Gladman planning proposal

Gladman Developments Ltd

Land off Church Road,

Stowupland

Mid Suffolk

Planning Statement

December 2014

Land off Church Road, Stowupland Planning Statement

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1 Executive Summary ....................................................................................................... 5

1.1 Context ........................................................................................................................ 5

1.2 Key Benefits of the Scheme ........................................................................................... 5

1.3 Accordance with the Development Plan .......................................................................... 5

1.4 National Planning Policy Framework – Weight to be Accorded to Development Plan Policies 6

1.5 Accordance with the Emerging DPD ............................................................................... 7

1.6 Full Objectively Assessed Housing Need .......................................................................... 7

1.7 Overview ................................................................................................................... 10

1.8 Overall Planning Balance ............................................................................................. 10

2 Introduction ................................................................................................................ 12

2.1 Context ...................................................................................................................... 12

2.2 The Application Submission ......................................................................................... 12

2.3 Community Benefits .................................................................................................... 14

2.4 Structure of the Statement .......................................................................................... 15

3 The Site Location and Context .................................................................................... 17

3.1 A Sustainable Location ................................................................................................ 17

4 Description of the Proposals ....................................................................................... 19

4.1 Introduction ............................................................................................................... 19

4.2 Description of Development ......................................................................................... 19

4.3 The Vision – Design Objectives .................................................................................... 20

4.4 Technical Considerations ............................................................................................. 21

4.5 Deliverability .............................................................................................................. 25

4.6 Section 106 Obligations and Conditions ........................................................................ 26

4.7 Summary ................................................................................................................... 26

5 National Planning Policy Framework .......................................................................... 27

5.1 Introduction ............................................................................................................... 27

5.2 Achieving Sustainable Development ............................................................................. 29

5.3 Promoting Sustainable Transport ................................................................................. 35

5.4 Delivering a Wide Choice of High Quality Homes ........................................................... 36

5.5 Promoting Healthy Communities .................................................................................. 37

5.6 Meeting the Challenge of Climate Change ..................................................................... 38

5.7 Conserving and Enhancing the Natural Environment ...................................................... 38

5.8 Building a strong, competitive economy ........................................................................ 40

5.9 Decision-Taking .......................................................................................................... 40

5.10The Framework Summary ........................................................................................... 40

6 The Development Plan and Emerging Plan ................................................................. 41

6.1 Introduction ............................................................................................................... 41

6.2 Weight to be Accorded to the Development Plan ........................................................... 41

6.3 Mid Suffolk Local Plan 1998 (1992-2006) (Saved Policies) .............................................. 44


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6.4 Relevant Saved Policies of the 1998 Local Plan and 2006 alteration. ................................ 44

6.5 The Mid Suffolk Adopted Core Strategy 2008 (2007-2025) ............................................. 52

6.6 Relevant policies of the Adopted Core Strategy 2008 ..................................................... 52

6.7 Relevant policies of the Adopted Core Strategy Focused Review 2012 ............................. 56

6.8 Relevant policies of the Stowmarket Area Action Plan 2013 ............................................ 58

Emerging Policies ............................................................................................................... 63

Development Plan Summary ............................................................................................... 63

7 Housing Land Need and Supply ................................................................................... 64

7.1 Overview ................................................................................................................... 64

7.2 Current Housing Land Supply Position .......................................................................... 65

7.3 Objectively Assessed Need .......................................................................................... 65

7.4 Previous Housing Delivery ........................................................................................... 70

7.5 Application of the Buffer .............................................................................................. 71

7.6 Housing Land Supply Assessment ................................................................................ 71

8 The Planning Balance .................................................................................................. 73

8.1 Introduction ............................................................................................................... 73

8.2 An Urgent Housing Need ............................................................................................. 73

8.3 Proposed Harm and Benefits of the Development .......................................................... 74

8.4 Compliance with Planning Policy .................................................................................. 75

8.5 Affordable Housing ..................................................................................................... 77

8.6 Accessibility ............................................................................................................... 77

8.7 Green Space .............................................................................................................. 77

8.8 New Homes Bonus ...................................................................................................... 77

8.9 New Employment and Economic Benefits ...................................................................... 78

8.10Summary ................................................................................................................... 78

9 Summary & Conclusions .............................................................................................. 79

9.1 The Application .......................................................................................................... 79

9.2 Vision - The Design Objectives ..................................................................................... 79

9.3 Delivery ..................................................................................................................... 79

9.4 Accordance with the National Planning Policy Framework ............................................... 79

9.5 Development Plan....................................................................................................... 80

9.6 Conclusion ................................................................................................................. 81


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Appendices

Appendix 1: Sustainability Matrix, December 2014 Appendix 2: Delivery Table, December 2014 Appendix 3: Draft S106 Heads of Terms, December 2014 Appendix 4: Proposed Draft Conditions, December 2014 Appendix 5: The Planning Balance, December 2014 Appendix 6: Utilities Appraisal, December 2014 Appendix 7: Affordable Housing Statement, December 2014


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1 EXECUTIVE SUMMARY

1.1 Context

1.1.1 This application seeks Outline Planning Permission for a residential development of up to 190

dwellings (use class C3) with all matters reserved, save for access; incorporating elements of

open space, children’s amenity and associated infrastructure.

1.2 Key Benefits of the Scheme

1.2.1 The application will provide a significant number of material benefits which should be

considered within the determination of this application, which include;

Increasing housing supply to help meet the Council’s immediate housing needs;

Providing a wide choice of quality homes, including affordable housing, meeting

significant and marked contribution that would be a real benefit for which there is a

present need to address;

Provision of 2.84 ha of the Site as public open space. This will offer additional ecological

value, providing a more diverse range of habitats on Site;

Easy access by all modes of transport to all types of service, retail, leisure facilities and

employment opportunities, as well as improvements to nearby bus stops, encouraging

use of public transport;

A contribution to improve footpaths from the Site to the school and to the Post Office.

Existing trees and hedgerows will be maintained wherever possible and enhanced

through additional planting providing a valuable ecological resource, and;

Providing public open space and a children’s equipped area of play to benefit existing

and new residents.

1.3 Accordance with the Development Plan

1.3.1 As outlined in Section 38(6) of the Planning and Compulsory Purchase Act 2004, planning

applications must be determined in accordance with the Development Plan unless material

considerations indicate otherwise. This is confirmed by paragraphs 11 and 12 of the

Framework.

1.3.2 The key issues to determine in the consideration of this planning application are whether;

The development proposals are in accordance with the relevant policies of the adopted

Development Plan, insofar as they apply and the degree of weight that can be

reasonably attributed to them; and


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The assessment of all other material considerations, including the Framework and the

application of the presumption in favour of sustainable development, point towards the

appropriateness of a grant of planning permission in the planning balance.

1.3.3 This application is a departure from the Development Plan as it conflicts with the existing

housing policies. However, housing policies within the Development Plan, as demonstrated

below, are out-of-date for the following reason:

Mid Suffolk District Council (MSDC) cannot demonstrate a five year supply of

deliverable housing and as such policies in relation to the supply of housing are not

considered up-to-date (paragraph 49); and paragraph 14 of the Framework and the

presumption in favour of sustainable development should apply where ‘principle

policies are out-of-date’1

1.3.4 In regards to other policies within the Development Plan, due weight should be afforded to

those policies in accordance to their consistency with the Framework as outlined in paragraph

215. It is demonstrated in this Statement that the proposals accord with other relevant policies

within the Development Plan that are consistent with the Framework.

1.4 National Planning Policy Framework – Weight to be Accorded

to Development Plan Policies

1.4.1 Those policies which do not relate to the supply of housing and are relevant to this application

will be afforded weight in relation to their consistency with the Framework as outlined in

paragraph 215.

1.4.2 The Council cannot demonstrate a five year supply of deliverable housing, as outlined above,

those policies relating to the supply of housing should be considered out-of-date as set out at

paragraph 49 of the Framework. In addition, in line with the Droitwich Spa Inspectors Decision2

the ‘principle policies’ of the development plan are out of date and the presumption in favour

of sustainable development should apply.

1.4.3 As outlined in paragraph 47 of the Framework, Local Planning Authorities must use their

evidence base to ensure their Local Plans meet the full objectively assessed need for market

and affordable housing. Gladman have commissioned independent consultants Regeneris to

1 Droitwich Spa APP/M1840/A/13/2199085 2 Droitwich Spa APP/M1840/A/13/2199085


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assess the full Objectively Assessed Need (OAN) for the District following the guidance set out

in the PPG. Against this OAN, the Council cannot demonstrate a five year housing land supply.

It has also been demonstrated that the Council cannot demonstrate a five year housing land

supply using their own housing target.

1.4.4 Gladman consider that the Council’s adopted housing target does not adequately reflect the

need of the District as outlined in the evidence proposed to inform the OAN (referred to in the

Hourigan Connolly 5 year-supply paper) This means the deficit in housing land supply is much

greater than the Council recognise.

1.4.5 In accordance with paragraph 14 of the Framework where in this instance, policies are out-of-

date, permission should be granted unless any adverse impacts would significantly and

demonstrably outweigh the benefits. It is for the Council to demonstrate the ‘significant gravity’

of harm3 which would outweigh the benefits of the development. It is Gladman’s very that

there are no such significant adverse impacts in this regard.

1.5 Accordance with the Emerging DPD

1.5.1 The Council are currently producing a new joint Site Allocations and Development Management

DPD with Babergh District Council, but it is in the very early stages. As this Plan has only

undergone a scoping exercise on policy topics, providing no planning policy to be assessed, it

can be afforded no weight in line with paragraph 216 of the Framework.

1.6 Full Objectively Assessed Housing Need

1.6.1 The East of England Regional Spatial Strategy (RSS) set out a target of 8,300 dwellings to be

completed in Mid Suffolk in the 20-year period between 2001 and 2021. This equates to a

requirement of 415 dwellings per annum (dpa). In the adopted 2008 Core Strategy, MSDC

state in paragraph 3.40 that:

“The District Council proposes that housing requirements beyond 2021 are estimated on the

basis of a continuation of the same annual rate as that up to 2021 i.e. 415 houses per year.”

1.6.2 Consequently, the Core Strategy projects the annual requirement of 415 dwellings forward to

2025, to take account of the Core Strategy’s 2007-2025 plan period. This results in a

requirement of 9,960 dwellings across the 2001-2025 period (8,300 + 1,660). As the Core

3 Droitwich Spa APP/H1840/A/13/2199085


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Strategy Plan period begins from 2007, the 2,692 dwelling completions between 2001 and

2007 were is removed from the requirement, resulting in a need of 7,268 dwellings for the

plan period 2007-2025.

1.6.3 Annualised, this equates to 404 dpa.

1.6.4 The Ipswich Study Area SHMA Update August 2012, which appears to be the latest SHMA

available, reiterates that MSDC establishes a target of 404 dpa in paragraph 11.2.9. It also

states that in the process of a formal review of the Core Strategy (which manifested as the

December 2012 Core Strategy Focused Review), MSDC planned to increase their general

greenfield housing allocations from 2,140 dwellings to 2,625 dwellings.

1.6.5 Policy FC2 of the Core Strategy Focused Review 2012 indeed sets out this increase in general

greenfield allocations. For the period 2012-2027, there are to be 2,625 dwellings delivered

across Mid Suffolk in greenfield sites. The 485 increase has been directed to the Stowmarket

area as part of the Stowmarket Area Action Plan.

1.6.6 The May 2014 AMR provides the most up-to-date assessment of the Council’s requirement

and 5-year housing land supply. In paragraph 4.16 MSDC again reiterate the annual

requirement is 404 dpa. They identify a shortfall of 61 dwellings from 2007, the beginning of

the adopted 2008 Core Strategy Plan period. In regards to a buffer, MSDC state in paragraph

4.20:

“The GR Warehousing appeal Inspector considered the standard 5% buffer to be appropriate,

based on a past 10 year period, representative of a whole economic cycle rather than the

recent past period of severe economic problems and market down turn.”

1.6.7 As such, MSDC consider a 5% buffer to be appropriate. After applying a 5% buffer to the 5-

year requirement (404 x 5) and 61-dwelling shortfall, MSDC identify a 5-year residual

requirement of 437 dpa. Against their claimed supply figure of 2,422, which incorporates the

new general allocations as part of the Stowmarket Area Action Plan and a windfall allowance,

the Council claim a supply of 5.5 years.

1.6.8 However, from the information in the preceding paragraphs, it is clear that the Council’s

housing requirement is derived from the now-abolished East of England RSS. The evidence

bases used to inform the RSS requirement is significantly out-of-date. MSDC acknowledge

this in the Focused Review, stating in paragraph 4.6:


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“Although the Core Strategy is in conformity with the Regional Spatial Strategy, which is to

be abolished, the Regional Spatial Strategy is not the only basis for establishing future housing

requirements and various other sources have been used as evidence for this update of the

Core Strategy. These include the Stowmarket Masterplan, 2008, Strategic Housing Market

Assessment (SHMA), Ipswich Housing Market Area, November 2008, and updates, and

Strategic Housing Land Availability Assessment (SHLAA) for Mid Suffolk, 2009 and 2010

update.”

1.6.9 Despite using a variety of sources, the majority of these documents are significantly out-of-

date and were produced pre-NPPF. Consequently, MSDC’s adopted requirement is not derived

from up-to-date evidence, nor is it representative of an Objectively Assessed Need (OAN) as

set out by paragraph 47 of the NPPF.

1.6.10 Gladman have commissioned Regeneris to undertake an assessment of housing need in the

Mid Suffolk and Suffolk Coastal Housing Market Area in which Mid Suffolk is a part of. The Mid

Suffolk assessment has demonstrated that the housing need in the District is much higher than

the figure produced in the Council’s own Development Plan Documents (DPDs). Based on a

number of economic forecasts Gladman believe the full Objectively Assessed Need for MSDC is

484 dpa (2012-2027), the Council believe their housing requirement to be 404 dpa.

1.6.11 The evidence produced on behalf of Gladman is robust and follows the guidance outlined within

the PPG. This evidence has also been through a peer review process. The Council’s evidence is

demonstrably deficient which will lead to a false premise in which to set out the five year

housing land requirement and ultimately the supply.

1.6.12 When the housing land supply is assessed by Regeneris’ OAN against previous back log and

past delivery with the inclusion of a 5% buffer applied to both the requirement and shortfall,

MSDC can only demonstrate a 3.29 year’s supply of housing.

1.6.13 The guidance provided in the Planning Practice Guidance (PPG) states:

“Where evidence in Local Plans has become outdated and policies in emerging plans

are not yet capable of carrying sufficient weight, information provided in the latest full

assessment of housing needs should be considered.”

1.6.14 The circumstances as outlined within this section of the PPG apply to this application.

1.6.15 The extent of this housing shortfall in regards to the full Objectively Assessed Need identified

by Gladman in the context of the principle policies which are not up-to-date is an important


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significant material consideration that should weigh heavily in favour of the proposals.

Paragraph 14 of the Framework and the presumption in favour of sustainable development

applies.

1.7 Overview

1.7.1 With regards to the above, the following factors have been established in respect of the

proposals:

The proposals will deliver market housing where there is an identified need;

The proposals will deliver much needed affordable housing 25% on-Site, with a sum

of money for 15% off-Site provision. This is 5% more than the 35% requirement of

Mid Suffolk. Gladman consider the additional percentage of affordable dwellings to be

provided must carry very substantial weight;

MSDC cannot demonstrate a five year supply of deliverable housing, and on inspection

by Gladman, the housing land supply is significantly under the five years required by

the Framework at only 3.29 years;

Gladman have established that the full Objectively Assessed Need of Mid Suffolk is 484

dpa, not 404 dpa as expressed by the Council;

The emerging Site Allocations and Development Management DPD cannot be afforded

any weight given that it does not provide any policies in which to assess against and;

The application accords with the Framework and the 3 dimensions of sustainable

development, and for that reason and the demonstrable lack of a housing land supply

and out-of-date principle policies, the presumption in favour of sustainable

development is engaged as outlined in paragraph 14 of the Framework.

1.8 Overall Planning Balance

1.8.1 As outlined in Section 38(6) of the Planning and Compulsory Purchase Act 2004 planning

applications must be determined in accordance with the Development Plan unless material

considerations indicate otherwise. This is confirmed by paragraphs 11 and 12 of the

Framework.

1.8.2 The application accords with the Framework. Policies in relation to the supply of housing are

out-of-date. Notwithstanding this, by virtue of the summary assessment above, the

presumption in favour of sustainable development contained within the Framework applies to

the proposals. Whilst it is for the Council to demonstrate harm, Gladman has undertaken this

assessment.


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1.8.3 There is no harm that arises as a consequence of the proposal that significantly and

demonstrably outweigh the benefits of the proposals when assessed against the policies within

the Framework.

1.8.4 As there are no significant material considerations that outweigh the technical non-compliance

with the out-of-date housing policies in the Development Plan, in these circumstances, and in

accordance with section 38(6) of the Planning and Compulsory Purchase Act 2004, planning

permission should be granted by virtue of the material considerations in favour of this

application.


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2 INTRODUCTION

2.1 Context

2.1.1 This Supporting Planning Statement is submitted to Mid Suffolk District Council (MSDC) on

behalf of Gladman Developments Ltd (hereafter referred to as ‘Gladman’), in support of a

planning application for Outline Planning Permission for Residential Development of up to 190

dwellings (Use Class C3) with all matters reserved, save for access, on land off Church Road,

Stowupland.

2.1.2 The application Site (hereafter referred to as the ‘Site’) comprises an area of land which

extends in its entirety to 10.90 hectares (ha), the edge red boundary of the Site is detailed

on the Location Plan submitted with the application.

2.1.3 The proposal responds directly to the need to significantly boost the supply of housing in

MSDC and in particular the proposal will help support the growth of Stowupland, helping to

sustain and build a sustainable community. This is supported by the case presented in the

Sustainability Report by Rural Solutions submitted with the application. The proposals will also

provide additional community facilities for the benefit of new and existing residents.

2.1.4 The indicative Framework Plan produced by FPCR demonstrates how the Site will deliver a

high quality residential development that will integrate well with the existing neighbourhood

and will be sensitively assimilated into the existing landscape.

2.2 The Application Submission


dwellings with all matters reserved, save for access. An indicative Framework Plan is provided

and an indicative Masterplan is provided within the Design and Access Statement (D&A) that

illustrates how the Site could be developed and demonstrates an appropriate development

capacity linked to density, they are not for determination at this stage.

2.2.2 A request for the application to be ‘Screened’ for the purposes of an Environmental Impact

Assessment (EIA) has been sent by letter dated 18th November 2014. Gladman allowed MSDC

an extension to determine this request. The Screening Request concluded that the proposed

development would not have a significant impact on the environment necessitating an EIA.

On the 18th December 2014, MSDC determined an EIA was not required.


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2.2.3 The application comprises:

Residential development of up to 190 dwellings at a net development of 26 dph, to

contribute to the identified need;

Two vehicular accesses; one off Church Road and the other off Gipping Road;

New recreational provision including; public and informal open space and a proposed

children’s play area;

New structure landscaping including trees and vegetation to create attractive informal

public open spaces and street scenes;

Retention of existing trees and hedgerows on Site;

Improvements to Public Rights of Way (PROWs) and;

Improvements to bus stops, providing new shelters, seating and Real-Time

Information (RTI)

2.2.4 The purpose of this Statement is to detail the application proposals: examine the Site and

surroundings; review the planning policy framework and relevant material considerations;

identify key benefits of the application and draw conclusions as to the Site’s suitability for the

proposed residential development. The National Planning Policy Framework - is hereafter

referred to as ‘the Framework’ and the National Planning Practice Guidance – is hereafter

referred to as the ‘PPG’.

