local Green Spaces should not be “an extensive tract of land”. The area in total measures approximately 90 hectares, which could be argued is extensive. An exampleof Local Green Spaces being found to be extensive is in the examiners report of the Backwell Neighbourhood Plan, where the examiner recommended modification to remove Local Green Spaces designations of 19 hectares and 32 hectares(2) from the plan.

This is not to say that the plan cannot include a policy to maintain a gap of open countryside between Long Melford and Sudbury. For example, the Stowupland Neighbourhood Plan(3) (which was recently examined and approved to go forward to referendum) contains a “Green Gap” policy to prevent coalescence with Stowmarket. An equivalent policy could be applied to the long Melford Neighbourhood Plan. To give examples of an appropriate use of the Local Green Space designation there are areas within the plan which could meet the requirements and have been identified on Map 6A-Village Services and Facilities. The Green, Little Green, Allotments, Football and Cricket Grounds and Country Park, could meet the criteria of being demonstrably special to the local community, if the parish council provides justification, and they are not extensive tracts of land.

 

Public Rights of Way (ProW)

Long Melford benefits from a reasonable local PRoW network. This network can provide a wide range of benefits including: physical and mental health benefits through access to the countryside; providing wildlife corridors; and in some circumstances providing sustainable transport options. The NPPF paragraph 98 states that planning policy should protect and enhance the PRoW network and it is encouraged that Long Melford Parish Council do this through the plan. This could be achieved through amendments to the supporting text and the inclusion of a policy.

To recognise the benefits of PRoW in the plan an amendment is suggested for inclusion in paragraph 3.5.

“Long Melford is surrounded by farmland, which gives it a wonderful rural setting and a number of outstanding views. It also benefits from a public rights of way network facilitating access to the countryside”

An amendment is suggested for paragraph 3.27 to bring the intention of national policy into the plan.

“To protect and enhance the green spaces in, and the landscapes around, the parish and to facilitate more people having the opportunity to enjoy those spaces, and to secure the valuable natural environment, and protect and enhance public rights of way which provide access to the countryside.”

The following is recommended policy wording to include within the plan, either as part of another policy or as its own policy.

“The Public Rights of Way network will be protected and enhanced. Where possible development should take opportunities to expand and improve links with the wider network, and improve the wider network.”

 

Transport

The emphasis placed on walking and cycling in the plan is welcome. SCC support the principle of increasing the ability of people to walk and cycle or use other modes of sustainable transport.

Policy LM-T1, Sustainable Travel

The intent of this policy is supported however amendments are recommended so that the policy aligns with national policy (allowing the plan to meet the Basic Conditions), aligns with local guidance, and to make the policy more effective.

NPPF paragraph 104 states that “planning policies should minimise the number and distance of journeys needed for employment, shopping, leisure, education and other activities…” As drafted the policy only applies to commercial and residential development. Other types of development, such as leisure and community uses (health facilities, schools, etc…), should also be located and developed in a way that reduces reliance on the car, but the policy as currently worded could restrict where these benefits are applied.

Changes to the second paragraph are recommended, as SCC has released new Travel Plan Guidance in January 2019(4), which applies to broader range of development and contains more specific information than is included in the policy. In general the policy should refer to county Travel Plan Guidance. Below is a redrafted version of the policy including recommended changes.

New residential and commercial developments Where relevant development should encourage sustainable travel, reduce reliance on car use and, where possible, improve accessibility to public transport. Developers must ensure that their site is linked to village facilities (as a minimum including but not limited to, one of the village convenience stores, the GP practice and the primary school) by safe, and adequately lit footways and cycleways which connect with existing footways and cycleways.

Planning applications for developments that will generate significant amounts of traffic movement must be accompanied by a Transport Assessment or Transport Statement. , which includes a Travel Plan that sets out how sustainable movement will be encouraged and car traffic accommodated satisfactorily. This will apply to residential development applications for 80 or more dwellings (SCC policy) and any commercial development application where a Travel Plan is considered appropriate by the Parish Council. For residential developments smaller than 80 units and larger than 10 units a simpler Transport Statement (including a Travel Plan) is required. Travel Plans or Travel Plan measures will be required as set in the Suffolk County Council Travel Plan Guidance.

