GO-East
GOVERNMENT OFFICE
FOR THE EAST OF ENGLAND
Mr Stephen Andrews
Mid Suffolk District Council
Council Offices
131 High Street
Needham Market
Ipswich
IP6 8DL
Maydo Pitt
Development and Infrastructure
26 November 2009
Our ref
Eastbrook
Shaftesbury Road
Cambridge
CB2 8DF
Tel:
01223 372919
GTN:
3841 2919
Fax:
01223 372862
Internet email:
[email protected]
Website: http://www.goeast.gov.uk
E1/W3520/15/02/01
Dear Mr Andrews,
MID SUFFOLK DISTRICT COUNCIL LOCAL DEVELOPMENT FRAMEWORK
MID SUFFOLK STOWMARKET AREA ACTION PLAN PROPOSED SUBMISSION DPD
1. Thank you for notifying the Government Office of the publication of the Mid Suffolk
Stowmarket Area Action Plan (AAP) Pre-Submission Development Plan Document
(DPD) under Regulation 27 of the Town & Country Planning (Local Development)
(England) (Amendment) Regulations 2008. We welcome the opportunity to comment.
2. We are pleased to note that you have undertaken a Sustainability Appraisal and
Habitats Regulations Assessment and that these documents are included in your
suite of proposed submission documents.
General Comments
3. We welcome the progress you have made on your AAP. However, as discussed with
your colleague, James Bailey, we do have a number of concerns in relation to your
current proposals.
4. As I am sure you are aware, publication under Regulation 27 is not another stage in
the consultation process. Subject to representations on soundness and to any
changes made as a consequence of these and/or the Inspectors Report, your DPD
should read as ready for adoption at this stage. We are unclear of the status of the
various ‘Proposals’ throughout the document and in any case, they appear to
duplicate many policies. Therefore, we suggest that these ‘proposal’ sections are
deleted from the document. We also consider that the Plan period for the AAP, which
should be consistent with the Core Strategy, is not made sufficiently clear. We
therefore consider that, for the avoidance of doubt, the plan period for the AAP
should be clearly stated early on in your document.
5. In our letter of 19 January 2009, in responding to your Issues and Options
consultation document, we questioned the inclusion of numerous policy approaches
where it was unclear why the policy approach was specifically relevant to the AAP
rather than the district as a whole. In our view, there are still a number of
development control style policies where it is unclear why the approach is specifically
relevant to the AAP area and which repeat elements of the Core Strategy (examples
include policies 3, 14, 15, 17, 39) . Therefore, we consider that there appears to be
scope for further editing, both to avoid duplication and in the interests of brevity. We
have not submitted specific representations on these matters, as we do not consider
that they amount to a ‘soundness’ issue, but we would urge you to look again at the
scope for minimising repetitive policy and eliminating superfluous text prior to
finalising your submission document. You will be aware that editorial changes may
be undertaken without the need to re-consult, provided they do not change the
submission document in any substantive way.
6. In relation to saved local plan policies, we are pleased to note that you have
identified which local plan policies will be replaced by the AAP. Please note,
however, that there is no provision for local plan policies to be partially replaced by
DPDs as you have outlined in table 13.4. Moreover, in relation to your proposal for
local plan policy SDA6 to be extended for three years after adoption of the AAP,
please note that there is no provision for this. Local plan policies that are identified as
being replaced by a DPD will be replaced by a DPD on its adoption.
7. In relation to your proposed policies on strategic gaps (policies SAAP19, SAAP21,
SAAP22), you will be aware of the national policy PPS7 in relation to local landscape
designations. Paragraphs 24 and 25 of PPS7 state that carefully drafted, criteria
based policies should provide sufficient protection for locally valued landscapes and
that local landscape designations should only be maintained/extended where it can
be clearly shown that criteria policies cannot provide the necessary protection. We
remind you, therefore, that you will need to ensure you can robustly justify your
approach to strategic gaps.
8. Our more substantive concerns relate to the conformity of the AAP with your adopted
Core Strategy. We deal with these matters in representations set out as an Annex to
this letter, since they potentially bear on the tests of soundness set out in PPS12,
and on compliance of the plan with national and regional policy.
Conclusions
9. There are a number of significant issues briefly set out in this letter and in more detail
in the associated representations which are in need of addressing prior to finalisation
of your AAP submission document. To this end, we look forward to meeting with you
and the Planning Inspectorate to discuss these issues.