2.2.5 Detailed research and investigations have been carried out by a professional team of

consultants on behalf of Gladman. The application submission comprises the plans and

documents listed in Table 1 below. The submission is entirely in line with the Department for

Communities and Local Government’s validation requirements set out within the PPG.

Table 1: Planning Application Submission Documents and Plans

Document/Plan Author/Date

1 Application Covering letter

Application Form and Certificates

Gladman

2 Location Plan (including Application Red Line) FPCR

3 Topographical Survey JLP Services Limited, August 2014

4 Development Framework Plan FPCR, December 2014

5 Design and Access Statement FPCR, December 2014

6 Landscape & Visual Impact Appraisal FPCR, December 2014

7 Transport Assessment Hydrock, October 2014

8 Framework Travel Plan Hydrock, December 2014

9 Phase 1 Environmental Report Enzygo, October 2014


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10 Flood Risk Assessment (FRA) and Drainage

Strategy

Enzygo, December 2014

11 N/A N/A

12 Soils and Agricultural Use & Quality Report Land Research Associates,

November 2014

13 Air Quality Screening Report Wardell Armstrong, October 2014

14 Noise Screening Report Wardell Armstrong, October 2014

15 Arboricultural Assessment FPCR, October 2014

16 Ecological Appraisals FPCR, December 2014

17 Archaeological Desk-Based Assessment and

Heritage Statement

CgMs, December 2014

18 Planning Statement Gladman, December 2014

19 Statement of Community Involvement Gladman, December 2014

20 N/A N/A

21 Statement of Community Involvement Gladman, December 2014

22 Socio-Economic Impact Report Regeneris, December 2014

23 Foul Drainage Analysis ULS, November 2014

24 Housing Land Supply Assessment Hourigan Connolly, December

2014

2.3 Community Benefits

2.3.1 The development of the Site has the potential to create a number of significant benefits for

the local community and surrounding area. These benefits would arise both as a direct and

indirect result of the development of the Site.

New Homes Bonus

2.3.2 The Government introduced the New Homes Bonus in April 2011 and will match the additional

Council Tax raised for each new property built (with an additional amount for affordable

homes) for the following 6 years.

2.3.3 The New Homes Bonus sits alongside the existing planning framework for making planning

decisions. Local Planning Authorities will continue to be bound by their obligations under

planning law and in particular the New Homes Bonus (NHB) is not intended to encourage

housing development which would otherwise be inappropriate.

2.3.4 The proposed development of the Site has the potential to generate in the region of £1.4

million over the course of 6 years. The bonus is an important source of funding for investment


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in local infrastructure and facilities; the Council can consult with the local community how

best to spend the funds.

New Employment and Economic Benefits

2.3.5 It is widely acknowledged that residential development has the ability to contribute to job

creation through the development and investment in infrastructure. Additionally, there are

lasting benefits associated with a new residential development relating to the new resident

population, the household expenditure in the area and its contribution to the size and depth

of the local labour force. Gladman have produced a socio-economic report which predicts the

total construction costs to be in the region of £22 million which in turn would support

approximately 400 jobs over the 5-year construction period, at an average of 80 full time

equivalent (FTE) per year.

2.3.6 It is estimated that the total expenditure generated by the new households would reach a

total of £1.3 million per annum in the wider District. Thus providing a boost to the local

shopping area and the District in turn contributing to the areas long term economic and social

sustainability.

2.3.7 Furthermore, once completed the development could attract skilled and well educated people,

therefore benefitting local employers.

Affordable Housing

2.3.8 The application seeks approval for up to 190 new homes; the current Council requirement for

affordable housing is 35%, thus an expectation of up to 67 affordable homes. For this

proposal, Gladman are proposing 25% on-Site affordable housing provision and a monetary

contribution for 15% of affordable homes off-Site. In total, this provides for 40% affordable

housing provision (76 units), exceeding the MSDC’s requirement by 5%. According to MSDC,

there is a preference for 75% social rented housing and 25% low-cost home ownership, based

on previous SHMAs and District Housing Need Surveys. Appendix 7 covers this is more detail.

2.4 Structure of the Statement

2.4.1 The remainder of this Statement is structured as follows:-

Chapter 3 - The Site Location and Context (a more detailed description and analysis

of the Site and its surroundings is contained within the accompanying D&A and Landscape

& Visual Impact Appraisal);


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Chapter 4 – Description of The Application Proposals – this Chapter provides a more

detailed explanation of the proposed uses, for which planning permission is sought and the

technical considerations;

Chapter 5 - National Planning Policy Framework, this Chapter identifies the basis for

consideration of the application, reviews the Framework and the PPG;

Chapter 6 - The Development Plan, this Chapter identifies the key Development Plan

polices of relevance to the application;

Chapter 7- Housing Land Need and Supply; this Chapter will demonstrate MSDC do

not have a current deliverable five year housing land supply;

Chapter 8 - The Planning Balance, this Chapter identifies the key issues which relate

to the proposed development and sets out the overall planning case for the development;

and,

Chapter 9 - Summary & Conclusions, this Chapter summarises why planning

permission should be granted.

2.4.2 The following Chapter considers the suitability of the Site’s location and context for the

proposed development.


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3 THE SITE LOCATION AND CONTEXT

3.1 A Sustainable Location

3.1.1 The Site is located within the administrative area of MSDC, within the Parish of Stowupland.

The latest Census data for Stowupland in 2011 identifies a population of 1,748.4

3.1.2 The Site is shown edge red on the Location Plan submitted with the application. In its entirety

it extends to 10.90 hectares (ha) and is currently in use as agricultural land predominately.

3.1.3 The Site lies between Gipping Road and Church Road, adjoining the existing residential

development to the north west and south west. A public footpath runs along a portion of the

western boundary, through the centre of the Site and continues south the eastern boundary.

3.1.4 The topography of the Site is fairly consistent throughout. The Site elevation is approximately

50m OD through the southern and centre portions of the Site. There is a very minor downward

gradient from the north east to south west throughout.

3.1.5 Paragraph 4.8.1 within the Transport Assessment (TA) identifies the location of the existing

bus stops which are within a 100m catchment of the Site boundary and approximately 400-

500m from the Site’s centre, located on Gipping Road and Reeds Way.

3.1.6 The number 387 bus service, located on Gipping Road in close proximity to the Site, operates

at a frequency service of 12 buses a day between Monday-Friday and 10 buses on Saturday.

This service takes a circular route through Stowupland, into Stowmarket and back again.

Between Monday and Friday, the first service from the stop on Reeds Way is at 06:55, with

subsequent services approximately once an hour. The last service leaves Stowmarket at

16:35, with stops in Stowupland by request only. The journey time between Stowupland and

Stowmarket on this service is approximately 20 minutes. When the bus stops at Bury Street

in Stowmarket, it is approximately a 950m (4 min) walk to Stowmarket Train Station.

3.1.7 Manual for Streets 5 suggests residential neighbourhoods should be around 800 metres (or

ten minutes) walking distance, of a range of facilities, all be it the 800 metres is not an upper

limit and it quotes the now withdrawn Planning Policy Guidance 13, Transport (PPG13) in

stating that walking offers’… the greatest potential…’ to replace car trips of under 2

kilometres.

4 Neighbourhood.statistics.gov.uk 5 Manual for Streets HMSO, 2007


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3.1.8 There is a small Co-Op located on Church Road which is approximately 1km walking distance

from the centre of the Site, which sells bread. A butchery/farm shop with a Post Office is

located approximately 800m walking distance from the centre of the Site, with a free bus

service to it along Gipping Road twice a week. This shop sells a variety of meat products, as

well as eggs and milk. Larger supermarkets such as ASDA and Tesco are located in nearby

Stowmarket, easily accessible by the 387 circular bus service between Stowupland and

Stowmarket.

3.1.9 Freeman Community Primary School is located adjacent to the Site off Church Road.

Stowupland High School is located further south west of the Site, also accessible off Church

Road. A full Sustainability Matrix is enclosed at Appendix 1 which identifies nearby facilities

to the Site in more detail.

3.1.10 Stowhealth Surgery and Combs Ford Surgery, both in Stowmarket, are accessible by bus from

Stowupland using the Number 387 circular service. There is a bus stop just outside Comb’s

Ford Surgery, but Stowhealth surgery requires a short 600m (6min) walk from Bury Street.

These surgeries are currently accepting new patients. Station View Dental Practice and Bury

House Dental Practice in Stowmarket are accepting new NHS patients. Wedgeworth House

Dental Practice, also in Stowmarket, will be accepting new NHS patients after Christmas.

3.1.11 Gladman consider the application proposals meet the aspirations of Manual for Streets and

based on the Site’s location and access to services and facilities is highly sustainable.

3.1.12 Gladman sought to engage with officers prior to the application submission, details of which

are included in the Statement of Community Involvement. Whilst officers at the time did not

consider they could support a residential development on the site for approximately 200

dwellings, at the same time officers advised they would give consideration to a smaller

residential scheme of approximately 50 dwellings. This is ultimately an acknowledgement

from the officer that the site is considered physically suitable for residential development and

thus sustainable.

3.1.13 Overall, Gladman consider the Site is physically suited to the proposed residential

development due to its context and location.


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4 DESCRIPTION OF THE PROPOSALS

4.1 Introduction

4.1.1 This Chapter outlines the key characteristics of the application proposals. It outlines the

design objectives and the delivery of the proposed development.

4.2 Description of Development

4.2.1 The application seeks Outline Planning Permission for a residential development. The full

description of development is set out below;

“Proposed construction of up to 190 new dwellings (Use Class C3) with access and associated

infrastructure.”

4.2.2 The proposed development, as depicted on the indicative Framework Plan, has been informed

by the detailed Site investigations and technical studies which are referred to in Chapter 2 of

this Statement and the feedback obtained by way of the community consultation.

4.2.3 The public consultation exercise undertaken by Gladman during the evaluation and

preparation of this application is detailed in full in the Statement of Community Involvement

(SCI). Details of the consultation and the way in which the submitted proposal responds to

the comments received are set out within the SCI.

4.2.4 The indicative Framework Plan enclosed has been prepared to indicate how the parameters

of the proposed development on the Site can be accommodated. This Plan depicts the

landscape zones and development parcels and indicates how up to 190 homes could be

carefully master-planned with open space, children’s play and significant landscaping at the

Reserved Matters stage. This would (across the gross Site area) result in a density of between

26 dwellings per hectare. The Framework Plan can accommodate a mix of terraced, semi-

detached and detached properties, thus reflecting the local need as discussed in the Rural

Solutions report accompanying this application. The Plan allows sufficient flexibility at the

detailed design stage for a house builder(s) to plan the layout in line with market demand

and local need for particular houses. The application also includes for the provision of 25%

affordable housing on-Site and 15% off-Site.

4.2.5 The Framework Plan allows for the majority of existing trees found along the boundaries of

the Site to be retained. Open space will be provided throughout the Site to ensure it is

accessible by all new and existing residents. The Plan also demonstrates that there will be

landscape buffering along the west and eastern boundaries of the Site.


20

4.2.6 The Framework Plan illustrates one possible option for the Site, taking account of

infrastructure requirements, open space provision, adjoining land uses, Site constraints and

the community consultation. Details of the evolution of the layout are set out in the D&A.

4.3 The Vision – Design Objectives

4.3.1 The accompanying D&A to this application demonstrates that the proposals are based on

sound design principles that have properly had regard to and addressed the Site context,

including its opportunities and constraints. Principal consideration has been given to the

existing residential areas along the north west and south west boundaries, as well as

considering the PROW running along the west of the Site from the north, through the centre

and then down along the eastern boundary by including a green space in the centre to create

a buffer between the proposed development and the PROW. Consideration has also been

given to existing connections to the surrounding residential area.

4.3.2 The D&A addresses the amount of development proposed for the Site, layout and proposed

hierarchy of built form across the Site, and the composition of the scheme within the existing

and proposed landscape framework.

4.3.3 The overarching objectives of the Framework Plan are to provide a good mix of housing sizes

and tenures within a high quality residential environment which responds to the adjoining

existing uses.

4.3.4 Careful consideration has been given to the provision of public open space within the scheme

to ensure that the scheme can be assimilated into the existing landscape and be connected

to the existing community. The Site exceeds the policy requirement in terms of public open

space for the area. The location of the formal recreation area is aimed at providing a central

‘hub’ for new and existing residents to use as well as a section of open space to the south

east to provide a buffer to the existing pylon line. Extensive areas of new landscape buffering

will also be provided to screen the views of the development from the surrounding residential

development in line with recommendations of the Landscape and Visual Impact Appraisal

(LVIA).

4.3.5 Whilst not for determination now, the Indicative Masterplan, found in the accompanying D&A,

demonstrates that the development could create a high quality and pleasant residential

environment that will be a desirable place to live, thus in turn attracting new residents to the

area to the benefit of local employers and to aid the encouragement of new businesses to

the area.


21

4.3.6 The proposals will improve the permeability to the surrounding area with the inclusion of

connections into the PROWs along the eastern and western boundaries of the Site.

4.4 Technical Considerations

4.4.1 A suite of technical reports have been prepared in support of the application. These

collectively assess any Site constraints and identify potential opportunities and thus the

creation of benefits arising from the development, which in turn have informed and influenced

the Framework Plan and Indicative Masterplan.

Ecology and Arboriculture

4.4.2 The Ecological Appraisal and survey work submitted with the application identify the Site is

within 2km and the Impact Risk Zone (IRZ) of the Gipping Great Wood Site of Special Scientific

Interest (SSSI), designated as such by Natural England due to being an ancient coppice-with-

standards wood. Ancient woodland can be adversely affected by increased visitor pressure

that could arise from the proposed development. However, the Ecological Appraisal has set

out that because there are no formal routes of access to the SSSI from the Site (for example,

PROWs and on private land), the alternative routes via farm tracks are between 2km and 4km

walking distance and because the proposal makes provision for a significant amount of Public

Open Space (POS) and landscaped areas, the SSSI is unlikely to be subject to any increases

in visitation arising from the development. Therefore it is not anticipated that there will be

any adverse effects on the SSSI.

4.4.3 A number of Phase 1 habitat field surveys for bats, breeding birds, amphibians and reptiles

have also been undertaken on the Site. The survey works concluded that the trees on the

Site provide little bat roosting potential. The habitats within the Site have limited value for

the local bat population and consequently it is unlikely they will be negatively affected by the

development proposal.

4.4.4 The Framework Plan provides for the retention of considerable areas of trees and hedgerows

across the Site, consequently, it is unlikely that the proposed development will have a

significantly adverse impact upon hedgerow habitat in the vicinity. These have been identified

on the retention plan accompanying the Arboricultural Assessment.

4.4.5 Where accessible ponds have been surveyed for the presence of Great Crested Newts (GCN),

the surveys have so far found that there is limited presence and potential for Great Crested

Newts on the Site. The presence of the existing population of GCN would not cause a

constraint to the development.


22

4.4.6 Consequently, there are no ecological or arboricultural constraints preventing the Site coming

forward for residential development, as concluded by the Ecological Appraisal, the

supplementary GCN Survey Report and Arboricultural Assessment.

Flood Risk and Drainage

4.4.7 The Environment Agency map and Flood Risk Assessment (FRA) confirms the Site is located

within Flood Zone 1 (low risk). This is land designated as having less than 0.1% annual

probability of flooding from rivers or the sea in any year (less than a 1 in 1,000 annual

probability of flooding). The FRA submitted with the application confirms the Site is not at risk

from flooding from external sources. A FRA has been submitted by virtue of the fact that the

Site area is in excess of 1ha.

4.4.8 The surface water drainage plan proposes to mimic the existing greenfield run-off rates plus

30% storage to take account of future climate change, in line with the Environment Agency’s

recommendations. A Sustainable Drainage System (SuDS) will be incorporated into the Site,

with various possible scenarios set out in the FRA.

4.4.9 There are no flood constraints, or surface water matters, preventing the Site coming forward

for residential development.

Archaeology

4.4.10 The Archaeological Desk-based Assessment by CgMs has established there may be a former

Medieval/Post- Medieval moated farmstead located in the north-west of the Site, which may

at most be of local importance.

4.4.11 The assessment concludes that it is likely that further archaeological assessment of the

potential area of archaeological interest will be required by the Suffolk County Council

Archaeological Officer, in their role as archaeological advisor to the Mid Suffolk District

Council. In the first instance this could comprise a geophysical survey of that part of the site

considered to have some archaeological interest and, if present, any archaeological features

could be targeted by trial trenching.

Ground Investigation

4.4.12 A Phase 1 Environmental Report has been undertaken to assess the ground-based hazards

which might affect development of the Site.

4.4.13 The Report has established that the overall risk from land contamination is very low to low

for the both current development and the re-development of the Site. This would need to be

confirmed by appropriate intrusive investigations, testing and assessment of the results of


23

the investigation. This is not unusual, therefore Gladman is willing to accept a condition that

requires the submission of this material.

4.4.14 There are no ground investigation matters preventing development of the Site for the

proposed use.

Landscape and Visual Impact

4.4.15 The LVIA submitted with the application details that the Site lies within the local landscape

character area of South Suffolk and North Essex Clayland (National Character Area Profile No.

86).

4.4.16 It is considered at this stage that the Site would have a low-medium landscape sensitivity to

change, due to the relatively well-contained nature of the Site, the existing urban fabric,

topography and established vegetation cover.

4.4.17 The Appraisal finds that the proposed development would represent a landscape impact to

the existing land, mainly due to the loss of greenfield agricultural land to developed residential

land and vehicular/pedestrian/cycle routes. However, the impact of these can be offset by

the proposed retention and enhancement of the field boundaries, hedgerows, trees, the

existing Site topography and the addition of new green infrastructure.

4.4.18 The proposals will mitigate any visual effects by retaining and incorporating landscape

elements into the proposed development to enhance existing landscape character. The

proposed development is typical of the surrounding area as the Site adjoins existing

residential development. The proposed development is of a similar topography to the

surrounding area as such the proposals will not break the skyline visually.

4.4.19 The Appraisal considers the Site has the potential to accommodate a well-planned residential

development without causing significant harm to the wider settlement or local landscape

context. The scale and size of the development would be in keeping with the existing

residential character at the edge of Stowupland. The vast majority of properties within

Stowupland and the surrounding landscape will be screened from the proposed development

by intervening buildings, landform and/or trees and hedgerows.

4.4.20 On this basis there are no defensible reasons for refusal with reference to landscape matters.

Trees

4.4.21 A detailed Arboricultural Assessment has been undertaken on the Site. This Assessment

confirms a small group of trees and small sections of hedgerows are required to be removed


24

to provide the main access roads for the Site from both Gipping Road and Church Road. Other

smaller sections will be required to be removed to facilitate development of this Site, as

detailed in Figure 3 of the Assessment. However, the majority of trees and hedgerows will be

retained, and in addition proposed new tree planting as part of the landscaping for the

development is proposed. The additional tree planting will increase the over canopy across

the Site.

4.4.22 The Assessment confirms the existing trees do not offer a constraint to the development of

the Site and will be incorporated into the detailed design wherever possible. It is considered

the proposed development is sound in regards to arboriculture with the majority of the

existing trees being retained.

4.4.23 There are therefore no arboricultural reasons preventing the development of this Site for the

proposed use.