Guidance on Transport Assessments, Transport Statements and Travel Plans should be sought from SCC.”

 

Policy LM-T2, Parking Guidelines

Inclusion of SCC Parking Guidance is welcome and supported, however as currently drafted the effect would be limited to residential development. The following amendment is recommended to ensure that SCCs parking guidance applies more widely to different kinds of development.

“Proposals for all new homes to be built in Long Melford must comply with and preferably exceed the SCC Parking

Guidance 2015…”

 

Policy LM-T3, Charging Points in New Developments

This policy is supported however it is recommended reference is made to SCCs Parking Guidance, which also requires that “access to charging points should be made available in every residential dwelling”, however also identifies how this might be achieved. It is also intended that this guidance is updated as technology progresses. A suggested amendment is below.

“Electric vehicle charging points should be made available by developers at every new residential dwelling as set out in SCCs Parking Guidance.”

 

Community Action LM-TCA1, Improve the Village Centre

SCC would welcome consultation on the public area study, and as highway authority consider the results and any recommendations made. Please note that SCC does not have available funding for public realm interventions in Long Melford therefore it would be sensible for the study to include consideration of funding and delivery mechanisms. These could include funding by developers as mitigation for schemes in Long Melford or use of the Parish Council’s Community Infrastructure Levey funding.

The study could also relate to the demographics of Long Melford as identified in the plan. It is recommended that the study considers how the public realm caters to the needs of older people and the needs of people with cognitive issues, such as dementia, which can impair an individual’s ability to navigate space. The Royal Town Planning Institute has produced advice on how planning can create better environments for people with dementia(5).

 

Community Action LM-VCA2

The review of links between green spaces could include cycle links as well as pedestrian links. There may also be scope elsewhere in the plan to look into potentially good locations for cycle parking within the town.

Site Specific Comments – SCC will be evaluating sites proposed in the plan to determine if they are likely to be acceptable from a highway perspective. These comments are not included here but will be submitted to the parish council in a follow up to this response as soon as possible.

 

Other Comments

Policy LM-H7, Allocation of Sites for Development: F1, Land west of Rodbridge Hill and opposite Ropers Lane

It is noted that the policy identifies that this site is approximately 1.1ha, however when assessing the site it appeared to be approximately 2.8ha on SCCs mapping software.

Policy LM-H8, Contingent Allocation of Sites, Northern Fringe of Sudbury

Due to the regulations regarding how developer contributions are collected and used, it is unlikely that the lastsentence of this policy will have the desired effect of providing more developer contributions to Long Melford. Long Melford Parish Council will be able to highlight potential impacts of development through consultation within the development management process. Obligations through Section 106 agreements need to be specifically attributable to a development and must be put towards a specific project. This is set out in national policy (NPPF paragraph 55) and the Community Infrastructure Levy Regulations (section 122), which state that in order to constitute a reason for granting planning permission the obligation must:

a) necessary to make the development acceptable in planning terms;

b) directly related to the development; and

c) fairly and reasonably related in scale and kind to the development.

The regulations mean that inclusion of this part of the policy will not enable more Section 106 contributions to be

obtained unless specific impacts of the development to the north of Sudbury can be identified.

Policy LM-H10, Size and Character of Developments

It is recommended that this policy does not limit what is meant by “services” by only listing the GP Surgery and primary school. A recommended amendment is below.

“The scale and nature of all schemes must ensure that an appropriate level of services, facilities and infrastructure including but not limited to GP Surgery and primary school capacity…”

Policy LM-H16, Community Benefit and paragraph 4.51

As previously mentioned, the emphasis placed in policy regarding good foot and cycle access is welcome, however stating that the priority for Section 106 contributions to go to foot and cycle paths, does not provide any further benefit than the provisions in policy Policy LM-T1 Sustainable Travel, which already requires development to link to the existing foot and cycle network. Additionally, by specifying section 106 contributions as the mechanisms for this, the policy could inadvertently exclude other types of agreement (such as section 278 agreements for highways works) and planning conditions.