Yours sincerely
MAYDO PITT
Cambridgeshire, Norfolk, Suffolk and Peterborough Team
INVESTOR IN PEOPLE
Appendix
Stowmarket AAP Proposed Submission Document – Go-East Representation 1 of 3
Housing Allocations: Policies SAAP 25 Development around Chilton Leys, SAAP 26
The Ashes and SAAP 27 Land off Farriers Road and Poplar Hill
The Government Office notes that policy CS8 of the adopted Core Strategy, as
acknowledged in paragraph 6.3 of the AAP, sets out a requirement for 400 dwellings on
previously-developed land (PDL) from 2010-2025 and 1,040 dwellings on greenfield land
from 2010-2025. We note that the AAP allocates three greenfield housing sites, which, in
combination, have a indicative capacity for 2000 dwellings. We note that the Council’s
rationale for the additional dwelling figures is that the RSS dwelling requirements are a
minimum, rather than ceilings which should not be exceeded. Whilst we would not
necessarily object to such an approach where this is justified and evidenced by local
circumstances, we do have concerns about the Council’s apparent over-reliance on
greenfield housing allocations as opposed to PDL sites and the Council’s evidence base for
such an approach.
We note that, other than the ‘Station Quarter’ site, which is allocated for mixed use including
residential, there are no brownfield allocations included in the AAP. We also acknowledge
the statement in paragraph 6.2 that there will be some opportunities to make use of PDL
sites in the centre of Stowmarket and it appears that a number of these have been identified
within the Council’s Strategic Housing Land Availability Assessment (SHLAA), published in
August 2009. Whilst we have not scrutinised the SHLAA in detail, it would appear that some
PDL sites, that have not been discounted, are available/suitable to be able to count towards
the Core Strategy requirement for 400 dwellings on PDL from 2010-2025. We are therefore
unclear why some of these sites have not been allocated in the AAP and why there is the
need to include all three greenfield site allocations.
On a different but related point, we consider that it is not entirely clear what policies SAAP25
and SAAP26 are intending to allocate. In relation to SAAP25, page 27 of the AAP indicates
that the ‘development around Chilton Leys’ site is a housing allocation. However, the policy
itself states that it is a mixed use site. Therefore, we consider that the AAP needs to resolve
this discrepancy and be much clearer about what proportions of the site are allocated for
particular uses. Similarly, it is not entirely clear what proportion of SAAP26 is allocated for
residential use and open space. We consider that policy SAAP26 should be clearer in this
regard.
INVESTOR IN PEOPLE
Stowmarket AAP Proposed Submission Document – GO East Representation 2 of 3
Policy SAAP37 Stowmarket Business and Enterprise Park
The Government Office notes that the AAP includes a large, greenfield employment land
allocation (Stowmarket Business and Enterprise Park). We note that the Core Strategy (refer
to page 50) states that ‘once the results of the revised Employment Land Review (ELR) have
been received the Council will give consideration to the possibility of the early review of the
employment section of the Core Strategy’. We are aware that the ELR has now been
completed, which, as paragraph 7.42 of the AAP acknowledges, identifies no current need
for additional employment land. In light of this finding and the statement in policy CS11 of the
Core Strategy that ‘major new allocations of employment land should be situated primarily in
or close to towns……and where the location and proposed use is consistent with the revised
Employment Land Review’, we do not consider there to be robust evidence for the inclusion
of the Stowmarket Business and Enterprise Park allocation in the AAP and it appears to be
contrary to the provisions of the adopted Core Strategy.
Similar to the point we raised in our earlier representation, we consider that the AAP needs
to be much clearer in terms of how much employment land it is allocating. We note the
statement in paragraph 7.41 that the total area is approximately 79ha, but that a significant
percentage of this is now proposed for public open space, screening and other nonemployment uses. We are unclear how this statement fits with the statement in policy
SAAP37 that the Site is allocated primarily for B1 and B8 uses and paragraph 6.4 which
indicates that land ‘East – land off Mill Lane’ is an employment allocation. Therefore, we
consider that the AAP needs to resolve this discrepancy and be much clearer about what
proportions of the site are allocated for particular uses.
INVESTOR IN PEOPLE
Stowmarket AAP Proposed Submission Document – GO East Representation 3 of 3
Policy SAAP7 Principal Shopping Area (Primary and Secondary Shopping Frontages)
The Government Office notes that policy SAAP7 includes provision for at least an additional
7000 sqm net non-bulky comparison goods by 2025 and at least an additional 700 sqm of
convenience floorspace by 2025. In our view, the AAP should be clearer about why the
Authority is proposing additional retail floorspace requirements which are above those set
out in the adopted Core Strategy, policy CS12 – Retail Provision.
We would not necessarily object to the inclusion of retail floorspace requirements in addition
to those identified within a Core Strategy where there is robust local evidence to support
such an approach. However, we are not aware of any such evidence in relation to your
proposals. We note that you have undertaken a Retail Monitoring Report (August 2009) but
this does not appear to identify any additional retail floorspace requirements, above those
identified in the Core Strategy. Therefore, we consider that the AAP needs to more clearly
justify the retail floorspace requirements proposed in the AAP.
INVESTOR IN PEOPLE