Highways

4.4.24 The TA submitted with the application confirms the Site has good accessibility by different

modes of transport. This is further enhanced by the connectivity of the Site to the surrounding

area, such as improved links to the PROWs located along the eastern and western boundaries

of the Site.

4.4.25 Two access points are proposed into the Site, one from Gipping Road and one from Church

Road. The proposed Site access arrangement can be found at figures 3.1, 3.2 and 3.3 of the

TA. Comprehensive modelling of the Site access junctions has demonstrated that they would

operate within capacity and would adequately accommodate the development proposals.

4.4.26 The TA concludes that the proposed development is acceptable in highways and

transportation terms and there are no transportation/highways reasons for refusal of the

planning application.

Noise

4.4.27 A Noise Screening Report has been submitted with the application. It is considered that any

potential noise sources are not likely to have a significant impact on the proposed residential

development. It is therefore considered that a suitable and commensurate level of protection

against noise will be provided to the occupants of the proposed accommodation

4.4.28 There are no reasons for refusal based on noise grounds.


25

Air Quality

4.4.29 The Site is not located within an Air Quality Management Area (AQMA) which suggests that

relevant air quality objectives are not close to the national target values. Therefore it is not

considered the impact of the proposals are likely to be significant and no further work is

necessary.

4.4.30 There are no reasons for refusal based on air quality grounds.

4.5 Deliverability

4.5.1 Gladman have a legal agreement with the landowners to dispose of the Site following the

grant of planning permission, there are therefore no landownership constraints preventing

the development of the land.

4.5.2 The Application is therefore submitted with the highest degree of commitment from Gladman

to the delivery of housing on the Site in the short term. Through engagement of the

application process Gladman have undertaken a viability appraisal based upon the Framework

Plan, up to 190 homes and 25% affordable housing (and a contribution for 15% off-Site

provision) and subject to reasonable CIL compliant S106 requirements, are confident the

development of the Site is viable.

4.5.3 The development of market dwellings will be delivered by private housebuilder(s), with

affordable housing either provided by or in partnership with a Registered Provider (RP) (if on

Site). Following a grant of consent, the Site would be marketed immediately and sold as

expeditiously as possible to one or more housebuilders who would submit the requisite

Reserved Matters application(s). A summary of Gladman’s delivery achievements is enclosed

as Appendix 2.

4.5.4 There are no technical constraints to the Site’s delivery and the Site is demonstrably suitable,

available and achievable and therefore wholly deliverable in the short term. In line with the

requirements as set out in the Framework6. The Site is available now, it offers a suitable

location for development now and is achievable with (as set out above) a realistic prospect

that housing will be delivered on the Site within five years and the Site is viable (subject to

reasonable S106 requirements).

4.5.5 It is likely that, subject to market conditions, on average around 20-40 market dwellings per

annum per housebuilder would be completed with the Site. The affordable housing often

takes place simultaneously (as required by Planning Condition or Section 106 Agreement)

6 NPPF, 2012, footnote 11


26

alongside the market dwelling completions. Taking into account infrastructure delivery it is

anticipated that the development of the Site would take in the order of 4-5 years to complete.

4.6 Section 106 Obligations and Conditions

4.6.1 A Draft S106 Heads of Terms is submitted with the application (Appendix 3). The

consultation process will identify in greater detail the requested S106 requirements, which

meet the statutory tests set out in Regulation 122 of the Community Infrastructure Levy

Regulations 2010. The PPG identifies that it can be good practice to submit information about

a proposed planning obligation alongside an application, it should not normally be a

requirement for validation of a planning application7.

4.6.2 Appendix 4 includes a list of suggested appropriate draft conditions.

4.7 Summary

4.7.1 In summary, the Site seeks residential development for up to 190 new homes with areas of

open space, a children’s play area and landscaping. The Site’s location offers both convenient

walking and cycling links to the surrounding area with bus links for potential future residents

of the development to a full range of amenity, shopping and employment options within

Stowmarket. The Site adjoins other appropriate built development (residential) along the

north west and south western boundaries.

4.7.2 Gladman has provided a comprehensive application submission, there are no known technical

reasons preventing the approval of the application. The Site can be accessed from both

Church Road and Gipping Road, with a number of pedestrian/cycle connection points to allow

ease of movement between existing and new residents. The Site is able to connect to utility

providers, it has limited ecological features which the application proposals will seek to

enhance and a suitably-designed scheme is considered acceptable to the character of the

landscape which, through mitigation, would not result in any undue harm.

7 NPPG, 2014 ID 14‐042‐20140306


27

5 NATIONAL PLANNING POLICY FRAMEWORK

5.1 Introduction

5.1.1 This Chapter considers the application proposals in compliance with the Framework.

5.1.2 Paragraph 196 of the Framework reiterates Section 38(6) of the Planning and Compulsory

Purchase Act 2004 which requires all applications to be determined in accordance with the

Development Plan unless there are material considerations which indicate otherwise.

5.1.3 The Development Plan for the area is considered in the next Chapter in detail; however the

Framework is of primary relevance which is a significant material consideration in the

determination of this application and is considered first and foremost.

5.1.4 The PPG reinforces the importance of the Framework as representing the most up-to date

Government planning policy, which must be taken into account where it is relevant to a

planning application. In particular the Guidance states that if decision-makers choose not

to follow the Framework, (Gladman emphasis) clear and convincing reasons for doing so

are needed.

5.1.5 The Government published and brought into force the Framework on 27 March 2012 following

an extensive period of consultation and revision. Its aim was to integrate the previous suite

of Planning Policy Statements, Circulars, Ministerial Statements and guidance notes as well

as a raft of ‘Letters to Chief Planning Officers’ into a single concise document.

5.1.6 At paragraph 1, the introduction to the Framework states:

“The National Planning Policy Framework sets out the Government’s planning policies

for England and how these are expected to be applied. It sets out the Government’s

requirements for the planning system only to the extent that it is relevant,

proportionate and necessary to do so.”

5.1.7 The Framework at paragraph 49 stipulates relevant policies for the supply of housing should

not be considered up-to-date if the Local Planning Authority cannot demonstrate a five-year

supply of deliverable housing sites, therefore the presumption in favour of sustainable

development should apply. This is discussed in detail in the following Chapter.

5.1.8 In addition, the Framework at paragraph 215 advocates that, following March 2013, only due

weight should be given to relevant polices in a Local Plan according to their degree of

consistency with the Framework.


28

5.1.9 Gladman consider the Council cannot demonstrate a deliverable 5 year deliverable housing

land supply. Gladman’s case to support this is set out in detail in Chapters 6 and 7.

5.1.10 In paragraph 14 of the Framework, the presumption in favour of sustainable development is

identified as being at the heart of the Framework. In situations such as this where the Council

cannot demonstrate a 5 year deliverable housing supply or, as addressed earlier, where the

Council’s Development Plan is out-of-date by virtue of the fact that the policies are time-

expired and the fact that the ‘principle policies’ are not Framework-compliant and therefore

out-of-date, the presumption in favour of sustainable development should be engaged:

“At the heart of the National Planning Policy Framework is a presumption in favour of

sustainable development, which should be seen as a golden thread running through

both plan-making and decision-taking.

For decision-taking this means:

approving development proposals that accord with the development plan

without delay; and

where the development plan is absent, silent or relevant policies are out of

date, granting permission unless:

–any adverse impacts of doing so would significantly and demonstrably

outweigh the benefits, when assessed against the policies in this Framework

taken as a whole; or

–specific policies in this Framework indicate development should be restricted.”

5.1.11 The Droitwich Spa Inspector8 provides a helpful interpretation as to how paragraph 14 should

be applied. This is discussed in detail in paragraph 6.2.8.

5.1.12 As addressed in the preceding Chapters there are significant benefits that would arise from

the development of this Site. Not least the fact that the Council cannot demonstrate a

deliverable 5 year housing land supply and the fact that this proposed development will

contribute to the Council’s current market and affordable housing needs. These benefits must

be weighed in the planning balance, which is detailed in Chapter 8 and Appendix 5. Following

a full technical appraisal of the ability of the Site to accommodate the proposed development,

it would not generate any adverse impacts that would significantly and demonstrably

outweigh the benefits.

8 Droitwich Spa APP/M1840/A/13/2199085


29

5.1.13 In his Ministerial Foreword, Rt Hon Greg Clarke MP stated that:

“The purpose of planning is to help achieve sustainable development.

Sustainable means ensuring that better lives for ourselves doesn’t mean worse

lives for future generations.

Development means growth. We must accommodate the new ways by which

we will earn our living in a competitive world. We must house a rising

population, which is living longer and wants to make new choices. We must

respond to the changes that new technologies offer us. Our lives, and the places

in which we live them, can be better, but they will certainly be worse if things

stagnate.

Sustainable development is about change for the better, and not only in our

built environment.”

5.1.14 His introduction continues:

“So sustainable development is about positive growth – making economic,

environmental and social progress for this and future generations.

The planning system is about helping to make this happen.

Development that is sustainable should go ahead, without delay – a

presumption in favour of sustainable development that is the basis for every

plan, and every decision. This framework sets out clearly what could make a

proposed plan or development unsustainable.”

5.2 Achieving Sustainable Development

5.2.1 The Framework defines sustainable development in line with the 5 “guiding principles” of the

UK Sustainable Development Strategy; Securing the Future, namely:

“Living within the planet’s environmental limits; ensuring a strong, healthy and

just society; achieving a sustainable economy; promoting good governance;

and using sound science responsibly.”

5.2.2 The Framework adopts the Brundtland definition of sustainable development of meeting the

needs of the present without compromising the ability of future generations to meet their


30

own needs. Of which paragraph 7 highlights there are 3 dimensions to sustainable

development, the economic, social and environmental elements of delivering sustainable

development. Paragraph 8 notes:

“These roles [economic, social and environmental] should not be undertaken in

isolation, because they are mutually dependent. Economic growth can secure

higher social and environmental standards, and well-designed buildings and

places can improve the lives of people and communities.”

5.2.3 Sustainability is simply therefore not just one factor but a combination of many. This has

been advocated by a number of Inspectors at recent planning appeals.

5.2.4 Taken together, the 3 dimensions of sustainable development as set out in the Framework

can contribute towards “positive growth” for this and future generations. Gladman considers

the Site is highly sustainable set against the 3 dimensions, in the following ways:

5.2.5 An Economic Role: There are significant economic benefits associated with the

development proposals. House building is a recognised important provider of economic

growth and therefore in turn indirect economic benefits to the construction industry.

Gladman is promoting underutilised land now, ensuring that sufficient land is available

in a sustainable location to support the identified housing growth need of 450 dwellings

in Key Service Centres and the general need across Mid Suffolk.

5.2.6 The 2014 New Anglia Strategic Economic Plan, prepared by the New Anglia Local

Enterprise Partnership (LEP) sets out the overall, long term strategic economic vision

for Norfolk and Suffolk. This plan has a number of implications for housing and how

housing can support the area’s long term economic growth objectives:

The plan outlines aims to deliver approximately 95,000 jobs with at least

117,000 new houses to support this growth by 2026. This would be a 32%

increase in delivery compared with the period 2001 to 2012 across the two

county areas.

It states that each home built in the LEP area would equate to £36,700 in GVA.

This is drawn from house builders being major employers and contributors to

the local economy. This approach supports Gladman’s own assessment of the

economic contribution that housing development makes.

House building is noted as a powerful stimulus for growth. It states that

housing can attract skilled labour, entrepreneurs and inward investment which


31

are all key drivers of growth.

5.2.7 MSDC, along with the other Suffolk District Councils, are represented in the New Anglia

LEP by Cllr John Griffiths, leader of St. Edmundsbury Borough Council. Consequently,

MSDC have agreed to assist with the delivery of the LEP objectives.

5.2.8 The proposal will bring £22 million in investment in construction; 400 full time

construction jobs supported over the construction period; £0.4 million gross household

expenditure within the District; approximately £1.4 million in New Homes Bonus

Scheme investment, to be provided to the Council to the benefit of the community;

continued support to the viability of retail and other businesses in Stowupland and

surrounding area.

5.2.9 340 working-age people will arise from the development, with approximately 290 of

these being economically active. The provision of 1-5 bedroom market and affordable

properties caters to a number of different people including young professionals and

those with a lower-income, allowing them to access employment opportunities in

Stowupland or Stowmarket.

5.2.10 Also, through increasing the level of houses available for local people, it would

contribute to an expansion of the local housing market area and affordability of open

market housing. Currently the issue of affordability is starkly reflected in the

affordability ratio for Mid Suffolk District. Affordability ratios in Mid Suffolk and England

are presented at the lower quartile level. Up until 2005 these ratios grew steadily but

have since levelled out, resulting in a net drop in the ratio. Nevertheless the ratio has

remained above national levels and lower quartile house prices are over seven times

higher than lower quartile earnings. This makes the housing market in Mid Suffolk

particularly difficult to access, especially for first time buyers or those on low incomes.

The picture was similar for the District’s median affordability ratio (this is a ratio of

median house prices to median earnings). In 2013 it stood at 7.05, well above the

England ratio of 6.7.

5.2.11 Furthermore, an Inspectors decision for a residential development in Basingstoke9

recognised the importance of long term economic benefits of residential development,

stating these benefits carry significant weight. The Inspector found that:

9 APP/H1705/A/13/2205929


32

“The proposals will generate construction jobs and economic activity. In the

longer term, as the Site is occupied, residents will add to local spending levels

and the proposal will generate considerable funds in terms of the New Homes

Bonus. Bearing in mind the approach of the Framework, these benefits carry

significant weight.”

5.2.12 Gladman do not consider there would be any adverse economic impacts arising from the

proposed development. On the contrary – there will be significant benefits. The provision of

a mix of housing types (market and affordable) brings with it key benefits in terms of

investment in construction, New Homes Bonus, economically-active people and affordability,

responding to the aspirations of the LEP and affordability issues in the District. The updated

Core Strategy also includes a new Employment chapter and new Employment Policy (Policy

FC3). The strategy outlines the importance of coordinating housing need with employment

growth, retail, infrastructure and services. The proposed development will contribute towards

supporting the area’s labour market needs through providing housing for working age people,

as well as helping to support local businesses and services centres via household expenditure.

5.2.13 A Social Role: The application promotes up to 190 new homes which will contribute

to meeting the deliverable five year supply in the District; this is the principal social

benefit of the proposed development. This will include a proposed 25% affordable

homes on-Site and a contribution for 15% off-Site. In light of the Framework’s priority

to ‘… boost significantly the supply of housing…’ Gladman consider the additional

percentage of affordable dwellings to be provided must carry very substantial weight.

5.2.14 MSDC’s Core Strategy outlines an ageing population as a key issue for the District: “For

Mid Suffolk the growth in the ageing population is growing faster than Suffolk as a

whole. This means that we need to find ways of supporting and helping people maintain

independent lives in their own homes, whilst encouraging younger people to stay in

the District.”10

5.2.15 Through a mix of 1-5 bedroom market and affordable properties, the proposal will

support the need for a more diverse demographic makeup in MSDC; the proposal will

cater to first-time buyers, young professionals and small families. This is in addition to

supporting the needs of larger families through large homes and providing small homes

for the elderly.

10 Mid Suffolk Core Strategy 2008, para 1.43


33

5.2.16 Consequently the proposal responds to one of the aims of paragraph 9 and 50 of the

Framework; widening the choice of high quality homes. Furthermore, the influx of a

variety of people will broaden the social capacity of Stowupland, enhancing inclusivity,

and broadening and enhancing community skills base.

5.2.17 The Site is considered in a sustainable location. A contribution to improve links to the

immediate Public Rights of Way is provided as part of the proposal. The Sustainability

Matrix (Appendix 1) identifies there are a number of services and facilities within the

immediate area and nearby Stowmarket.

5.2.18 The accessibility of existing services and facilities therefore demonstrates the Site’s

social and sustainability credentials and ability to support a strong, vibrant and healthy

community. The provision of additional market and affordable housing must be applied

significant weight.

5.2.19 An Environmental Role: Of particular relevance is that the application will contribute

to protecting and enhancing the natural and built environment. This will be through

retention of trees and hedgerows and new planting, creating a platform for enhanced

biodiversity at the Site.

5.2.20 There are excellent links to the immediate area that will be enhanced by the application

proposals to provide a pleasant walking/cycling route to these facilities. The Site has good

public transport links, there are a number of bus stops located in close proximity to the Site

along Gipping Road, Reeds Way and Church Road. The number 387 bus service located on

Gipping Road, in close proximity to the Site, operates at a frequency of 12 buses a day

between Monday-Friday and 10 buses on Saturday. This service runs from Stowupland and

runs throughout Stowmarket before returning to Stowupland. As part of the proposal, the

nearby bus stops will be improved with new shelters, seating and RTI, encouraging people to

use public transport. A contribution will also be made to improving the surrounding PROWs,

promoting walking and interaction with the surrounding countryside. If better routes to, for

example, the Post Office or school are available then existing residents will be encouraged to

use these routes more frequently.

5.2.21 The development will be of a high quality design and will provide a good standard of amenity

and open space. The location of the Site allows for a choice of modes of transport to be used

to access local facilities. The application proposals are considered wholly sustainable under

the terms of the economic, social and environmental roles of the Framework.


34

5.2.22 Whilst emphasising the need to balance the 3 dimensions, paragraph 19 of the Framework

states:

“The Government is committed to ensuring that the planning system does

everything it can to support sustainable economic growth. Planning should

operate to encourage and not act as an impediment to sustainable growth.

Therefore significant weight should be placed on the need to support economic

growth through the planning system.”

5.2.23 Following a thorough assessment of the technical suitability of the proposals to the Site and

the potential impacts that may arise, all have been given due consideration with particular

consideration to the Landscape and Visual Impact Assessment of the surrounding area. These

are discussed in detail in the D&A and the LVIA. It is on this basis that Gladman do not

consider there are any adverse impacts that would significantly and demonstrably outweigh

the benefits arising from the development when assessed against the Framework as a whole.

5.2.24 Paragraph 17 sets out the ‘Core Planning Principles’ of which a key objective is to seek the

delivery of high quality design. It includes the following clear statements to support growth:

“Proactively drive and support sustainable economic development to deliver the

homes, business and industrial units, infrastructure and thriving local places that

the country needs. Every effort should be made objectively to identify and then

meet the housing, business and other development needs of an area, and

respond positively to wider opportunities for growth...;

always seek to secure high quality design and a good standard of amenity for all

existing and future occupants of land and buildings;

take account of different roles and character of different areas…;

provide mixed use developments, and encourage multiple benefits from the use

of land in urban and rural areas, recognising that some open land can perform

many functions (such as for wildlife, recreation, flood risk, mitigation, carbon

storage, or food production);

actively manage patterns of growth to make the fullest possible use of public

transport, walking and cycling, and focus significant development in locations

which are or can be made sustainable; and,

take account of and support local strategies to improve health, social and cultural

wellbeing for all, and deliver sufficient community and cultural facilities and

services to meet local needs.”


35

5.2.25 The proposal strongly accords with the relevant Core Planning Principles set out in paragraph

17 of the Framework. These proposals will deliver homes that are required now within Mid

Suffolk. Through the influx of 290 economically-active people of various incomes, household

expenditure and investment in construction, economic development is supported. The D&A

and LVIA establish how the proposal secures a high quality design and good standards of

amenity, taking account of the character of the area and makes full use of PROWs and public

transport connections. Through provision of open space and landscaping, wildlife, recreation

and social wellbeing needs are met. Through a mix of 1-5 bedroom market and affordable

properties, the proposal will cater for the needs of different people. The Ecological Appraisal.

