South Suffolk Labour Submission to Babergh Local Plan Consultation

Babergh and Mid Suffolk Local Plan Consultation Response
November 2017

This response is from South Suffolk Constituency Labour Party. It concerns only
the Babergh local plan. It provides an overall commentary on the proposed plan
and associated Vision for Sudbury, and includes answers to some to the specific
questions in the consultation document.

1. Housing Requirement
As stated in the plan, the population of Babergh is predicted to grow by 8000 (an
increase of roughly 9% on the current number of residents) in the next 20 years.
This figure is also set out in the Suffolk JSNA. The plan also indicates that
average household size is 2.3 people (2011 Census). 28% of households in
Babergh are single occupation (source Suffolk Observatory). The proposed OAN
is for a further 7,820 households. Even assuming a proportional increase in
single person households due to the rise in the elderly population over the next
20 years, it is not clear why the OAN establishes an increase in houses almost
equal to the growth in the number of residents.
We appreciate that the OAN may take into account additional housing pressures
from surrounding districts such as Ipswich. If this is the case, why is this
additional need not reflected in the anticipated increase in population of 8000?
Babergh needs to be clear what figures are being used, how they relate to each
other, and what the implications are for infrastructure (such as schools, roads
and healthcare) as well as housing development. Without this clarity, the
developments in infrastructure required to meet increased population need may
be significantly under-estimated.

2. Housing Type
Questions 19 and 20:
It is very clear, when considering those local neighbourhood plans which are
either complete or in development, and when talking to local residents, that
there is a very high need in the district for smaller and suitable houses for older
people to downsize into, and for younger people to move into, particularly in the
villages (which accommodate more than half of Babergh’s residents). Building
housing stock for older people to downsize could in turn free up, and make more
affordable, housing for younger families to move into. Therefore we support both
options HM2 and HM3 (these are compatible).
Having already stated that Babergh has a higher proportion of 4 bedroom houses
than is usual, the plan states that the majority of housing required will be ‘two,
three and four bedroom houses’. It is highly unlikely that Babergh will deliver
either the numbers of affordable homes needed or the type of homes needed
without a more specific and carefully delineated breakdown of housing
requirements in the plan. We consider that the plan should be prioritising
smaller houses in order to encourage the flow of housing throughout the
generations, in line with option HM2.
Question 22: The Council should continue to set the requirement for affordable
housing at 35%.
Other points:
There is no mention of social or council housing, despite an explicit
acknowledgement in the plan that housing costs in Babergh are typically 9 times
higher than average earnings, and that housing in many rural areas is
‘unaffordable’. An increase in council housing could be a significant step forward
in ensuring that there is sufficient truly affordable housing to enable young
people to stay in the area, a clear priority for the council given the skew of the
population towards older age groups over the next 20 years.
The need for housing for older people to downsize to is much broader than just
the need for sheltered housing. But why, given the expressed need for a
substantial increase in sheltered housing, has Babergh recently decommissioned
its own sheltered housing stock?
There is little in the plan about architecture or housing design, or how good
design can incorporate renewable technologies and promote sustainable energy
use. Whilst we recognise that Babergh needs to accommodate the specific
requirements of conservation areas and the AONBs, the council could take the
opportunity to promote and encourage more environmentally friendly designs
such as pre-fabricated builds. These are not only ‘greener’ but often more
affordable, thus helping the council meet more of its objectives at once.
Question 16: We support the proposal that Babergh adopt the new standards on
Question 17: Babergh should encourage inclusion of well-designed flats. These
could for example be focused on the needs of older people, or help address the
need for homes to rent for younger people. Good quality flats can be both
appealing and environmentally more sustainable than individual houses.