A community benefit policy does have the opportunity identify existing routes or points in the foot and cycle network that potentially need improvement should new development arise. It could also do this with “community facilities”, by specifying which facilities the could benefit from development. It is possible that improvements to community facilities could also be funded by the proportion of CIL that the parish will receive from development. It is recommended that this policy Is reworked to highlight specifically where improvement may be needed to village facilities.

It is also recommended that the second sentence of paragraph 4.51 is reworded to more accurately describe how and section 106 contributions and CIL differ. It currently states that section 106 obligations are “supplementary” to CIL and while it is correct that they are a different kind of contribution to CIL, this wording implies that section 106 funding can be used on top of CIL money for specific items of infrastructure or mitigation, which is not the case.

Regulations prohibit the use of Section 106 obligations to fund infrastructure that is already funded by CIL. Section 106 planning obligations are generally used to fund infrastructure which is directly related to development, with CIL generally used to mitigate the cumulative impacts of growth. Regulations apply which ensure development is not charged twice for the same infrastructure.

Policy LM-B4, Allocation of Site for Development: S1, Land Adjacent to Nethergate Brewery at Junction of Borley Road and B1064, Sudbury Road

A map showing the allocated land should accompany this policy, as with other site allocation policies.

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I hope that these comments are helpful. SCC is always willing to discuss issues or queries you may have. Some of these issues may be addressed by the SCC’s Neighbourhood Planning Guidance, which contains information relating to County Council service areas and links to other potentially helpful resources.

The guidance can be accessed here: Suffolk County Council Neighbourhood Planning Guidance.

If there is anything I have raised you would like to discuss, please use my contact information at the top of this letter.

Yours sincerely,

SCC

(1) https://www.healthysuffolk.org.uk/jsna/reports/health-needs-assessments

(2) https://www.cheltenham.gov.uk/download/downloads/id/7045/m4-1328_redrown_appendix_4_backwell-np_examiners-report.pdf

(3) https://www.midsuffolk.gov.uk/planning/neighbourhood-planning/neighbourhood-planning-in-mid-suffolk/stowupland-neighbourhood-plan/

(4) https://www.suffolk.gov.uk/planning-waste-and-environment/planning-and-development-advice/travel-plans/

(5) https://www.rtpi.org.uk/media/2213533/dementia_and_town_planning_final.compressed.pdf

Suffolk County Council – 28/02/19

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Comment from Mr I Russell of Withindale Mill – 28/02/19

There are some points where I think it could be strengthened. In particular I would like to comment on heritage and landscape, housing and business development, green spaces, and the implementation plan.

 

Heritage and Landscape

Paragraph 2.3 is fundamental: “Long Melford lies within the project area that is under review for a possible extension to the Dedham Vale and Stour Valley Area of Outstanding Natural Beauty (AONB)”

I think the NP should support this extension. This is a long term project to preserve part of our national heritage for future generations. It means AONB principles should apply to planning decisions.

The AONB project area does not include Lavenham but the Wool Towns project does. The landscape between Long Melford and Lavenham, much of it in the parish, must be protected as well as the Stour Valley.

The Railway Walk bounds this landscape in Long Melford. The footpaths across the fields between the railway track and the bypass offer superb views of the village and the church. You can see the same view from afar from high ground to the west of Brundon. Insensitive building alongside the railway would destroy not only the views. It would break the integrity of the land which has linked the Stour at Long Melford to Lavenham for time immemorial.

 

Housing and Business Development

While the NP must meet residential housing targets it should also provide for the micro-businesses it aims to foster. Short term pressure to build houses should not be at the expense of business that will help to build the local economy. The NP mentions design in keeping with the village. This could apply equally to micro-business building. Factory built local designs?