Through S106 obligations the proposal can make contributions to local needs, such as

education and health infrastructure.

5.2.26 Gladman’s proposal strongly accords with the aims of the Framework in so far as it will

deliver sustainable development. As covered above, through the influx of 290

economically-active people of various incomes, household expenditure and investment

in construction, the economic aspirations of the Development Plan and LEP are

addressed and thus, as per Framework paragraph 21, the proposal would allow MSDC

to encourage sustainable economic growth. The development will be of a high quality

design and will provide a good standard of amenity and open space. The location of

the Site allows for a choice of modes of transport to be used to access local facilities

and will provide significant economic support for the vitality and viability of Stowupland,

according with the relevant Core Planning Principles set out in paragraph 17 of the

Framework. Through a mix of 1-5 bedroom market and affordable properties, the

proposal will support the need for a more diverse demographic makeup in MSDC; the

proposal will cater to first-time buyers, young professionals and small families. This is

in addition to supporting the needs of larger families through large homes and providing

small homes for the elderly. The arrival of a variety of people will broaden the social

capacity of Stowupland, enhancing inclusivity, and broadening and enhancing

community skills base, in accordance with paragraph 50.

5.2.27 The proposal benefits from the presumption in favour of sustainable

development (Gladman emphasis).

5.3 Promoting Sustainable Transport

5.3.1 Paragraphs 29-41 of the Framework set out how transport factors should be taken into

account when considering development. Transport Assessments should support all

developments that generate significant amounts of movement whilst Travel Plans are cited

as an important tool to facilitate sustainable transport modes. It also states that development


36

should only be prevented or refused on transport grounds where residual cumulative impacts

of the development are severe.

5.3.2 The Transport Assessment accompanying this application demonstrates that the Site can be

accessed satisfactorily and safely in terms of junction design and that the development offers

the opportunity for walking and cycling linkages within the proposed development and to the

local services in Stowupland. Public Transport is also available to future residents of the Site

along Gipping Road and Church Road and improvements to nearby bus stops will encourage

use of public transport. In addition to being Framework-compliant, encouragement of using

public transport is also in line with Suffolk County Council Transport Plan’s aspirations to make

greater provision for sustainable transport networks and services.

5.3.3 A key benefit of the scheme is a proposed extension of the 30mph limit beyond the potential

access point on Gipping Road. This is a significant safety benefit as there is currently no

footpath on this road.

5.3.4 Paragraph 38 aims to ensure large residential development is supported with key facilities,

located within walking distance. This application includes a new equipped area of play and

open space, which will not only benefit the new residents but also existing residents.

5.4 Delivering a Wide Choice of High Quality Homes

5.4.1 The Framework sets out the Government’s key housing objective, which is; “to boost

significantly the supply of housing”. Paragraph 47 sets out how LPAs should achieve this boost

in the supply of housing, including a requirement to:

“identify and update annually a supply of specific deliverable sites sufficient to

provide five years’ worth of housing against their housing requirements with an

additional buffer of 5% (moved forward from later in the plan period) to ensure

choice and competition in the market for land. Where there has been a record

of persistent under delivery of housing, local planning authorities should increase

the buffer to 20% (moved forward from later in the plan period) to provide a

realistic prospect of achieving the planned supply and to ensure choice and

competition in the market for land.”

5.4.2 Paragraph 49 provides extremely clear guidance on both how this should be achieved and

how applications should be considered if it is not:

“…Housing applications should be considered in the context of the presumption


37

in favour of sustainable development. Relevant policies for the supply of housing

should not be considered up-to-date if the local planning authority cannot

demonstrate a five-year supply of deliverable housing sites.”

5.4.3 The Gladman proposals entirely accord with this national policy objective in so far as the

application will deliver new housing development which will assist MSDC by contributing

towards the central Government objective of significantly boosting the supply of housing.

5.4.4 The grant of planning permission now, on this Site, will improve the Council’s portfolio of

suitable, available and deliverable housing sites thus contributing towards the remediation of

this poor housing land supply position.

5.4.5 Paragraph 50 seeks the delivery of a wide choice of quality homes and affordable provision.

5.4.6 The Gladman proposal will deliver up to 190 homes that will include properties of 1-5

bedrooms and 25% affordable housing on-Site and a sum of money for 15% off-Site provision

elsewhere or upgrade of existing housing stock where deemed appropriate.

5.4.7 Paragraph 55 seeks to promote sustainable development in rural areas, locating housing

where it will enhance or maintain the vitality of rural communities. Along with paragraph 57

of the Framework, this application aims to deliver a high quality ad inclusive development

which includes a new open space for new and existing residents to use, enhancing the vitality

of the local community.

5.4.8 The application proposals entirely accord with the criteria set out in the Framework.

5.5 Promoting Healthy Communities

5.5.1 Paragraphs 69-70 promote the creation of sustainable, healthy communities by protecting or

enhancing community facilities and open spaces. The Framework Plan that is submitted

illustrates how the provision of open space, landscaping, informal open space and the

footpath and cycle linkages can be integrated into a detailed design for the Site at the

Reserved Matters stage. All of these components of the scheme will enable the new resident

community, together with the existing resident population who are relatively local to the Site,

to take exercise and thus the proposed scheme will actively promote general well-being for

the new and existing resident community.

5.5.2 The application complies in full with this Framework aspiration.


38

5.6 Meeting the Challenge of Climate Change

5.6.1 Paragraph 95 of the Framework seeks “new development in locations and ways which reduce

greenhouse gas emissions”, and urges LPAs to adopt national standards in order to drive for

the delivery of sustainable development. The application proposal meets these criteria as it

will be delivered to relevant building regulations applicable at the time of submission,

notwithstanding the improvements to bus stops and PROWs will encourage greater use of

sustainable methods of transport rather than using the car – and additional aspirations set

out in the Travel Plan framework.

5.6.2 The application complies in full with this Framework aspiration.

5.7 Conserving and Enhancing the Natural Environment

5.7.1 Paragraphs 109-115 addresses the protection of valued landscapes. It requires Local

Authorities to create, protect, enhance and manage networks of biodiversity and green

infrastructure.

5.7.2 Paragraph 112 also addresses use of agricultural land:

“Local planning authorities should take into account the economic and other

benefits of the best and most versatile agricultural land. Where significant

development of agricultural land is demonstrated to be necessary, local planning

authorities should seek to use areas of poorer quality land in preference to that

of a higher quality.”

5.7.3 Best and most versatile land is defined as grade 1, 2 or 3a. The application is accompanied

by a Soils and Agricultural Use & Quality Report (November 2014). This confirms that 100%

of the Site is Grade 3b.

5.7.4 The loss of agricultural land to other uses is regrettable however Gladman consider the impact

of such loss should be considered against the potential benefits that would accrue from the

development of the land for residential, primarily the boost to housing supply and the

associated economic benefits that would arise from this, including significant job creation,

investment in the local and District economy, the construction impacts, the New Homes

Bonus, and the increase in open space and landscaping. The application complies with

paragraph 112 of the Framework as it does not promote the use of best and most versatile

agricultural land.

5.7.5 Paragraph 118 provides guidance to minimise impacts on biodiversity:


39

“When determining planning applications, local planning authorities should aim

to conserve and enhance biodiversity by applying the following principles:

if significant harm resulting from a development cannot be avoided

(through locating on an alternative Site with less harmful impacts),

adequately mitigated, or, as a last resort, compensated for, then

planning permission should be refused;

proposed development on land within or outside a Site of Special

Scientific Interest likely to have an adverse effect on a Site of Special

Scientific Interest (either individually or in combination with other

developments) should not normally be permitted. Where an adverse

effect on the Site’s notified special interest features is likely, an exception

should only be made where the benefits of the development, at this Site,

clearly outweigh both the impacts that it is likely to have on the features

of the Site that make it of special scientific interest and any broader

impacts on the national network of Sites of Special Scientific Interest;

development proposals where the primary objective is to conserve or

enhance biodiversity should be permitted;

opportunities to incorporate biodiversity in and around developments

should be encouraged.”

5.7.6 The Ecological Report demonstrates that significant harm in respect of biodiversity does not

arise as a consequence of the application proposal.

5.7.7 The Site is not a Site of Special Scientific Interest (SSSI) but it is within 2km of the Gipping

Great Wood SSSI. The Ecological Appraisal has set out that because there are no formal

routes of access to the SSSI from the Site (for example, PROWs), the alternative routes via

farm tracks are between 2km and 4km walking distance and because the proposal makes

provision for a significant amount of Public Open Space (POS), the SSSI is unlikely to be

subject to any increases in visitation. Therefore it is not anticipated that there will be any

adverse effects on the SSSI.

5.7.8 The Framework Plan has wherever possible, been evolved to conserve the existing hedgerows

and trees located along the boundaries and within the Site. Additional tree planting and

structure landscaping will be introduced into the development which will help to create a


40

legible landscape structure which will help to define a sense of place within the scheme. This

approach will provide the potential to enhance biodiversity across the Site.

5.8 Building a strong, competitive economy 5.8.1 Paragraph 19-20 of the Framework underlines the Governments focus on ensuring that the

planning system supports business to support a sustainable economic growth. It is recognised

that the provision of housing across the country is fundamental to economic growth. Council’s

should provide for the correct number of homes for their area to enable them to meet there

economic aspirations. Gladman have identified, through work undertaken by Regeneris, that

the Council’s housing requirement figure of 404 dpa is too low. As a result this figure could

lead to restricting the economic potential of Mid Suffolk in the future.

5.9 Decision-Taking 5.9.1 Paragraphs 186-187 state:

“Local planning authorities should approach decision-taking in a positive way to

foster the delivery of sustainable development. The relationship between

decision-taking and plan-making should be seamless, translating plans into high

quality development on the ground.

Local planning authorities should look for solutions rather than problems, and

decision-takers at every level should seek to approve applications for sustainable

development where possible. Local planning authorities should work proactively

with applicants to secure developments that improve the economic, social and

environmental conditions of the area.”

5.9.2 Paragraphs 188-191 encourage applicants to engage in good quality pre-application

engagement. The SCI sets out the measures Gladman sought to engage with MSDC at the

pre-application stage.

5.10 The Framework Summary

5.10.1 In summary, the proposals achieve demonstrable accordance with the overall objectives and

relevant policies of the Framework, in particular, the golden thread of sustainability thus

invoking the ‘presumption in favour of sustainable development’. Following a

thorough assessment of any potential impacts of the development Gladman and their advisers

do not consider there are adverse impacts that would significantly, and demonstrably

outweigh the benefits as proposed. In accordance with the Framework and the presumption

in favour of sustainable development, the proposals should be approved without delay.


41

6 THE DEVELOPMENT PLAN AND EMERGING PLAN

6.1 Introduction

6.1.1 The current Development Plan consists of:

The saved policies of the Mid Suffolk Local Plan 1998 and its 2006 alteration. (Plan

period to 2006, 2006 alteration policies to 2011)

The Mid Suffolk Core Strategy, adopted September 2008, and the Mid Suffolk Core

Strategy Focused Review, adopted December 2012 (Plan period to 2027)

The Stowmarket Area Action Plan, adopted February 2013 (Plan period to 2027)

6.1.2 Under the terms of Section 109 of the Localism Act 2011 the Secretary of State has, by order,

revoked the Regional Spatial Strategy for this area, the East of England Plan. It no longer

forms part of the Development Plan.

6.2 Weight to be Accorded to the Development Plan

6.2.1 Under the provisions of the Planning and Compulsory Purchase Act 2004, policies in Mid

Suffolk Local Plans were saved until 27th September 2007. The Secretary of State directed

that the policies were to be ‘saved’ beyond the expiry of the Plan until superseded by the

emerging Local Development Framework. It should be noted that such policies were only

meant to be used for Development Management purposes until the end of the given Plan-

period, which is 2006 in the case of the 1998 Mid Suffolk Local Plan. The saved period is now

a significant amount of time ago and though the Secretary of State has allowed select policies

to be retained until superseded, they are nevertheless substantially out-of-date.

6.2.2 Not all of the 1998 Local Plan policies have been superseded by the 2008/2012 Core Strategy,

thus remain as ‘saved’ policies. The 1998 Local Plan is considered to be time-expired as it

only covers a period up to 2006. Paragraph 215 (of the Framework) states that limited weight

should be given to these policies according to their level of consistency with the Framework.

However, Gladman consider as the principle policies of the Local Plan are also time-expired

and therefore out-of-date, the presumption in favour of sustainable development set out in

paragraph 14 of the Framework should be engaged. This is in line with an Inspector’s

interpretation at an appeal decision in Droitwich Spa11, discussed in more detail shortly.

11 Droitwich Spa APP/M1840/A/13/2199085


42

6.2.3 Two policies relating to affordable housing, Policy H4 and H5, were updated in June 2006 to

take account of market changes. These policies are also classed as saved policies and remain

in place for Development Management purposes until they are superseded. This 2006 update

to these affordable housing policies covers a period of 2003-2011 and is thus also time-

expired.

6.2.4 The Site is shown to be outside the development limit of Stowupland as shown by the

Proposals Map which accompanies the 1998 Local Plan, which covers the Plan period 1992-

2006. The accompanying policies which cover settlement boundaries, Prop 1 and H7, are

listed as saved policies that have yet to be superseded, however they are time-expired.

6.2.5 The Mid Suffolk Core Strategy was adopted in 2008, with a review and changes adopted in

2012 (discussed in more detail later). The original 2008 Core Strategy and 2012 Update should

be read in conjunction with one another, along with the saved policies of the 1998 Local Plan.

Supplementary to these DPDs is the Stowmarket Area Action Plan (2013), which sets out

policies and housing distribution for the Stowmarket Area (including Stowupland).

6.2.6 Gladman acknowledge the Core Strategy is not time-expired, however it was originally

prepared pre-Framework and ultimately principle policies are inconsistent with the Framework

and therefore out-of-date.

6.2.7 Paragraph 49 of the Framework advocates that relevant policies for the supply of housing

should not be considered up-to date if the Local Planning Authority cannot demonstrate a 5

year supply of deliverable housing sites. As outlined in the next Chapter, Gladman have

demonstrated that MSDC cannot demonstrate a 5 year supply of deliverable housing sites, as

such policies in relation to the delivery of housing should not be considered up-to-date.

6.2.8 A recent appeal decision at Droitwich Spa12 has provided a useful summary as to the approach

which should be taken when applying the presumption in favour of sustainable development

as outlined in paragraph 14 of the Framework. In light of this decision the following points

can be made as to the steps in weighting the Planning Balance as outlined in paragraphs 4.76

– 4.82 of the Inspectors decision:

“Benefits and constraints to a development should be fed into the equation provided

by paragraph 14 of the Framework in circumstances where principle policies are out

of date;

12 APP/H1840/A/13/2199085 (Decision issued 2nd July 2014).


43

In these instances, only if the Council can demonstrate harm which ‘significantly and

demonstrably’ outweighs the benefits of the development should consent be refused;

Harm must be of ‘sufficient gravity’ to significantly and demonstrably outweigh the

benefits, the reason for this significant shift is that the key policy objective of the

Framework under paragraph 47 is to ensure that a 5 year supply of housing is in

place and that old plans with outdated constraints do not hinder development;

There should be an understanding of the significant benefits of a scheme, benefits

can include but are not limited to; boosting significantly the supply of housing; helping

meet a Council’s 5 year housing land supply; the provision of affordable housing; the

creation of jobs from the development and the economic benefits this brings;

improvements to local services such as public transport connections; provision of

open space, landscaping and habitat creation;

Ultimately the harm of the development should be weighed against the significant

benefits of the development.”

6.2.9 This appeal decision provides a guide as to how the presumption outlined in paragraph 14 of

the Framework should be applied. As the Core Strategy and Stowmarket Area Action Plan’s

principle policies are not considered up-to-date or Framework-compliant on account of the

lack of a deliverable 5-year housing land supply, paragraph 14 of the Framework should be

engaged and there should be a presumption in favour of sustainable development.

6.2.10 It has been established that MSDC’s housing requirement and consequently their 5-year

housing land supply is based upon information derived from the East of England RSS. The

Hunston Appeal Judgement (12th December 2013) is now considered relevant to the

determination of planning applications where the determining Authority do not have an

Adopted Local Plan compliant with the Framework. His Honour Judge Pelling QC quashed a

Planning Inspectors decision in regards to this matter. The implications of this Judgement in

the context of the applications in Mid Suffolk are discussed in more detail in the following

Chapter.

6.2.11 In addition the recently published PPG, advocates:

“it should be borne in mind that evidence which dates back several years, such as that drawn

from revoked regional strategies, may not adequately reflect current needs.”


44

6.2.12 Therefore the overall housing requirement should be based on a full Objectively Assessed

Need as required by the Framework. The Applicant has produced a full Objectively Assessed

Need of the area and consider that this figure is more reflective of the current and long term

housing situation, detailed in the next Chapter.

6.2.13 Gladman acknowledge the proposed development is a departure from the Development Plan

and therefore, as per section 38(6) determination shall be made in accordance with the Plan

unless material considerations indicate otherwise.

6.2.14 The Statement will now assess the proposals against the relevant policies of the Development

Plan.

6.3 Mid Suffolk Local Plan 1998 (1992-2006) (Saved Policies)

6.3.1 The Mid Suffolk Local Plan 1998 cannot be regarded as decisive in this case as it is time

expired and as such out-of-date (as per paragraph 14 of the Framework), and is in conflict

with the Framework which is a significant material consideration. These policies were not

intended to guide development in Mid Suffolk beyond 2006.

6.3.2 Nevertheless, the proposals that form this application are tested against the policies contained

within the 1998 Local Plan. As it is unknown what ‘weight’ the decision-maker will apply, it is

therefore for completeness only.

6.4 Relevant Saved Policies of the 1998 Local Plan and 2006 alteration.

Policy SB2 – Development Appropriate to its Setting

6.4.1 This policy covers the kind of development within a settlement boundary that will be

supported by MSDC. It states development or change of use appropriate to their surrounding

will normally be permitted providing it matches the character and appearance of the area,

does not negatively impact traffic or road safety or negatively impacts open space or wildlife

areas. Excessive infilling or inappropriate forms of development will be refused.

6.4.2 Lying outside the settlement boundary, the proposal would be considered an inappropriate

form of development when considered against this policy. However, since this Policy does not

allow for the provision of housing outside the built up area to meet the identified housing

shortfall and it is time-expired, it is inconsistent with paragraph 49 of the Framework and out-

of-date. The approach to the use of restrictive settlement boundaries has been deemed to be


45

a housing restraint policy in cases such as the Alsager decision13 (discussed in more detail

shortly) and is therefore out-of-date.

Policy SB3– Retaining Visually Important Open Spaces 6.4.3 Set out in this policy is that Visually important Open Spaces will be protected because of their

contribution to character of the area. The District Authority will resist development that causes

a harmful effect on these identified Visually Important Open Spaces within or abutting

settlement boundaries.

6.4.4 The Site adjoins an identified Visually Important Open Space, the fields of the local schools.

This policy is now time-expired. Nevertheless our LVIA considers the vast majority of

properties within Stowupland and the surrounding landscape will be screened from the

proposed development by intervening buildings, landform and/or trees and hedgerows.

Moderate/Major adverse visual effects experienced at year one would reduce to Minor adverse

as tree and shrub planting within the open space and greenway corridors establishes. On this

basis there are no defensible reasons for refusal with reference to visual matters. The

proposed development is therefore in compliance with policy SB3.