3. Spatial Distribution
We support BHD4 - new settlement focused. A new settlement allows for
thorough and considered investment in infrastructure to create a new
community, and can ensure that the right mix of housing is put in place from the
start, to meet the needs of older and younger residents. Allowing for nearly 35%
of new houses on a new settlement also lessens the likelihood of large
developments being ‘tagged-on’ to existing villages with inadequate attention to
roads, schools and so on. Babergh is relatively rich in land, so a new settlement is
an achievable and desirable option.
We suggest that Raydon airfield should be considered as a potential site for a
new settlement. Development there would take advantage of close links with the
business and retail hub of Hadleigh, and help with overcrowding at East
Bergholt, as well as being close to the A12. Any potential adverse impact on
Capel St Mary (in relation to roads and infrastructure) would need to be clearly
understood and mitigated. However a new settlement could also have the
potential to address some of the road and traffic constraints affecting Hadleigh.

4. Economy: Town Centres and retail
We wish to see thriving town centres, and functional clusters of villages, each
supported by more frequent and more affordable public transport. We would
like to understand what the council has learnt from the Portas review (and other
recent reviews about town centre development), and considers relevant to
Sudbury, Pinewood and Hadleigh. We share the council’s preference that out-ofcentre
development should be restricted, therefore support option OC1.
The plan does not appear to consider the potential impact of Brexit on economic
growth and activity in the district. We appreciate that it is not possible to
calculate the likely impact at present, however the council should acknowledge
the need for ongoing assessment of potential impact in regard to employment,
and consequent flexibility in their approach. Two key areas that could be affected
and that could have an impact on the types of housing required are London
commuting and farming.

5. Environment: Biodiversity
We are aware of very significant concerns by local experts about the impact of
existing local developments on environments rich in biodiversity and the decline
of protected species. Requirements to protect biodiversity should be

6. Infrastructure: Transport
A strategic plan such as this one should provide an opportunity to plan better
public transport links as part of infrastructure developments and to connect
functional clusters and villages to towns. As noted in the Vision for Sudbury,
access to public transport is poor; where buses do exist they are expensive and
often infrequent. The impact of this is felt particularly on younger people (who
may be reliant on public transport for mandatory post-16 education), on older
people (particularly in villages) and on economically disadvantaged residents - a
significant proportion of whom, as the plan notes, live in rural areas. The plan as
it stands, with the possibility that developments could be spread widely
throughout more rural areas of the district, appears very dependent on the car.
There is also a clear assumption that the Western bypass will be built yet there is
no certainty, route or timeframe for this as yet. Building in better public
transport would help Babergh meet its environmental objectives as well as
contributing to healthier lifestyles by promoting walking. We do not consider
that opportunities to develop public transport across the district as part of the
development plan have been given sufficient priority.

7. Deliverability
In recent years, Babergh has approved large volumes of housing (often in the
face of considerable opposition from local residents) yet the number of
completions is staggeringly low. If this trend continues, Babergh will achieve
nothing more than increased anxiety amongst residents and increased profits
from developers banking land. The plan will also be rendered void, leaving the
district vulnerable to national planning policy. This will do nothing to address
the stated housing need.
The recent failures of completion in recent years appear to relate to an inherent
bias in the system nationally towards developers rather than residents. The plan
should therefore set out how Babergh will seek to mitigate the impact of this
bias, and at the same time ensure that its Vision can be realised. For example,
Babergh could propose caps on developers such as the requirement to complete
builds within 2 or 3 years of granting planning permission.
A further gap in the plan is the workforce required to build 355 houses per year
in the Babergh area, particularly post-Brexit. What steps do the council propose,
to ensure that there are sufficient numbers of appropriately skilled workers in
the area to deliver against the plan?