 

Green Spaces

I am unaware of the deliberations behind the green space shown on Map 4H. For the reasons above I think all the land between the bypass and the railway track should be hatched green, pending a review. Land to the east of the bypass to be included in the review.

 

Implementation

Re paragraphs 8.12 and 8.13 I think the NP should include a review in the light of the JLP and vice versa. An essential part would be to balance the need for residential housing and micro-business accommodation in Long Melford with employment opportunities in Sudbury, Acton and elsewhere.

During the bypass enquiry years ago BDC agreed an Eastern bypass would service the new businesses they expected to the east, e.g. at Acton. The part the A134 bypass has to play in supporting economic growth in the area remains unresolved.

The decision not proceed with the Sudbury western bypass is important. As a result, residential development that would add to the congestion in Sudbury should be deprecated, the focus should be on sustainable development in the area.

Best regards

Ian Russell

Withindale Mill

Mr Ian Russell – 28/02/19

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Comment from The Hamilton Charity – 28/02/19

Thank you for the opportunity to comment on the above draft plan. I write on behalf of the Hamilton Charity. The Charity is keen to develop some affordable housing in the village for local people. We support the suggested allocation of thirty properties on the Old Allotments site at High Street. We are in touch with Babergh Planning and Housing personnel and also in touch with housing providers to rty and move this scheme forward. Colleagues on the Neighbourhood Planning Team may be aware of the strong representations by Historic England and the constraints that this could place on the site. Our view is that we would want to maximise use of the site to meet local housing need.

I will keep you advised of progress.

Kind regards

Peter Turner.

Trustee/Administrator (The Hamilton Charity)

The Hamilton Charity – 28/02/19

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Comment from Mr P Turner – 28/02/19

I write in a personal capacity. I broadly support the objectives of the draft plan.

I would urge the Council to take a closer look at pedestrian safety, in particular safer home to school routes. The new Kier development may generate some younger families and the need for a safer route to the local primary school.

The Council may wish to pursue the suggestion of a pedestrian refuge near to the junction of Roman Way to encourage pupils and parents to walk to and from school.

The Council may also wish to ensure that the new Bull Lane Housing development provides a safe pedestrian route to connect with existing footpaths towards the village centre. Also Bus Users will need on both sides of the road somewhere safe to wait and ideally the facility of a bus shelter.

On the subject of bus shelters and a desire to encourage greater use of public transport, I would suggest that bus shelters are provided at the most used bus stops. I would advise against seating in the shelter to avoid the risk of them becoming a meeting place. Whilst we live in a comparatively dry part of the country I again make the point that use of public transport should be encouraged.

The village is blessed with a number of local and strategic footpaths however a longer term aim to see a continuous strategic cyle/footway between long Melford and neighbouring towns/villages would be a worthwhile aim. Sadly opportunities were missed when the former railway line was closed.

Kind regards

Peter Turner.

Mr Peter Turner – 28/02/19

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Comment from Suffolk County Council – 07/03/19

(Accepted following request prior to 28/02/19)

 

Dear Long Melford Parish Council,

Pre Submission version of the Long Melford Neighbourhood Plan

Thank you for allowing more time for Suffolk County Council (SCC) to provide information related to the proposals within the Long Melford Neighbourhood Plan. This addendum to our main response provides details of sitespecific information on highway matters and early years provision.

Site Specific Highways Comments

Site G1,Spicers Lane

Spicers Lane is a narrow single track access with no separate footway that serves approximately 10 dwellings, there is access to the footway network and public transport links on the high street and it is considered this will be acceptable for another single dwelling. There is poor visibility for Spicers Lane onto Hall Street due to parked cars and street furniture in the layby, however speeds in this area are generally low. The proposal is within a parking area; If this provision is for existing dwellings or business, then they would need to be accommodated elsewhere.