Policy GP1 – Design and Layout of Development

6.4.5 The Council state that development with poor design and layout will be refused in this policy.

Proposals should maintain and enhance existing character and appearance of the existing

surroundings, use appropriate materials and support or enhance important existing

environmental landscape features. Attention should be paid to the relationship between

buildings and open space, and between proposed development and existing development.

6.4.6 The D&A, Framework Plan and LVIA identify the proposal’s good design principles. Compliance

with this policy can be achieved at the Reserved Matters stage.

Policy HB1 – Protection of Historic Buildings 6.4.7 A high priority is given to protecting the character and appearance of architectural or historic

interest in this policy. Particular regard will be given to protecting the setting of listed

buildings.

6.4.8 No Listed Buildings are present on the Site, though the proposal is within close proximity to

a number of Grade II Listed Buildings and a Grade II* Listed Building on Church Road and

Gipping Road. Figure 11 in the Heritage Statement submitted with this application shows the

location of the Listed Buildings within proximity to the Site. The conclusion of the Heritage

Statement submitted with this application is that, after a detailed assessment, the proposal

13 CO/17165/2013


46

will not affect the heritage assets’ significant nor affect the contribution that their setting adds

to their significance.

6.4.9 Therefore the application is in compliance with policy HB1.

Policy H7 – Restricting Housing Development Unrelated to the Needs of the

Countryside

6.4.10 This policy outlines that there will be strict control over proposals for new housing outside

settlement boundaries. The provision for new housing will normally form part of the existing

settlements.

6.4.11 Paragraph 49 of the Framework advocates that relevant policies for the supply of housing

should not be considered up-to-date if the Local Planning Authority cannot demonstrate a five

year supply of deliverable housing. Gladman consider Policy H7 is a relevant housing policy.

6.4.12 The recent issue of a Consent Order of an application under Section 288 of The Town and

Country Planning Act 1990 between Gladman Developments Limited and the Secretary of

State for Communities and Local Government and Cheshire East Council in quashing the

planning decision relating to the land at Alsager14. The Consent Order states that the Inspector

was wrong that policies relating to settlement boundaries (PS4), open countryside (PS8) and

restricted development in the open countryside (H6) were not policies for the supply of

housing.

6.4.13 In addition this Consent Order supersedes reference to an ‘Alsager’ decision in the recently

published Inspectors Report into an appeal ‘The Feniton Park Ltd’. Notably the Inspector

sitting on this appeal in his decision stipulates:

“…I would hesitate to accept the proposition that a policy could not be relevant to the

supply of housing simply because housing is not its main purpose. It was open to the

Government to say, in the NPPF, that the provisions of paragraph 49 apply to policies

‘specifically related to’ or ‘solely concerned with’ the supply of housing: instead , the

term chosen was ‘relevant…for’ “

“This confirms my view that the assessment to be made is whether a particular policy

is related to the supply of housing, and not whether housing is its sole or main

purpose.”

14 CO/17165/2013


47

6.4.14 In addition to this, the Consent Order of Anita Coleman of 9th May 2013 dismisses the

planning decision, particular regard here is given to paragraph 46. The Judgement outlines

that the policies in place restricted development which were contrary to the aims of the

Framework- whist it is accepted the case related to renewable energy the principles can be

applied to residential development.

6.4.15 Since this Policy does not allow for the provision of housing outside the built up area to meet

the identified housing shortfall, it is inconsistent with paragraph 49 of the Framework and

out-of-date.

6.4.16 On this basis Gladman do not consider policy H7 is relevant or material to the determination

of this application. No weight is therefore to be attached to this Policy.

Policy H13 – Design and Layout of Housing Development 6.4.17 This policy seeks to set out the standards that new housing development should meet. The

design and layout should respect the character of the proposal Site and its surroundings,

complement the existing scale, form and materials of the settlement, have adequate privacy

for residents, retain existing landscape features, have a safe and high quality road and access

design and enhance ecological features.

6.4.18 As identified on the Framework Plan and Figure 3 of the Arboricultural Assessment submitted

with the application, the majority of existing trees and hedgerows will be maintained. New

trees, hedgerows and trees are provided as part of the proposal. The D&A Statement sets

out how the proposal complements the existing settlement’s scale, form, materials, character

and amenity, provides adequate levels of privacy for each dwelling and a safe, high quality

road network.

6.4.19 Compliance with this policy, demonstrated by the Framework Plan, can be achieved at the

reserved matters stage.

Policy H14 – A Range of House Types to Meet Different Accommodation Needs

6.4.20 In a development of 10 or more dwellings, the Council will encourage a variety of housing

types and designs to cater for different accommodation needs.

6.4.21 The proposal consists of a mix of 1, 2, 3, 4 and 5 bedroom properties, which has the potential

to cater to a large variety of different people and different sized families thus contributing to

the local need. The D&A sets out the different kinds of housing designs in more detail. It is

proposed that there will be 25% affordable housing on-Site and a contribution for 15% off-

Site which will cater to first-time buyers, small families and young people. At a total of 40%,


48

this exceeds the requirement of altered policy H5 to provide 35% affordable housing on major

developments.

6.4.22 Consequently, the development is compliant with policy H14.

Policy H15 – Development to Reflect Local Characteristics

6.4.23 In this policy, the Council reiterate that new housing should be consistent with the pattern

and form of neighbouring area and be mindful of the character of its setting. Access and

drainage and the configuration of natural features should also be consistent with the existing

built form. Additionally, developments on allocated sites with net densities of 25-37 dwellings

per hectare will be generally encouraged by the Local Planning Authority.

6.4.24 The D&A, LVIA, Framework Plan, Arboricultural and Archaeological desk-based assessments

all set out that the proposed development is mindful of the existing character, form, setting

and natural features. Access is proposed off Gipping Road and Church Road, which already

serve as sources of access junctions elsewhere in the settlement. As shown in the Framework

Plan, the drainage network used by the Site is one that already exists. The Ecology and

Arboricultural Assessments outline that the majority of existing ecological features will be

retained or enhanced. Therefore the proposal is highly consistent with existing local

characteristics.

6.4.25 Additionally, though not an allocated site, the proposed development puts forward a potential

density of 26 dwellings per hectare in the submitted Framework Plan, consistent with policy

H15 guidance.

6.4.26 The proposal is compliant with policy H15.

Policy H16 – Protecting Existing Residential Amenity 6.4.27 The Council will refuse development that contributes to a loss of open space that contributes

to the character or appearance of an area and which are important for recreation or amenity

purposes, and development that materially reduces amenity and privacy of adjacent

dwellings.

6.4.28 The Site is not designated as Visually Important Open Space. Though the Site currently hosts

a number of PROWs used for amenity purposes, these are being retained, enhanced and

better connected to outside PROWs as part of the proposal as set out in the Framework Plan.

A contribution will also be made to make improvements to these external PROWs. Thus there

is no loss to this element of existing provision. The Framework Plan has sought to retain the

openness of these routes in the Site to limit the effect on their amenity. The LVIA sets out


49

how the proposal’s design aims to maintain the amenity and residential privacy of the existing

settlement.

6.4.29 The proposal is therefore compliant with policy H16.

Policy CL1 – Guiding Principle to Development in the Countryside

6.4.30 This policy aims to ensure the landscape quality and character of the countryside will be

protected. Proposals for development in the countryside should be sited and designed to have

minimum adverse effect on the appearance of the landscape and should seek to positively

contribute to its diverse character through tree planting, hedgerow creation and fostering of

wildlife habitats.

6.4.31 The Framework Plan outlines that new trees and hedgerows will be delivered as part of the

proposal, in addition to the retention of the majority of the existing specimens as shown in

Figure 3 of the Arboriculture Assessment. As detailed in the Ecological Appraisal, the new and

retained trees and ecological features provide widened opportunities for foraging and

commuting for amphibians and bats. The LVIA considers the proposal has the potential to

accommodate a well-planned residential development without causing significant harm to the

wider settlement or local landscape context.

6.4.32 Consequently the proposal meets the requirements of policy CL1.

Policy CL8 – Protecting Wildlife Habitats

6.4.33 The Planning Authority will refuse development which is a threat to rare or vulnerable species,

especially those that are protected by law. Retention of important wildlife habitats will be

sought through planning conditions.

6.4.34 Included with the Ecological Appraisal is an assessment on the presence of Great Crested

Newts. The species are afforded full protection under Schedule 5 of the Wildlife & Countryside

Act 1981 (as amended) and under the Conservation of Habitats and Species Regulations 2010

(as amended). The Site does not host any Great Crested Newts, nor will the proposal

negatively impact the local population. The Ecological Appraisal concludes there is no adverse

impact on the limited wildlife habitats currently on the Site, rather, the retention and addition

of hedgerows and trees have the potential to enhance the habitat for commuting and foraging

amphibians and bats.

6.4.35 The proposal is therefore in line with the requirements of policy CL8.


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Policy CL11 – Retaining High Quality Agricultural Land 6.4.36 The District Planning Authority will encourage the conservation of Agricultural Land, with

particular protection afforded to Best and Most Versatile Agricultural Land (namely Grades 1,

2 and 3a).

6.4.37 Soils and Agricultural Use & Quality Report concludes 100% of the Site is Grade 3b and

therefore does not represent Best and Most Versatile Agricultural Land. Policy CL11 is

therefore not relevant to this application.

Policy T9 – Parking Standards 6.4.38 This policy sets out that development proposals will normally be required to provide for the

parking and manoeuvring of vehicles on the application Site in accordance with the parking

standards adopted by the Council.

6.4.39 This can be accommodated at the Reserved Matters stage. Please refer to the indicative

Masterplan, which sets out how the proposal is compliant with Policy T9.

Policy T10 – Highway Considerations in Development 6.4.40 In this policy, the Council outline what highway matters they regard when considering

planning applications. This includes provision of safe access into the Site, the suitability of

existing roads giving access to the development (in terms of pedestrian safety and free flow

traffic), whether the traffic generated by the proposals will be acceptable in relation to the

existing road network capacity, adequate turning and parking space and whether the needs

of pedestrians and cyclists have been met.

6.4.41 As concluded in the Transport Assessment, the existing highway network can accommodate

the proposed traffic generated by the development and does not create any safety concerns.

Particular regard has been given to Church Road, Gipping Road and Thorney Green Road.

Furthermore, paragraph 6.1.4 of the Assessment states out “The development will provide a

Site layout designed in accordance with current best practice to accommodate pedestrians

and cyclists. The sustainability assessment shows that the Site is accessible by non-car

modes”.

6.4.42 As such, the proposal in compliant with policy T10.

Policy RT4– Amenity, Open Space and Play Areas Within Residential Development

6.4.43 For residential development comprising 10 or more dwellings, public open space should be

provided in the form of play areas, formal recreation areas or amenity areas, unless the

District Planning Authority is satisfied that adequate facilities already exist nearby.


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Supplementary planning documents will set out guidance to the amount and form of open

space needed.

6.4.44 This has taken the form of the Supplementary Planning Document for Social Infrastructure

Including Open Space, Sport and Recreation, implemented February 2007. It sets

requirements of 2.0m2 per person for Play Areas and 6.0m2 per person of Informal Recreation

Space (Table 2, page 8).

6.4.45 The proposal is for 190 dwellings which, using the local average population density of 2.2

people per dwellings (as calculated in the accompanying SCI), will yield approximately 418

people. This generates a requirement of 836m2 of Play Area (0.08 ha) and 2,508m2 (0.25ha)

of Informal Recreation Space, a total of 3344m2 (0.33ha). As set out on the Framework Plan,

0.09ha of the Site is provided as an Equipped Area of Play for children and 0.28ha is provided

as Informal Recreation Space, a total of 0.37ha. The proposal exceeds the requirements

required from the SPD as seen in the Green Infrastructure Schedule table of the Framework

Plan, and is thus compliant with policy RT4 and the requirements of the SPD. Notwithstanding

this, a significant area of landscaping is also provided (2.47ha), which is a significant

recreational benefit to the area.

Policy RT12 – Footpaths and Bridleways 6.4.46 This policy outlines that the Council will safeguard the existing footpath and bridleway network

in the District, and will support proposals to secure its improvement or alteration where

appropriate.

6.4.47 As set out in the submission, the proposal incorporates and improves existing Public Rights

of Way within its design and provides new footpaths. Additionally, connections to outside

PROWs have been established and a monetary contribution to enhancing these external

PROWs will be made. The proposal is therefore compliant with RT12.

Altered Policy H4 – A Proportion of Affordable Housing in New Housing

Developments

6.4.48 In this altered policy adopted in 2006, there is a requirement to provide 35% of affordable

housing on developments of 5 dwellings or more or sites more than 0.17 hectares in Mid

Suffolk.

6.4.49 The proposed development makes provision for 25% affordable housing on Site and will

provide a sum of money for 15% off-Site affordable housing provision. As a housing policy,

policy H4 is considered out-of-date in the absence of a deliverable 5-year housing land supply

as per paragraph 49 of the Framework. Notwithstanding, the proposal is compliant with policy

H4 as it exceeds the 35% requirement.


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6.4.50 A social rented/intermediate tenure split is not covered in this policy, but was confirmed by

MSDC to be a preference of 75% social rented and 25% low-cost home ownership. Appendix

7 covers this in more detail.

6.5 The Mid Suffolk Adopted Core Strategy 2008 (2007-2025)

6.5.1 As stated, the Mid Suffolk Core Strategy was adopted in 2008, with a focused review and

changes adopted in 2012, and is the current Development Plan for the District. As per section

38(6) of the Planning and Compulsory Purchase Act (2004), the Development Plan remains

the starting point for the determination of planning applications.

6.5.2 The 2012 focused review makes some alterations, particularly in regards to housing

distribution (but not housing requirement) and must be read in conjunction with the 2008

Core Strategy, as opposed to replacing it outright. The following relevant policies are those

set out in the initial 2008 Plan.

6.6 Relevant policies of the Adopted Core Strategy 2008

Policy CS1 – Settlement Hierarchy 6.6.1 This policy sets out that the majority of new development (including retail, employment and

housing allocations) will be directed to towns and Key Service Centres, but also with some

provision for meeting local housing needs in primary and secondary villages, in particular

affordable housing.

6.6.2 Stowupland is classified as a Key Service Centre and therefore a settlement where there will

be a focus for new development (450 dwellings on greenfield land 2012-2027; see policy

FC2). As of yet there are no allocations in Stowupland and, as set out in Chapter 7 of this

Statement, a dire need for new housing in Mid Suffolk.

6.6.3 The proposal is therefore in line with policy CS1, as the proposal represents new development

in a Key Service Centre.

Policy CS2 – Development in the Countryside and Countryside Villages 6.6.4 This policy outlines that development in the countryside will be restricted to defined categories

such as agriculture and forestry, replacement dwellings, dwelling extensions, recreation and

tourism uses, mineral extraction, flood protection and more.


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6.6.5 The development exists outside the defined settlement boundaries set out in the 1998 Local

Plan saved policies and thus would constitute as open countryside. Policy CS2 aims to restrict

development outside settlement boundaries as new residential development is not listed as a

permitted category. Paragraph 49 of the Framework advocates that relevant policies for the

supply of housing should not be considered up-to-date if the Local Planning Authority cannot

demonstrate a five year supply of deliverable housing. Gladman consider Policy CS2 is a

relevant housing policy in accordance with the aforementioned ‘Alsager’ decision.

6.6.6 The recent issue of a Consent Order of an application under Section 288 of The Town and

Country Planning Act 1990 between Gladman Developments Limited and the Secretary of

State for Communities and Local Government and Cheshire East Council in quashing the

planning decision relating to the land at Alsager15. The Consent Order states that the Inspector

was wrong that policies relating to settlement boundaries (PS4), open countryside (PS8) and

restricted development in the open countryside (H6) were not policies for the supply of

housing.

6.6.7 In addition this Consent Order supersedes reference to an ‘Alsager’ decision in the recently

published Inspectors Report into an appeal ‘The Feniton Park Ltd’. Notably the Inspector

sitting on this appeal in his decision stipulates:

“…I would hesitate to accept the proposition that a policy could not be relevant to the

supply of housing simply because housing is not its main purpose. It was open to the

Government to say, in the NPPF, that the provisions of paragraph 49 apply to policies

‘specifically related to’ or ‘solely concerned with’ the supply of housing: instead , the

term chosen was ‘relevant…for’ “

“This confirms my view that the assessment to be made is whether a particular policy

is related to the supply of housing, and not whether housing is its sole or main

purpose.”

6.6.8 In addition to this, the Consent Order of Anita Coleman of 9th May 2013 dismisses the

planning decision, particular regard here is given to paragraph 46. The Judgement outlines

that the policies in place restricted development which were contrary to the aims of the

Framework- whist it is accepted the case related to renewable energy the principles can be

applied to residential development.

15 CO/17165/2013


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6.6.9 Since this Policy does not allow for the provision of housing outside the built up area to meet

the identified housing shortfall, it is inconsistent with paragraph 49 of the Framework and

should be afforded no weight in this decision.

Policy CS3 – Reduce Contributions to Climate Change 6.6.10 It sets out that sustainable construction techniques will be encouraged in all new dwellings

to achieve at least a three star rating under the Code for Sustainable Homes. This requirement

will rise over the Plan period and by 2013 new dwellings will achieve at least a four star rating

and by 2016 new dwellings will achieve a six star (carbon zero) rating.

6.6.11 As a housing policy, policy CS3 is considered out-of-date in the absence of a deliverable 5-

year housing land supply as per paragraph 49 of the Framework and should be given no

weight.

Policy CS4 – Adapting to Climate Change 6.6.12 In this policy, the Council outline all proposals should “contribute to the delivery of sustainable

development and reflect the need to plan for climate change”. Particular considerations are

current or future flood risk, pollution and biodiversity. These are considered in turn.

6.6.13 The Site is located within Flood Zone 1 (low risk) in the Environment Agency flood risk Map.

This is land designated as having less than 0.1% annual probability of flooding from rivers or

the sea in any year (less than a 1 in 1,000 annual probability of flooding). As set out in the

accompanying Flood Risk Assessment the surface water drainage plan proposes to mimic the

existing greenfield run-off rates plus 30% to take account of future climate change. A

Sustainable Drainage System (SuDS) will be incorporated into the Site, with various possible

scenarios set out in the FRA.

6.6.14 The Noise and Air Quality reports submitted with this application both conclude that the

proposal will not have a negative impact on the quality of air or create undue noise.

6.6.15 The Ecological Appraisal sets out that the Site has limited potential in terms of habitat and

biodiversity. The majority of existing landscape features are being retained, which may

enhance the foraging and commuting opportunities of amphibians, thus there are no major

negative impacts on biodiversity arising from the proposal.

6.6.16 For these reasons, the proposal is compliant with policy CS4.

Policy CS5 – Mid Suffolk’s Environment 6.6.17 Policy CS5 sets out that all development must enhance the environment, including the historic

environment and retain the local distinctiveness of the area. The Council will work to protect


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manage and conserve the landscape qualities as a whole, including Designated Sites, and

Wildlife Corridors, and require design of new developments to respect local distinctiveness

and historic and archaeological assets will be protected.

6.6.18 The Site is not located in a Conservation Area, though it is close to 2 existing Listed Buildings

on Church Road and Gipping Road. The Archaeological Desk-Based Assessment by CgMs has

established there may be a former Medieval/Post- Medieval moated farmstead located in the

north-west of the Site, which may at most be of local importance. As concluded by the

Assessment, it is likely that further archaeological assessment of the potential area of

archaeological interest will be required by the Suffolk County Council Archaeological Officer.

The Assessment also concludes that proposal will not affect the heritage assets’ significant

nor affect the contribution that their setting adds to their significance.