8. The Vision for Sudbury
There are some inconsistencies in the Vision for Sudbury document, principally
to do with the size of the population covered, and whether or not figures for
Great Cornard are included. One page of the document reads more like a political
broadcast than a proposal for promoting investment in local business.
The document suggests that some developments such as the redevelopment of
the Hamilton Road quarter, and revised proposals for the bus station, will take
place in the short to medium term. This suggests that there are options available
for these long standing concerns. If this is the case, there needs to be
transparency and full public engagement on the available options.
The document asks for views on themes and priorities for the town. Some
suggestions, such as developing a brand for the town, and distinguishing
between different zones in the town, seem irrelevant and unlikely to deliver
either economic or environmental benefit, or increased wellbeing for the
population. Our priorities are public services (including better public transport),
and environment. We are opposed to charging for car-parks. We support Option
B, slower evolutionary change, as the least damaging and most sustainable way
of securing long-term benefit to the local population.

We acknowledge the need for an up-to-date plan, and acknowledge the need for
increased housing provision to meet the expected increase in residents over the
next 20 years. However, we do challenge the lack of ambition and leadership in
the plan, and do not think sufficient thought has been put into ensuring that the
plan is actually achievable.
We do not think this plan adequately reflects the changing needs of the existing
and growing population, or accounts for the infrastructure requirements of
either the anticipated number of households or residents. It is also not clear how
the proposals in this Plan relate to other key decisions taken by the council. In
short, the plan appears to be driven more by financial necessity on the part of the
council, and risks prioritising the requirements of developers over the needs of
residents and the local environment. Given recent history of housing being
agreed but not delivered, it is also not at all clear that the proposed housing
numbers are actually achievable.
As has been seen often in recent years, both the council, parish/town councils
and residents lose much time, human and financial resource when proposed
developments are perceived as at odds with the desires and needs of the local
population. A new plan could provide the mandate for Babergh to work in
collaboration with neighbourhoods, not in opposition to them, and for less time
and money to be wasted in the law courts. As it stands, this plan does not
achieve that aim.
A Local Plan can, and should be, about much more than just housing. This plan
sets out housing development with bolt-ons for infrastructure, environment,
economic growth and wellbeing. A truly ambitious and community-focused plan
would integrate all these factors to produce a coherent, sustained and
deliverable vision for kind of community we would all like to be living in for the
next twenty years.
We propose that Babergh work more comprehensively and constructively with
town and parish councils to draw up a revised plan which more fully explores
issues of public transport, environment, and housing churn. A revised plan
should include realistic and deliverable timescales, and reflect the housing need
of existing residents, as well as future population.
1. The council should explain, clearly, the relationship between expected
population growth and housing need.
2. The plan must include council and social housing.
3. In planning for the size and type of housing, the plan should more
explicitly address the need for housing churn across generations and the
impact of this on required housing mix.
4. The council should actively pursue the ‘new settlement’ option. This
should include considering Raydon airfield as a potential site for a new
5. The council should ensure that the plan includes measures to develop
better public transport links between key villages and towns, and set out
how the council, in collaboration with Suffolk County Council, will help
promote better bus services. Alongside this, the council should publish a
timeframe and solution for resolving the siting of the bus shelters/station
in Sudbury.
6. The delivery of a Western Bypass should not be assumed (at least not in
the timeframe of the plan), so alternative options for housing and
industrial growth associated with the possible bypass should be set out in
the plan.
7. The plan should include measures designed to ensure that once planning
permission is approved, dwellings must be completed within a specific
timeframe (we propose 3 years).
8. The plan should include an assessment of workforce capacity in the
district to meet the assessed need.
9. The council should be transparent in dealings regarding long-standing
development proposals in Sudbury, notably the Hamilton Road quarter.
10. The council should indicate what flexibilities will be put in place to ensure
that any future impact of Brexit is assessed and accommodated in the
11. The plan should be more ambitious about the potential to deliver
environmental sustainability alongside new housing, rather than treating
environmental issues as an ‘add-on’ to development. The plan should
include measures to properly protect against depletion of natural
resources, stronger measures to protect biodiversity, and ambitious
targets on energy efficiency.

Emma Bishton
On behalf of South Suffolk Constituency Labour Party

Please check your e-mail for a link to activate your account.