Sites L1 and A1, Cordell Road

There are existing accesses off Cordell Road. These sites will be suitable the small number of dwellings proposed. Visibility will need to be 2.4m x 43m for the vehicle access on both locations.

Site B1 Borley Road

Borley Road does not have a footway linking the site to the existing footway network and there is very little highway verge to provide a footway. For 18 dwellings, this would not be acceptable in sustainable access terms. In the past 5 years there have been 7 injury accidents on the B1064/Borley Road junction. This junction will need to be investigated and major mitigation provided. It is recommended that the policy requires any planning application address the pedestrian access issue and the potential impacts on the junction.

Site K1, High Street

The site has access to the footway network on high street and has bus stops within walking distance, making this site acceptable from a sustainable transport perspective.

Site F1 Rodbridge Hill

Rodbridge Hill has a footway network on the opposite side of the road to the site, so a crossing point and bus stops will be required along the frontage of this site.

 

Early Years

SCC organise early years capacity by district electoral wards. The only early years setting within the ward is at the primary school. There is some ability to provide capacity at this setting however it is expected that this capacity (12 full time equivalent (FTE) places) will be taken up by children arising from the development already permitted or being built within the ward (132 dwellings). The Neighbourhood Plan growth is expected produce need for an additional 7 FTE places, totalling a need for 19 FTE places when combined with development currently in the planning pipeline.

The appeal site at east of station road for 150 dwellings would also give rise to an additional early years demand of 13 FTE places if granted permission. Combining the currently permitted growth, the neighbourhood plan growth and the appeal site (if permission is granted) would give a total early years need of 32 FTEs.

This gives rise to two possible scenarios.
1. Current permissions + neighbourhood plan growth = 210 dwellings = 19 FTEs early years demand
2. Current permissions + neighbourhood plan growth + east of station road = 360 dwellings = 32 FTEs early years demand

The second scenario is straightforward to resolve as SCC has requested land on the site east of station road for an early years setting, in the event the land east of station road is granted planning permission.

The first scenario is more challenging, as 19 FTEs cannot be accommodated at the primary school settings, and 19 FTEs is also not enough demand to enable a new setting to come forward. It is important to note that early years education is provided by the market, meaning there must be sufficient demand to sustain a setting.

SCC prefer a plan lead approach to development in order to better enable provision to infrastructure and would like to support the Neighbourhood Plan. As such, the following options are presented that the neighbourhood planning group could consider in order to address this potential infrastructure issue.

  • Specifying a dwelling mix which would create lower demand – certain sizes of dwellings, or dwellings aimed at certain demographics, could lower the overall early years demand. This includes homes for older people (such as sheltered housing, extra care housing, or care homes), or dwellings with one bedroom. It is noted a preference for smaller dwellings and bungalows is stated in policy LM-H13, however it is not sufficiently detailed to specify specific dwelling mixes.

  • Introducing site phasing into the plan – site phasing would specify when allocated sites can come forward, effectively staggering when demand arises, so that existing early yeas facilities are able to provide for the demand. It should be noted that that during examination of neighbourhood plans inspectors have not been in favour if this measure, preferring the market to determine when sites should come forward. The Debenham Neighbourhood Plan Submission draft included site phasing, but the inspector recommended removal of this. However it is a possibility if an evidenced case can be made.

  • More site allocations – more allocated housing sites could enable the provision of a new setting, but would also have other impacts such as on the demand for primary school places, and would possibly mean that a repeat of the regulation 14 consultation stage may be necessary. It is also recognised that this option may not be favoured by the community.

     

SCC is would like to engage in discussion with the neighbourhood planning group regarding these issues.If there is anything I have raised you would like to discuss, please use my contact information at the top of this letter.

Yours sincerely,

Cameron Clow
Planning Officer
Growth, Highways, and Infrastructure

Suffolk County Council – 07/03/19 (By special arrangement)

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The consultation period for comments on the Long Melford Neighbourhood Plan ended on 28/02/19.

 

 

 

 

 

 

 

 

 
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