6.6.19 The LVIA considers the Site has the potential to accommodate a well-planned residential


context.

6.6.20 The Ecological Appraisal and survey work submitted with the application identify the Site is

within 2km and the Impact Risk Zone (IRZ) of the Gipping Great Wood Site of Special Scientific

Interest (SSSI), designated as such by Natural England due to being an ancient coppice-with-

standards wood. Ancient woodland can be adversely affected by increased visitor pressure

that could arise from the proposed development. However, the Ecological Appraisal has set

out that because there are no formal routes of access to the SSSI from the Site (for example,

PROWs), the alternative routes via farm tracks are between 2km and 4km walking distance

on private land and because the proposal makes provision for a significant amount of Public

Open Space (POS), the SSSI is unlikely to be subject to any increases in visitation. Therefore

it is not anticipated that there will be any adverse effects on the SSSI.

6.6.21 The Ecological Appraisal also establishes there will be no adverse impact on the local wildlife

or biodiversity. The new and retained trees and ecological features provide widened

opportunities for foraging and commuting for amphibians and bats.

6.6.22 As such, the proposal is compliant with policy CS5.

Policy CS6 – Services and Infrastructure

6.6.23 MSDC state that new development is expected to provide or support the delivery of

appropriate and accessible infrastructure to meet the justifiable needs of new development.

Local priorities for which infrastructure contributions may be sought include utility provision,

transport infrastructure, healthcare, education, libraries, social and community facilities,


56

village service and facilities, community safety, open space, sport, cultural and leisure

facilities, green infrastructure, improvements in public transport, improvements to pedestrian

and cycle routes, and more.

6.6.24 Draft Heads of Terms are enclosed in Appendix 3. They will be reviewed during the

determination process. Gladman will accept contributions which are demonstrated to meet

the CIL terms. The proposal is able to comply with policy CS6.

Policy CS9 – Density and Mix 6.6.25 In this policy, MSDC outline that new housing developments should provide a mix of house

types, sizes and affordability to cater for different accommodation needs. Density should

average at least 30 dwellings per hectare, unless special local circumstances dictate

otherwise. Lower densities may be justified in villages to take account of the character and

appearance of the existing built environment.

6.6.26 As set out in the Framework Plan, the proposed development has an indicative density of 26

dwellings per hectare. This is lower than the guideline of an average of 30 set out in this

policy, however it is considered appropriate for the existing character and built environment

of Stowupland.

6.6.27 Furthermore the development consists of a mix of 1, 2, 3, 4 and 5 bedroom properties,

catering for a large variety of people and the local need. 25% affordable housing is proposed

to be on-Site and a contribution for 15% off-Site which will cater to first-time buyers, small

families and young people. This makes provision for 40% affordable housing in total,

exceeding the policy requirement.

6.7 Relevant policies of the Adopted Core Strategy Focused Review

2012

6.7.1 This update, adopted in December 2012, supersedes some elements of the 2008 Core

Strategy, namely housing policy CS8 “Provision and Distribution of Housing”. The need for a

review was considered necessary by MSDC due to “important changes of circumstances

including the passage of time, further detailed research, analysis, representations, the

National Planning Policy Framework (NPPF) and above all, evidence that has come out of the

development of other plans including the Stowmarket Area Action Plan.”

6.7.2 The following relevant policies are those set out in the 2012 Core Strategy focused review.


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Policy FC1 and FC1.1 – Presumption in Favour of Sustainable Development / Mid Suffolk Approach to Sustainable Development.

6.7.3 In accordance with paragraph 49 of the Framework, “When considering development

proposals the Council will take a positive approach that reflects the presumption in favour of

sustainable development contained in the National Planning Policy Framework. It will always

work proactively with applicants jointly to find solutions which mean that proposal can be

approved wherever possible, and to secure development that improves the economic, social

and environmental conditions in the area. Planning applications that accord with the policies

in this Local Plan (and, where relevant, with polices in Neighbourhood Plans) will be approved

without delay unless material considerations indicate otherwise. Where there are no policies

relevant to the application or relevant policies are out of date at the time of making the

decision then the Council will grant permission unless material considerations indicate

otherwise – taking into account whether: Any adverse impacts of granting permission would

significantly and demonstrably outweigh the benefits, when assessed against the policies in

the National Planning Policy Framework taken as a whole; or Specific policies in that

Framework indicate that development should be restricted.”

6.7.4 As outlined in the Chapter 7, Gladman have demonstrated that MSDC cannot demonstrate a

5 year supply of deliverable housing sites, similarly the Local Plan is out-of-date and ‘principle

policies’ of the Development Plan are out-of-date by virtue of their inconsistency with the

Framework, the presumption in favour of sustainable development therefore applies.

6.7.5 This Statement has set out a number of key benefits which the proposal would bring deliver

a social, environmental and economic level, which must be a material consideration when

deciding this application as per Section 38(6) of the Planning and Compulsory Purchase Act

2004. As outlined in the accompanying reports and set out across this Statement, there are

no adverse impacts that arise from the development which would significantly and

demonstrably outweigh the benefits of the proposal (Gladman emphasis). The proposal

should therefore, using the wording of policy FC1, be “approved without delay” as it

represents a sustainable development.

6.7.6 Gladman sought at the pre-application stage to work with Officers, this is documented in the

SCI.

Policy FC2 – Provision and Distribution of Housing 6.7.7 The policy seeks that, from 2012, Mid Suffolk aim to deliver 2,625 homes and associated

infrastructure over a 15-year period. In Key Service Centres, which includes Stowupland

according to policy CS1, 450 dwellings on greenfield sites are aimed to be delivered over 15

years, with 100 on greenfield sites in the first 5 years (2012-2017). Additionally, 300 dwellings

are aimed to be delivered on Previously Developed Land (PDL).


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6.7.8 According to the most recent AMR (May 2014) Housing Trajectory, as of March 2014 106

dwellings of 356 units for a permission in Great Blakeham (A Key Service Centre) have been

built. A further 250 are expected to come forward between 2014-2019. 190 dwellings have

been directed to Elmswell for the period 2014-2019, also a Key Service Centre, as have 167

in Bramford in the same period. However, all of these schemes are on PDL sites, a former

cement works, bacon factory and undisclosed factory respectively, and would not contribute

to the 450 greenfield target.

6.7.9 The proposed development consists of 190 dwellings to be delivered over 5-years, providing

a healthy contribution to the 450 required over the 15-year Plan period. However paragraph

49 of the Framework advocates that relevant policies for the supply of housing should not be

considered up-to-date if the Local Planning Authority cannot demonstrate a five year supply

of deliverable housing. As set out in the next Chapter, MSDC do not have a 5-year supply of

deliverable housing so therefore this policy is considered out-of-date and should have no

weight to the determination of this application.

6.8 Relevant policies of the Stowmarket Area Action Plan 2013

6.8.1 The Stowmarket Area Action Plan, adopted February 2013, sets out relevant planning policies

to guide future development in Stowmarket and the nine settlements that border its existing

Plan boundary, which includes Stowupland according to Map 4.1. It also allocates specific

sites to ensure that there is sufficient land for future growth in employment, housing, retail

and recreation within the identified area, none of which are in Stowupland. This document is

supplementary to the adopted Core Strategy 2008/2012 and plans from a 15-year period from

2012.

6.8.2 It was decided by planning officers to direct the entirety of the Stowmarket Area Action Plan

proposed greenfield allocations of 1,525 dwellings to the Stowmarket settlement itself, despite

the area boundary also covering Key Service Centres like Stowupland and Haughley. However,

this does not mean that these settlements no longer have potential for growth; the Focused

Review target of 450 greenfield dwellings still applies to settlements like Stowupland.

6.8.3 Worthy of note is paragraph 6.2 in the Stowmarket Area Action Plan, which states that there

is a need to allocate further areas of greenfield land on the fringe of the town to meet future

housing requirements. Stowupland exists as a settlement on Stowmarket’s fringe, within the

AAP policy area.


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6.8.4 The following relevant policies are those set out in the Stowmarket Area Action Plan.

Policy SAAP 4.1 – Presumption in Favour of Sustainable Development 6.8.5 This policy is a reiteration of policy FC1/FC1.1 in the Core Strategy Focused Review 2012,

setting out a presumption in favour of sustainable development. As set out earlier, Gladman

consider the development represents a sustainable development and therefore compliant with

policy SAAP 4.1. In the absence of a 5-year deliverable housing land supply and/or out-of-

date ‘principle policies’ of the Development Plan, there should be a presumption in favour of

the proposal.

Policy SAAP 4.2 – Providing a Landscape Setting for Stowmarket 6.8.6 In this policy, development in the Action Area must, where appropriate, enhance the quality

of the wider green infrastructure network to maximise the conservation and enhancement of

its biodiversity and increase its accessibility and community value. The Council will also resist

development that would have a harmful effect on the value of a Visually Important Open

Space and will require developments that may have a detrimental effect on the quality of a

Visually Important Open Space to be sensitively designed to minimise these effects.

6.8.7 The Ecology and Arboricultural Assessments set out that the large majority of existing

landscape features will be retained and enhanced. Where new Open Space is provided, so

are public footpaths as set out in the Framework Plan, to enable good access and interaction

from new and existing residents.

6.8.8 The LVIA considers the proposal has the potential to accommodate a well-planned residential


context.

6.8.9 The proposal is therefore compliant with policy SAAP 4.2.

Policy SAAP 6.1 – Housing and Waste Storage 6.8.10 The Council require that all new dwellings should include space to accommodate three 240

litre wheeled bins, with consideration for communal waste storage areas for clusters of

dwellings and flat/apartments.

6.8.11 This can be addressed at the Reserved Matters stage in order to be compliant with policy

SAAP 6.1. The Illustrative Masterplan demonstrates 190 properties with private space could

be accommodated on the Site. This private space/gardens can accommodate the relevant

wheeled bins.

Policy SAAP 6.4 – Development in the Villages


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6.8.12 It is expected that proposals within or abutting the development boundaries of the

settlements in the Action Plan Area will conform to existing Development Plan policies.

Approved development will have to contribute to the Infrastructure Delivery Programme

(IDP).

6.8.13 The preceding paragraphs have covered how the proposal is in accordance with the relevant

Development Plan policies and is therefore compliant with policy SAAP 6.4 in this regard.

6.8.14 The specific schemes to which any given development will contribute to the IDP will be

determined upon the receipt of planning applications and through planning obligations, as set

out in SAAP Policy 11.1, which is covered in more detail shortly.

Policy SAAP 8.1 – Developer Contributions to a Sustainable Transport Network 6.8.15 MSDC outline in this policy that development within the Stowmarket Area Action Plan area

will be planned in order to reduce the need to travel and encourage walking, cycling and use

of public transport. New development will need to contribute to the network of transport

infrastructure. Proposals will also be assessed in terms of impact on the road network, traffic

capacity, highway safety, environmental impact of traffic generated, pedestrian and cycle

accessibility and availability and access to public transport. Additionally, developers should

make direct provision of the necessary transport infrastructure relating to the Site of the

development, or contribute to some elsewhere.

6.8.16 As established in the Framework Plan, the development maintains, enhances and increases

connectivity between existing PROWs throughout the Site, encouraging walking and

improving the local network. It also creates new pathways. The Transport Assessment

concludes that traffic could be accommodated within the highway network safely. As part of

the benefits of the proposal, local bus stops will be improved with new shelters, seating and

RTI, encouraging people to use public transport.

6.8.17 The proposal is therefore in line with policy SAAP 8.1.

Policy SAAP 9.1 – Biodiversity Measures 6.8.18 MSDC will aim to protect the Stowmarket Action Area’s biodiversity and geodiversity based

on existing policies, as well as the Area Action Plan Map 9.1. All development proposals must

provide an ecological survey which sets out impact on protected species and habitats, also

outlining any mitigation techniques, demonstrate how they will contribute and integrate in full

the Suffolk Biodiversity Action Plan targets, retain mature trees, ensure linkages with the

surrounding countryside, plant treebelts where the Site borders open countryside and provide

advance landscape planting to ensure the visual impact of future development is mitigated.


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6.8.19 An Ecological Appraisal has been submitted with this application that concludes that there is

no adverse impact on any protected species or Site biodiversity. It in fact concludes that the

retention and addition of hedgerows may encourage commuting and foraging opportunities

for amphibians. A supplementary report concluded there was no impact on the local

population of Great Crested Newts. The Arboricultural Assessment sets out that the vast

majority of trees and hedgerows, including mature specimens, are to be retained.

6.8.20 The objectives of the Suffolk Biodiversity Action Plan are as follows.

“1. Ensure development avoids adverse impacts on biodiversity

2. Where avoidance is not possible, mitigate residual impacts of developments. (Not

applicable in this instance)

3. Where mitigation is not possible, compensate for losses incurred during development.

4. Enhance developments for biodiversity. (Not applicable in this instance).

5. Ensure biodiversity is taken into consideration during, and after, the construction phase of

development.”

6.8.21 As outlined in the Framework Plan, over 25% of the site consists of green infrastructure

including open space and new hedgerows and trees. Furthermore, linkages to the outside

countryside are being improved by enhancement and creation of new and existing PROWs.

Furthermore, a contribution will be made to improve external PROWs.

6.8.22 For these reasons, the proposal is compliant with the requirements of policy SAAP 9.1.

Policy SAAP 9.5 – Historic Environment 6.8.23 Development in settlements in the Action Plan Area should protect the historic landscape

including natural and man-made landmarks. Listed Buildings and their setting will be

protected.

6.8.24 No Listed Buildings are present on the Site, though the proposal is within close proximity to

a number of Grade II Listed Buildings and a Grade II* Listed Building on Church Road and

Gipping Road. Figure 11 in the Heritage Statement submitted with this application shows the

location of the Listed Buildings within proximity to the Site. The conclusion of the Heritage

Statement submitted with this application is that, after a detailed assessment, the proposal

will not affect the heritage assets’ significant nor affect the contribution that their setting adds

to their significance.

6.8.25 Therefore this proposals is compliant with policy SAAP 9.5.


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Policy SAAP 10.2 – Provision of Accessible Natural Greenspace 6.8.26 In accordance with Natural England guidelines for 'Accessible Natural Greenspace Model'

(ANGSt), the Council will seek to ensure that every home is within 300 metres of at least one

accessible green space of 2 hectares.

6.8.27 English Nature, in devising the Accessible Natural Greenspace Standard, defined natural

greenspace as ‘areas naturally colonised by plants and animals’. The Site adjoins areas of

open countryside, home to wildlife and vegetation, which are accessible by, but not limited

to, existing PROWs. Thus the proposal is compliant with policy SAAP 10.2, as homes are

within 300m to adjoining open countryside.

Policy SAAP 10.3 – Improving the Quality of Open Spaces

6.8.28 Development that increases the provision, accessibility, quality and connectivity of open

spaces will be supported. In particular, MSDC are looking to provide improvements to the

network of green open spaces and footpaths/cycle routes, as well as improvements to the

public realm that include leisure, recreation and other cultural uses.

6.8.29 The proposed development complies with this policy, because it seeks to create, maintain and

improve existing PROWs and increase their connectivity to areas outside of the development

Site. Furthermore the proposal includes an equipped area of play for children, which serves

as a recreational use. Over 25% of the Site area is provided as open space. The proposal is

therefore compliant with policy SAAP 10.3.

Policy SAAP 11.1 Developer Contributions to Infrastructure Delivery 6.8.30 This policy dictates that all development within the Stowmarket Area Action Plan will be

required to provide for the supporting infrastructure they necessitate. The specific schemes

to which any given development will contribute will be determined upon the receipt of

planning applications, having regard to the anticipated impacts of the development and,

where relevant, viability. The test for relevance for planning obligations are set out in

paragraph 204 of the Framework. Infrastructure will be delivered through obligations after

viability appraisals have been prepared, the cost of which are covered by the developer.

6.8.31 Within the AAP area, developers should set out that the relevant infrastructure that is needed

to support and service their proposed development have either been incorporated into

proposed schemes or is provided through other appropriate means. Adequate capacity must

existing line with policy CS6. Following the adoption of a CIL, developers will be required to


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pay the CIL or through S106 agreements. Currently MSDC’s CIL is as draft charging schedule

stage and is undergoing consultation, from the 10th November and 24th December 2014.

6.8.32 No reliance on this can be provided. Gladman will accept all CIL compliant infrastructure

requests for building, therefore the proposal is compliant with policy SAAP 11.1.

Emerging Policies

6.8.33 MSDC are currently working on a joint Development Management and Site Allocations DPD

with Babergh District Council. However, this is still in the early stages; in June 2014 the two

authorities produced a Scoping Report. This was consulted on between the 13th of June and

the 18th of July 2014. The Council are currently considering the results of the consultation

exercise and are aiming to produce an Issues and Options paper in February 2015.

Development Plan Summary

6.8.34 It is acknowledged that with regard to Section 38(6) of the Planning and Compulsory Purchase

Act 2004 this application is a departure from the Development Plan.

6.8.35 The application is able to comply with all relevant policies which are considered to be

Framework compliant. All others in the context of the Framework are therefore out-of-date

as the Council cannot demonstrate a five year supply of deliverable housing sites.

6.8.36 The application supports the aspirations of the AAP to accommodate development on

greenfield land on the fringe of Stowmarket.

6.8.37 It has been demonstrated the proposal with the associated planning benefits constitute

sustainable development. MSDC cannot demonstrate a deliverable 5 year housing land supply,

and as the Local Plan is time-expired and the ‘principle policies’ of the Development Plan are

not Framework-compliant, therefore in line with paragraph 14 of the Framework planning

permission should be granted “unless any adverse impacts of doing so would significantly and

demonstrably outweigh the benefits, when assessed against the policies in this Framework

taken as a whole”.

6.8.38 There are no adverse impact of the development that would outweigh the significant benefits,

this is considered and evidenced further in the following Chapters.

6.8.39 The emerging Site Allocations and Development Management joint DPD does not constitute

a policy document but merely scopes the topics of policy to be included in any subsequent

Local Plan, it can be afforded no weight in line with paragraph 216 of the Framework.


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7 HOUSING LAND NEED AND SUPPLY

7.1 Overview

7.1.1 There is now a much stronger requirement to meet the full identified objectively assessed

need for market and affordable housing in order to meet the policy requirement of the

Framework and to boost the supply of housing.

7.1.2 MSDC’s most recently tested housing requirement was derived from the now revoked East of

England RSS. The East of England Regional Spatial Strategy (RSS) set out a target of 8,300

dwellings to be completed in Mid Suffolk in the 20-year period between 2001 and 2021. This

equates to a requirement of 415 dwellings per annum (dpa). In the adopted 2008 Core

Strategy, MSDC state in paragraph 3.40 that:

“The District Council proposes that housing requirements beyond 2021 are estimated on the

basis of a continuation of the same annual rate as that up to 2021 i.e. 415 houses per year.”

7.1.3 Consequently, the Core Strategy projects the annual requirement of 415 dwellings forward to

2025, to take account of the Core Strategy’s 2007-2025 Plan period. This results in a

requirement of 9,960 dwellings across the 2001-2025 period (8,300 + 1,660). As the Core

Strategy Plan period begins from 2007, the 2,692 dwelling completions between 2001 and

2007 were is removed from the requirement, resulting in a need of 7,268 dwellings for the

plan period 2007-2025.

7.1.4 Annualised, this equates to 404 dpa.

7.1.5 The Ipswich Study Area SHMA Update August 2012, which appears to be the latest SHMA

available from the Council, reiterates that MSDC establishes a target of 404 dpa in paragraph

11.2.9. It also states that in the process of a formal review of the Core Strategy (which

manifested as the December 2012 Core Strategy Focused Review), MSDC planned to increase

their general greenfield housing allocations from 2,140 dwellings to 2,625 dwellings.

7.1.6 Policy FC2 of the Core Strategy Focused Review 2012 sets out this increase in general

greenfield allocations. For the period 2012-2027, there are to be 2,625 dwellings delivered

across Mid Suffolk in greenfield sites. The 485 increase has been directed to the Stowmarket

area as part of the Stowmarket Area Action Plan, which, as demonstrated shortly, is factored

into the Council’s claimed supply.


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7.1.7 Regeneris, on behalf of Gladman, have produced an Objective Assessment of Housing Need

for the Mid Suffolk and Suffolk Coastal Housing Market Area. They state that the Objectively

Assessed Need for Mid Suffolk is 484 dpa.

7.1.8 This Chapter will consider the housing land supply situation for MSDC, providing a critique of

the Council’s current housing figure. It is considered that MSDC are unable to demonstrate a

five year supply of deliverable housing sites as required by paragraph 47 of the Framework

7.2 Current Housing Land Supply Position

7.2.1 The May 2014 AMR provides the most up-to-date assessment of the Council’s requirement

and 5-year housing land supply. In paragraph 4.16 MSDC again reiterate the annual

requirement is 404 dpa. They identify a shortfall of 61 dwellings from 2007, the beginning of

the adopted 2008 Core Strategy Plan period. In regards to a buffer, MSDC state in paragraph

4.20:




7.2.2 As such, MSDC consider a 5% buffer to be appropriate. After applying a 5% buffer to the 5-

year requirement (404 x 5) and 61-dwelling shortfall, MSDC identify a 5-year residual

requirement of 437 dpa. Against their claimed supply figure of 2,422, which incorporates the

new general allocations as part of the Stowmarket Area Action Plan and a windfall allowance,

the Council claim a supply of 5.5 years.

7.3 Objectively Assessed Need

7.3.1 From the information in the preceding paragraphs, it is clear that the Council’s housing

requirement is derived from the now-abolished East of England RSS. The evidence bases used

to inform the RSS requirement is significantly out-of-date. MSDC acknowledge this in the

Focused Review, stating in paragraph 4.6:

“Although the Core Strategy is in conformity with the Regional Spatial Strategy, which is to

be abolished, the Regional Spatial Strategy is not the only basis for establishing future housing

requirements and various other sources have been used as evidence for this update of the

Core Strategy. These include the Stowmarket Masterplan, 2008, Strategic Housing Market

Assessment (SHMA), Ipswich Housing Market Area, November 2008, and updates, and

Strategic Housing Land Availability Assessment (SHLAA) for Mid Suffolk, 2009 and 2010

update.”


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7.3.2 Despite using a variety of sources, the majority of these documents are significantly out-of-

date and were produced pre-NPPF. Consequently, MSDC’s adopted requirement is not derived

from up-to-date evidence, nor is it representative of an Objectively Assessed Need (OAN) as

set out by paragraph 47 of the NPPF.

7.3.3 It has been demonstrated in numerous judgements, in the first instance, the Court of Appeal

Judgement in Hunston, that where the housing requirement for the relevant area has not yet

been established, decision-makers must identify the full Objectively Assessed Need. This

judgement applies to NWLDC as it is currently in a policy vacuum, Sir David Keene at

paragraph 26 states:

“… it is not for an Inspector on a Section 78 appeal to seek to carry out some sort of

local plan process as part of determining the appeal, so as to arrive at a constrained

housing requirement figure… I have some sympathy for the Inspector, who was

seeking to interpret policies which were at best ambiguous when dealing with a

situation which existed here, but it seemed to me to have been mistaken to use a

figure for housing requirement below the full objectively assessed needs figure until

such time as the Local Plan process came up with a constrained figure.”

7.3.4 As set out in Hourigan Connolly’s Housing Land Supply Assessment submitted with this

application, the relevancy of the Hunston Judgement in the context of Mid Suffolk has been

discussed in the Mendlesham Case. The case relates to a recent unsuccessful appeal in the

District which considered the Council’s 5 year supply of deliverable housing16

7.3.5 The Appellant disputed the 5 year supply position. They argued that, as the housing

requirement set out in the RS was a minimum target which took account of constraints to

development, the Core Strategy Focussed Review’s requirement was based on a “policy

constrained” scenario and did not reflect the full objectively assessed need (OAN). The

Appellant went on to cite the relevance of the Hunston case (as discussed above) and claimed

that the Inspector appointed to assess the Core Strategy Focussed Review did not consider

whether the housing land supply targets complied with the requirements of the Framework.

7.3.6 The appeal Inspector disagreed with the relevance of the Hunston case as he stated that the

reliance of the Council upon RS figures in that situation took place in a policy vacuum, which

was not the case in Mid Suffolk. Moreover, he also disagreed that the Core Strategy Focussed

16 Appeal by GR Warehousing Ltd against the refusal of planning permission for the demolition of the GR

Warehousing facility and storage buildings, along with redevelopment of the site to provide 51 dwellings (PINS Reference: APP/W3520/A/13/2199563).


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Review Inspector had not considered whether the housing land requirements were

Framework compliant, stating that:

“In particular, one of the main issues upon which the soundness of the CSFR depended, as

identified by that Inspector, specifically explored “whether the amount and distribution of

housing land would meet the full objectively assessed need for market and affordable housing

in the housing market area, as far as would be consistent with the policies of the Framework”.

It also explored “whether the housing provision would be deliverable within the plan period.”

7.3.7 Whilst the Core Strategy Focussed Review Inspector clearly does look at the issue of housing

land supply, the work undertaken by Regeneris clearly demonstrates that the issue of full

OAN was not dealt with comprehensively. The Core Strategy Focussed Review Inspector

states that:

“The Council has taken the opportunity in the CSFR to review its housing figures, the

distribution of housing across the District and to update the figures for 15 years. The provision

is consistent with the RS as earlier reported, which requires a minimum provision and is not

a ceiling.”

7.3.8 Other than discussing the consistency with the RS, the Inspector does not go on to discuss

the actual requirement in any further detail. Indeed the remainder of the Inspector’s

assessment focuses more upon the distribution of housing rather than the overall numerical

requirement. Furthermore, the Council’s requirement is based upon an extrapolation of the

RS target from April 2021 to March 2025 to cover the full Core Strategy Plan period. Again,

in the context of new evidence from Regeneris this cannot represent full OAN as the

Framework requires as it merely replicates the RS figures which are constrained. This

extrapolation for this additional four year period is relevant as it has implications for the

average annual requirement figure.

7.3.9 In any event each case should be considered on its merits having regard to the evidence

available to the decision maker. In that respect there is now important evidence available to

the Council via the Regeneris work that ought to be considered in assessing any planning

application put forward by our client and having regard to the provisions of Paragraph 30 of

the PPG.


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7.3.10 The appeal at Shottery17 engaged with an assessment of the full Objectively Assessed Need.

The Council in that case sought to use an assessment of the 5 year supply based on RS review

data that was subsequently below the most recent evidence based assessment (a report by

GL Hearn). The Inspector considered this evidence was more recent than that used for the

RS:

“However the expert assessments are based on the most up to date available

information and consider a range of factors before arriving at the recommended option.

The GL Hearn study provides a more recent evidence base than the RSS Review panel

[43-45]. I therefore consider that the figure for 11,000-12,000 dwellings for the period

2008-2028 accords more closely with the full, objectively assessed needs for market

and affordable housing required to be met under the Framework than the Council’s

figure of 8,000 dwellings.”

7.3.11 The Secretary of State (SoS) supported this conclusion, stating:

“he notes that there is disagreement over the 5 year land requirement and supply

position, and that the Framework requires local planning authorities to plan for the full,

objectively assessed needs for market and affordable housing in the housing market

area, as far as is consistent with the polices of the Framework (IR489). For the reasons

given by the Inspector on the information currently before him, he considers that the

figure of 11,000-12,000 dwellings for the period 2008-2028 more closely accords with

the requirements of the Framework (IR 492)”,

7.3.12 The first ground of the subsequent S288 Challenge was that the Inspector erred in law in

assessing supply against a requirement of 11,000-12,000 homes. Hickinbottom J considered

this matter in some detail in his Judgement. He concluded:

“…the housing requirement position must be considered when a planning application

is made for housing development.”18

7.3.13 He added that the SoS’s decision did not bind the Council as to its future housing requirement

in an emerging LP nor did it bind another Inspector or the SoS, as to the housing requirement

figure in other applications or appeals.

17 Land west of Shottery, south of Alchester Road and North of Evesham Road, Stratford‐upon‐Avon CV37 9RX

(APP/J3720/A/11/2163206) (24‐10‐12) 18 Stratford on Avon District Council v SoS & J S Bloor Limited & Hallam Land Limited & RASE (2013 EWHC 2074) Judgment of

Mr Justice Hickinbottom (18‐07‐13).


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7.3.14 The Barwood Land case19 arrived at the same conclusions20. Specifically, paragraph 32 states:

“A revoked RSS is not a basis for the application of a constraint policy to the assessment

of housing needs, because it has been revoked and cannot be part of the Development

Plan. The same would be true of an out- of date Local Plan which did not set out the

current full objectively assessed needs. Until the full, objectively assessed needs are

qualified by the polices of an up to date Local Plan, they are the needs which go into

the balance against any NPPF polices. It is at that stage that constraints or otherwise

may apply. It may be problematic in its application, but that is how paragraph 47

works.”

7.3.15 Further to the above the PPG21 has also provided guidance on the approach taken to decision

making when there is no up to date Local Plan in place:

“It should be borne in mind that evidence which dates back several years, such as that

drawn from revoked regional strategies, may not adequately reflect current needs.

Where evidence in Local Plans has become outdated and policies in emerging plans

are not yet capable of carrying sufficient weight, information provided in the latest full

assessment of housing needs should be considered.”

7.3.16 Gladman have commissioned Regeneris to produce a report identifying the full Objectively

Assessed Need for the Mid Suffolk and Suffolk Coastal Housing Market Area. This OAN figure

has been produced in line with guidance set out in the PPG and complies with national

planning policy. Gladman believe that the Council’s housing requirement does not reflect the

true level of housing need in the HMA and, as such does not fully comply with the Framework

or the guidance set out in the PPG.

7.3.17 Gladman believe that the figure produced in the updated Regeneris OAN is the most up to

date full Objectively Assessed Need for MSDC and the OAN figure of 484 dpa should be used

in the calculation of the District’s housing supply.

7.3.18 To summarise, the following table outlines the OAN figures produced for MSDC:

19 South Northamptonshire v Barwood Land and Estates Limited (2014 EWHC 573) Judgement of Mr Justice Ouseley (10‐03‐14) 20 Refer to paragraphs 30‐32 21 NPPG (2014) reference ID: 3‐030‐20140306


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Table 3: Comparison of available housing need figures

Source Figure (dpa)

MSDC 404

Regeneris OAN 484

7.4 Previous Housing Delivery

7.4.1 In calculating the backlog for their five year housing land supply position, MSDC have

incorporated housing delivery since 2007, the beginning of the adopted 2008 Core Strategy

Plan period. This approach gives the Council an undersupply of 61 dwellings from 2007 to

2014.

7.4.2 As outlined by Hourigan Connolly, who have produced a Housing Land Supply Assessment of

MSDC (submitted with this application), the Regeneris employment led OAN figure results in

a shortfall of 106 dwellings for the period 1 April 2012 to 31 March 2014. In considering

shortfall against the Regeneris OAN figure, Hourigan Connolly have not made any allowance

for under-performance against the Core Strategy for the period 1 April 2007 to 31 March

2014. If this was the case, a further 115 dwellings would need to be added to the 5-year

requirement. Table 4 below demonstrates this approach.

Table 4: Backlog against RSS and OAN

Period RSS-based

requirement

(dpa)

OAN

requirement

(dpa)

Delivery Shortfall

(RSS-based

requirement)

Shortfall

(OAN

requirement)

2007/08 404 - 489 +85 -

2008/09 404 - 398 -6 -

2009/10 404 - 292 -112 -

2010/11 404 - 330 -74 -

2011/12 404 - 396 -8 -

2012/13 404 484 313 -91 -171

2013/14 404 484 549 +145 +65

Total 2,828 968 2,767 -61 -106


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7.5 Application of the Buffer

7.5.1 In regard to a buffer, MSDC state in paragraph 4.20 of their adopted Core Strategy:




7.5.2 Thus MSDC deem it appropriate to apply a 5% buffer to their 5 year housing land supply

calculations.

7.5.3 Considering the Council’s delivery against their adopted target, Hourigan Connolly state Mid

Suffolk is not considered to be persistently under-performing and the use of a 5% buffer is

justified. The matter will need to be kept under regular review however.

7.5.4 As such Gladman will use this approach to calculate MSDC housing land supply below.

7.6 Housing Land Supply Assessment

7.6.1 The table below draws together the evidence Gladman have produced above to calculate

MSDC current five year supply of deliverable housing. To note Gladman are using the Council’s

claimed supply figure of For comparison, the table below will use the Council’s adopted figure

and Gladman’s OAN figure:

Table 5: Gladman’s five year housing land assessment for NWLDC between 2014 and 2019

Five Year Housing Requirement – 2014 - 2019

Source MSDC Requirement (404

dpa)

Regeneris OAN (484

dpa)

Housing requirement 2014 – 2019 2,020 2,420

Previous under supply

(MSDC – 2007-2014)

(Regeneris/Hourigan Connelly –

2012/2014)

61 106

Sub total 2,081 2,526

Buffer 5% 104 126

5 year requirement for MSDC 2,185 2,652

Annualised requirement 437 530

Identified supply 2,422 1,742

Number of years supply 5.5 3.29


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7.6.2 As demonstrated above the Council cannot demonstrate a five year supply of deliverable

housing. Gladman have demonstrated that MSDC have a housing land supply of 3.29 years,

as such the housing policies of Development Plan are not considered up-to-date in regards to

paragraph 49 of the Framework.


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8 THE PLANNING BALANCE

8.1 Introduction

8.1.1 This Chapter draws together the information from the preceding Chapters of this Statement.

It sets out the overall planning case for granting planning permission on the Site.

8.1.2 Gladman have demonstrated that the Council cannot demonstrate a 5 year deliverable

housing land supply, against the Gladman’s commissioned OAN, MSDC can demonstrate a

3.29 years supply, constituting a substantial shortfall and a position which must be rectified

immediately and it is the Local Authority’s responsibility to do so.

8.1.3 As demonstrated by the earlier Chapters, the application proposals represent sustainable

development and the key consideration therefore is whether there are significant and

demonstrable adverse impacts that would outweigh its benefits and thus the presumption in

favour of sustainable development.

8.2 An Urgent Housing Need

8.2.1 The Framework seeks to boost significantly the supply of housing22. It clearly states that

where a Council cannot demonstrate a 5 year supply of deliverable land the Local Plan policies

should not be considered up to date.

8.2.2 The District has experienced under delivery of housing since 2007 as demonstrated by the

Chapter 7 of this statement. Consequently following a thorough housing land supply

assessment which forms part of this planning application submission, MSDC cannot

demonstrate a 5 year deliverable housing land supply. Gladman’s assessment confirms the

Council only have 3.29 years of deliverable housing supply.

8.2.3 Paragraph 49 of the Framework dictates “…relevant polices for the supply of housing should

not be considered up to date if the local planning authority cannot demonstrate a five-year

supply of deliverable housing sites.”

8.2.4 The Council cannot demonstrate a deliverable five year supply of land for housing using

Gladman’s OAN or their own RSS-based requirement against Hourigan Connolly’s revised

supply figure of 1,742 dwellings (4.41 years). MSDC have an obligation to comply with the

Framework and in particular the requirement to demonstrate a deliverable 5 year housing

land supply.

22 NPPF, 2012, paragraph 47


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8.2.5 Paragraph 14 of the Framework is therefore engaged, it states “….where the development

Plan is absent, silent or relevant polices are out-of-date…” the requirement on the decision

maker is to conclude whether firstly the proposed development would be sustainable and

secondly if it is whether any adverse impacts would “…significantly and demonstrably…’”

outweigh the benefits.

8.2.6 The Council can only demonstrate 3.29 years supply of deliverable housing. The principle

policies of the Development Plan are out-of-date. Paragraph 14 of the Framework is therefore

engaged.

8.2.7 However, any housing land supply assessment should now also be considered in the context

of a recent appeal decision in Launceston, Cornwall23. In that case, the Inspector accepted

that the Council could demonstrate a 5 year supply of housing land but found that provided

the Site was sustainable, an excess of permissions is not harmful in the context of the

Framework. This represents a signal change in the interpretation of housing land supply

arguments and reflects the clear emphasis on housing delivery and thus the aspirations of

the Framework. The Inspector concluded:

“Nevertheless, irrespective of whether the five year housing land supply figure is met

or not, NPPF does not suggest that this has to be regarded as a ceiling or upper limit

on permissions. On the basis that there would be no harm from a scheme, or that the

benefits would demonstrably outweigh the harm, then the view that satisfying a 5 year

housing land supply figure should represent some kind of limit or bar to further

permissions is considerably diminished, if not rendered irrelevant. An excess of

permissions in a situation where supply may already meet the estimated level of need

does not represent harm, having regard to the objectives of NPPF.”

8.3 Proposed Harm and Benefits of the Development

8.3.1 Appendix 5 demonstrates limited harm will arrive from the development. As per the advice

from the Droitwich Spa Inspector24 it is for the Local Authority to demonstrate the ‘significant

gravity’ of harm. However, there are a significant number of qualitative and quantitative

benefits that will arise from the proposed development, these are considered in more detail

below.

8.3.2 The grant of planning permission now, on this Site, will improve the Council’s portfolio of

suitable, available and deliverable housing sites and will help towards addressing the need of

23 APP/D0840/A/13/2209757 24 Droitwich Spa APP/M1840/A/13/2199085


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housing land in Mid Suffolk. It is apparent that there are no adverse impacts from the housing

element of the scheme which would outweigh the significant benefits:

Provision of 2.84 ha of the Site as public open space, this will offer intrinsic ecological

value, providing a more diverse range of habitats than what is already present;

Increasing housing supply to help meet the Council’s immediate housing needs;

Providing a wide choice of quality homes, including affordable housing meeting

significant and marked contribution that would be real benefit for which there is a

present need to address;

Providing housing in an accessible location;

Easy access by all modes of transport to all types of service, retail and leisure facilities,

and employment opportunities;

Existing trees and hedgerows will be maintained and enhanced through additional

planting thus preserving its longevity and providing a valuable ecological resource i.e.

benefiting wildlife such as bats and amphibians;

New structural landscaping along the east and west boundaries of the proposed

development will provide new wildlife corridors;

Improvements to Public Rights of Way (PROWs);

A contribution to improve footpaths from the Site to the school and to the Post Office.

Improvements to bus stops, providing new shelters, seating and Real-Time

Information (RTI);

Control drainage run off from the Site to remove the potential flooding elsewhere

and;

Providing public open space and children’s play facilities to benefit existing and new

residents.

8.4 Compliance with Planning Policy

8.4.1 The proposal accords with the Government’s policies enshrined within the Framework in so

far as they will deliver sustainable development to meet the growth needs of MSDC.

8.4.2 This Statement has considered in detail the Site’s context and its sustainability credentials set

against the 3 dimensions of the Framework.

8.4.3 The assessment of sustainability provides the context for the balancing exercise the

Framework requires, where the Development Plan is absent, silent or lacks relevant polices.

8.4.4 In terms of the 3 dimensions of sustainable development (economic, social and

environmental). The Site is located in an accessible location in close proximity to a number of

day to day services (as detailed in the Sustainability Matrix within Appendix 1) and will


76

provide significant economic support that will reinforce the vitality and viability of the

settlement and its community. The proposals benefit from the presumption in favour

of sustainable development. Gladman have clearly identified a number of significant

benefits that will arise from the proposed development which in turn would outweigh any

limited harm.

8.4.5 Paragraph 17 of the Framework also recognises the intrinsic nature of the countryside as a

Core Planning Principle. The application Site is located in an area that has previously been

identified as open countryside (although as addressed above in Chapter 6 no weight is given

to this policy designation). There will be a change to the landscape by virtue of transformation

from agricultural land to a development of up to 190 houses and this is indisputable,

irrespective of the level of mitigation provided at the Reserved Matters stage by way of a

creative layout and landscaping to reduce the proposed development’s built form. Therefore,

the matter for consideration is how significant that impact is likely to be, thus whether it

would represent substantial material harm and the assessment required by paragraph 14 of

the Framework to establish if any adverse impacts would significantly and demonstrably

outweigh the benefits. It is for the Council to demonstrate the ‘significant gravity’ of harm

which would outweigh the benefits of the development.

8.4.6 The Site adjoins existing complimentary residential development along the north west and

southern western boundaries. Therefore the Site in physical terms cannot be considered to

be within the open countryside.

8.4.7 Overall it is considered that the proposed residential development would not be out of scale

or context with the nature of the landscape in which it is proposed. Any impact on the

character of the landscape will be offset by the retention and enhancement of existing field

boundaries, trees, hedgerows and the existing Site topography.

8.4.8 Conversion of agricultural land to residential use would be a fundamental change to the

landscape, however, Gladman do not consider this would result in substantial damage when

seen in the wider context of this Appraisal, the extensive landscaping and open space

provision. Gladman conclude its impact would not result in significant material harm (as per

the terms of paragraph 14 of the Framework), which would demonstrably and significantly

outweigh all the other benefits the application will bring.

8.4.9 This proposal will make an immediate and positive impact towards remediating the District-

wide chronic shortage of both market and affordable housing, which is a significant material

consideration.


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8.5 Affordable Housing

8.5.1 The application proposal will deliver affordable housing which will immediately assist the

Council in helping to begin to remediate the shortage of affordable homes. The level of

affordable housing proposed exceeds the policy requirement of 35%, with 40%, 25%

provided on-Site and a provision for 15% off-Site subject to discussions with Officers.

Gladman consider the additional percentage of affordable dwellings to be provided must carry

very substantial weight;

8.6 Accessibility

8.6.1 The Site can be accessed satisfactorily and safely in terms of junction design and the

development offers the opportunity for walking and cycling linkages within the proposed

development and to the local services in Stowupland, with good public transport links to the

nearby Stowmarket.

8.6.2 In summary, the proposals for a residential development will provide a sustainable

development in transport terms and planning permission should be granted in accordance

with the Framework.

8.7 Green Space

8.7.1 The existing hedgerow and tree features will, wherever possible, be integrated into the areas

of formal and informal public open spaces and will be maintained and enhanced with

additional landscape plating to maximise the recreational value of these areas. This is a major

benefit as the Site is not actively managed or maintained now.

8.7.2 These features, together with new structure planting will provide for a high quality

environment for the benefit of the future community. The formal open spaces will be linked

to the existing PROWs, could create pedestrian and cycle route around the Site and will

provide pleasant and attractive routes that will encourage people to walk and cycle throughout

the scheme. The application proposals will increase the accessible and useable formal and

informal open space provision in by approximately 25% of the total Site area for the benefit

of existing residents as well as new. This is a major benefit to the local area.

8.8 New Homes Bonus

8.8.1 Using the Department for Communities and Local Government New Homes Bonus calculator

MSDC would gain in the order of £1.4 million pounds. The materiality of this is recognised in

the Localism Act 2011.


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8.9 New Employment and Economic Benefits

8.9.1 It is widely acknowledged that residential development has the ability to contribute to job

creation through the development and investment in infrastructure. There are in addition

lasting benefits associated with a new residential development relating to the new resident

population, the household expenditure in the area and its contribution to the size and depth

of the local labour force our economic appraisal predicts the total construction costs to be in

the region of £22 million which in turn would support 400 construction jobs over construction

period.

8.9.2 It is estimated that the total expenditure generated by the new households would reach a

total of £1.3 million per annum in the wider District. Thus providing a boost to the local

shopping area and the District in turn contributing to the areas long term economic and social

sustainability.

8.9.3 Furthermore, once completed the development could attract skilled and well educated people,

therefore benefitting existing local employers.

8.10 Summary

8.10.1 MSDC cannot demonstrate a five year supply of deliverable Sites and the Council are currently

relying on a housing target which does not represent an objectively assessed need.

8.10.2 Decision Makers are reminded that in particular the Guidance states that if decision-makers

choose not to follow the Framework, (Gladman emphasis) clear and convincing reasons

for doing so are needed.

8.10.3 Whilst emphasising the need to balance the 3 dimensions, paragraph 19 states:

“The Government is committed to ensuring that the planning system does everything

it can to support sustainable economic growth. Planning should operate to encourage

and not act as an impediment to sustainable growth. Therefore significant weight

should be placed on the need to support economic growth through the planning

system.”

8.10.4 Gladman’s proposal strongly accords with the aims of the Framework in so far as it will deliver

sustainable development. The Site is located in an accessible location close to the key services

and will provide significant economic support for Stowupland and the surrounding area.

8.10.5 The proposal benefits from the presumption in favour of sustainable development

(Gladman emphasis).


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9 SUMMARY & CONCLUSIONS

9.1 The Application


dwellings with all matters reserved, save for that of access. Whilst an Indicative Masterplan

is provided within the D&A that illustrates how the Site could be developed and demonstrates

an appropriate development capacity linked to density, it is not for determination at this stage.

9.2 Vision - The Design Objectives

9.2.1 The D&A accompanying this application demonstrates that the proposals are based on sound

design principles that have properly had regard to and addressed the Site constraints and

opportunities. The scheme achieves good integration with the existing settlement of

Stowupland and the surrounding area. The overarching objectives of the Framework Plan is

to provide a good mix of housing sizes and tenures within a high quality residential

environment.

9.3 Delivery

9.3.1 The Site is able to fully comply with the requirement of footnote 11 of the Framework and

the terms of delivery identified. Following a grant of consent, the Site would be marketed by

Gladman and sold to one or more house builders who would submit the required Reserved

Matters application(s).

9.4 Accordance with the National Planning Policy Framework

9.4.1 The Gladman proposal strongly accords with the aims of the Framework in so far as it will

deliver sustainable development.

9.4.2 The Framework sets out the Government’s key housing objective, which is; “to boost

significantly the supply of housing”. Paragraph 47 sets out how LPAs should achieve this boost

in the supply of housing, through a key requirement to demonstrate a five year supply of

deliverable land for housing based upon a full objective needs assessment of future housing

requirements.

9.4.3 It is MSDC’s responsibility to accord with this national policy objective. The evidence put

forward by Gladman has demonstrated that the Council have a significant housing land supply

shortfall that will not be rectified by using the Council’s RSS-based requirement. This

application will deliver new housing development which will assist MSDC by contributing

towards the Central Government objective of significantly boosting the supply of housing.


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9.4.4 MSDC have incorrectly assessed their requirement figure and as a result they do not have a

five year supply of deliverable housing. Using the Council’s housing requirement, as

demonstrated previously, MSDC can only demonstrate a 4.41 years supply against Hourigan

Connolly’s revised housing supply figure of 1,742 dwellings. Against Regeneris’ OAN, the

Council can only demonstrate a 3.29 year supply.

9.4.5 The Site is located in an accessible location close to the key services and will provide

significant economic support for the vitality and viability of Stowupland. The proposal

benefits from the presumption in favour of sustainable development (Gladman

emphasis).

9.4.6 The Gladman proposal will deliver up to 190 homes that will include a significant proportion

of affordable houses varying in range, size and tenure which entirely accords with the criteria

set out in the Framework.

9.4.7 The proposal also strongly accords with the Core Planning Principles set out in paragraph 17

of the Framework. These proposals will deliver homes that are required now within Mid Suffolk

and at the spatially preferable location of Stowupland.

9.4.8 The development will be of a high quality design and will provide a good standard of amenity

and open space. The location of the Site allows for a choice of modes of transport to be used

to access local facilities.

9.4.9 In summary, it has been demonstrated that the proposals achieve demonstrable accordance

with the overall objectives of the National Planning Policy Framework, in particular, the golden

thread of sustainability thus invoking the ‘presumption in favour of sustainable development’.

On any fair reasonable assessment of the current deficit of housing land supply, this should

be given significant weight.

9.5 Development Plan

9.5.1 No weight can be given to housing policies within the MSDC Core Strategy, Saved 1998 Local

Plan or Stowmarket Area Action Plan as the Council cannot demonstrate a five year supply of

deliverable housing, and in line with paragraph 49 of the Framework, these policies relating

to housing are not considered up-to-date. In situations such as this where the Council cannot

demonstrate a 5 year deliverable housing supply or, as addressed earlier, where the Council’s

Development Plan is out-of-date by virtue of the fact that the policies are time-expired and

the fact that the ‘principle policies’ are not Framework-compliant and therefore out-of-date,


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the presumption in favour of sustainable development as per paragraph 14 of the Framework

should be engaged.

9.5.2 The emerging Site Allocations and Development Management DPD for MSDC (prepared jointly

with Babergh District Council) is at such an early stage and at present does not have any

policies to be applied to the determination of planning applications, as such no weight can be

given to this emerging Plan.

9.5.3 In the overall planning balance of weighing the Development Plan with other material

considerations that support this proposal it is evident that the weight of other material

considerations demonstrably and significantly outweighs any non-compliance.

9.6 Conclusion

9.6.1 Without the right type of new housing further pressures will be placed on house prices, people

will be forced to move further away from the area and new investment and growth could

ultimately be stifled.

9.6.2 New residential development has a critical role to play in all aspects of social, economic and

environmental needs of the area, and as demonstrated this development will contribute to

all. The economic benefits of this development are more important than ever in the current

economy and should not under any circumstances be overlooked.

9.6.3 The Framework identifies positive improvements which the planning system should seek to

achieve which includes widening the choice of high quality homes, improving the conditions

in which people live, work, travel and take leisure and making it easier for jobs to be created

in cities, towns and villages.

9.6.4 Stowupland should not be deprived of deliverable investment in the short term, there is

currently no plan in place to allocate any housing to the village. Additional housing is vitally

important in safeguarding local services and improving the local economy, it is in reality only

large scale developments that can aid this, rather than piecemeal small scale developments

and it is on this basis that Gladman seeks to promote a sustainable major development that

will support local needs, housing needs and services allowing for growth of Stowupland,

allowing it to continue to thrive and provide for the daily needs of the existing residents.

9.6.5 Having identified that MSDC’s relevant housing policies are not up-to-date, and having

identified the strong accordance with the Framework and the matters of housing need and

land supply, in accordance with Section 38(6) of the Planning and Compulsory Purchase Act

2004, it is appropriate that planning permission should be granted now based on the


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significant weight of material considerations that outweigh any departure from the

Development Plan. The change from agricultural use to residential following detailed

consideration of the surroundings, and views into and out of the Site would not result in

substantial harm that would significantly and demonstrably outweigh the significant benefits

generated by the development.

9.6.6 The Council are asked to approve the application accordingly.

Appendix 1: Sustainability Matrix, December 2014

Gladman Sustainability Matrix – Land off Church Road, Stowupland

Sustainability Criterion Factor Sustainability

Outcome Commentary Document Reference

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Primary Check List

Is the site outside Green Belt, National Park, AONB and other protected landscapes?

The site is not within any Green Belt, National Park or other protected landscapes.

See Landscape and Visual Assessment

The scheme does not affect a wildlife sensitive location – SSSI, SNIC, LNR?

The nearest site of protected landscape is the Gipping Great Wood SSSI. The proposal is within the SSSI’s outermost Impact Risk Zone, but has poor access to it and is considered not to negatively impact its setting and recreational function.

See Ecological Assessment

Will the site contribute to a shortfall in the 5-year housing land supply?

The site will contribute to Mid Suffolk’s shortfall in 5-year housing land supply.

See Planning Statement

the site is: Available The site is available. See Planning Statement

the site is: Suitable The site is suitable. See Planning Statement

the site is: Achievable The site is achievable. See Planning Statement

Does the scheme accord with delivery of the Council’s Regeneration Strategy?

The development of greenfield land is necessary to deliver the housing growth for Mid Suffolk


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Sustainable Settlement and Location

Is the site adjoining or within a recognised Sustainable Settlement or Location for Growth in LPA Policy?

The site is adjoining Stowupland, a Key Service Centre in the adopted Core Strategy settlement hierarchy. These are sustainable settlements where a growth of 450 homes is directed in the 15-year plan period 2012-2027.


What makes this location sustainable?

Accessibility to local and neighbourhood facilities within or just beyond the 800m walking distance.- maximum acceptable walking distance (IHT)

ATM 800m - Will be Installed at Allard’s Farm Shop Amenity Area 600m (Stowupland Sport’s Centre bookable facilities) Early Years Care Provision 400m (Stowupland Pre-School) Food shop 1km (Co-Op Food) Primary school 400m (Freeman Community Primary School) Secondary School 850m (Stowupland High School) Bus Stop 350-400m (Church Road/Trinity Walk/Reeds Way) Pub 750m (The Crown Pub) Post Office 800m (In Allard’s Farm Shop) Sports Facility 600m (Stowupland Sport’s Centre) Community Centre 600m (Stowupland Village Hall)

See Design and Access Statement and Transport Assessment

What makes this location sustainable?

Accessibility to district services within or just beyond the 2,000m walking distance, including utilising public transport.

Train Station 970m (Stowmarket Train Station) Health Centre 600m (Stowhealth Surgery) Dentist 720m (Station View Dental Practice) Library 800m (Stowmarket Library) District Centre 570m (Stowmarket Town Centre) Supermarket 750m (Tesco) District Sports Facility 860m (NRG Fitness Gym) Employment Area 570m (Stowmarket Town Centre) Bank 570m (Numerous in Stowmarket Town Centre) Pharmacy 650m (Boots)

See Design and Access Statement and Transport Assessment

Development restricted to flood zone 1 / able to contain rainfall from 1:100 year rain events

The development lies within Flood Risk Zone 1.

See FRA

Areas of ecological and geological interest are unaffected / mitigated by the proposals

There are no adverse impacts on ecological or geological interests. The proposal has the potential to encourage commuting and foraging of amphibians.

See Ecological Appraisal

Development at this location will not lead to an avoidable loss of Best and Most Versatile (BMV) agricultural soils?

BMV land will not be lost as 100% of the soil is classified as 3b. See Soils and Agricultural Use & Quality Report

Additional capacity provided to ensure existing education / medical facilities will cope

Discussions will take place to establish whether a contribution is required to increase the capacity of existing educational and medical facilities, though initial research indicates that both the local schools and medical facilities are under capacity.


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Sustainable Transport

All homes within 5km of long distance public transport services (railway station/bus service)

From the centre of the proposal site, homes are approximately 450-500m away from bus stops on Church Road, Gipping Road and Reeds Way. The homes are also within approximately 3km of Stowmarket Train Station.

See Transport Assessment

Development site within 800m of hourly bus service Aforementioned bus stops on Gipping Road and Reeds Way are served by the 387 circular service, which runs once per hour.

See Transport Assessment and Travel Plan

Simple street pattern of indicative scheme gives priority to pedestrians and cyclists linking outwards to as many local facilities, public transport and natural green spaces as possible.

The Site has been designed to link as much as possible with the surrounding area by providing pedestrian links through to multiple Public Rights of Way.

See Design & Access Statement

Travel Plan Co-ordinator to provide site-specific Travel Pack detailing measures to reduce car-reliance and give access to lift share

A Travel Pack will be prepared for new residents. See Transport Assessment and Travel Plan

High quality paving materials used to control traffic speed, encourage shared-use, amenity, recreation and community

Pavements and shared surfaces will be prepared to provide a pedestrian-friendly environment and reduce traffic speeds.


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Economic Benefits

Does the scheme promote aims of Planning for Growth? The proposals are consistent with Planning for Growth. See Planning Statement

Benefits to LPA: New Homes Bonus, Council Tax revenue, CIL / S106 contributions; Job creation (f/t, p/t), Economic value of works

There will be significant benefits associated with 190 dwellings, such as £1.4 million in New Homes Bonus, approximately 80 full time construction jobs created annually during the construction period of the Site, and £0.4 million in household spending within the District.

See Socio-Economic Report

Proposal that increases the viability and reinforces the sustainability of local businesses and facilities.

Pedestrian access routes tie into the existing footpath network and improvements will benefit the connection to the local Farm Shop and Post Office.


Existing dwellings within settlement benefiting from increased sustainability by provision of new facilities on-site

Provision of new open space on-Site will be made easily and readily available to both the new development and the surrounding housing.


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Housing

Does the provision of Affordable Housing distributed throughout the site contribute to the major local shortfall of affordable housing

Yes. Affordable housing is not to be grouped or pushed to the Site boundaries but appropriately ‘pepper potted’ throughout the development.

See Affordable Housing Statement

Diversity of housing stock: • flexibility within homes to enable home-working

Proposal promotes the highest quality sustainable design, creating a 'place' which is both safe and attractive and which enhances quality of life, health and social well-being.


Meet Local Housing needs, maintain land supply and reduce waiting lists by providing a range of types, sizes and tenures of market housing based on socio-economic demographics.

The proposed development consists of a range of 1, 2, 3, 4 and 5 bedroom properties catering to a variety of different people with different housing requirements. 40% of these properties will be affordable housing, 25% on-Site and 15% provided for off-Site with a monetary contribution.

See Affordable Housing Statement

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Education, Community & Sports provision affecting

quality of life

Enable safe routes to schools Existing footpaths provide the safe access to the Primary School and Secondary School. A contribution is provided to enhance these footpaths.

See Draft Heads of Terms

Will create a balanced community by increasing affordability and introducing a younger demographic of working age population.

An increase in the choice of homes, especially for first-time buyers, will allow younger people to enter the housing market in the area.


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Linkages Integration Design (Intrinsic Factors)

A high quality built environment with a network of connected streets with active frontages responsive to local vernacular as reference points for design

The Site specifically does not seek to create, or generate a pastiche of what has gone before, but instead to look forward to contemporary sustainable design solutions which effectively integrate into the existing fabric of Stowupland by way of referencing common building materials, layout and street hierarchy.


Provide multi-functional green spaces on-site achieving Local Plan and / or NPFA standards for recreation and play space, incorporating • Local landscape features,

• Existing vegetation / native planting scheme • SUDS including swales, open water course, reed beds or ponds

The proposals include on-Site provision of a children’s play area and public open space that exceed the local policy requirement. The Site’s landscape and ecological assets, and the conservation of natural resources are important in terms of minimising the impact of development within the Site but also in the setting of the development within its wider context. A significant portion of the land is identified for this landscaping (26%).


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“approving development proposals that accord with the development plan without delay;”

It has been demonstrated that the proposals are in broad compliance with the overall objectives of National Planning Policy.


NPPF: Para 14: “At the heart of the National

Planning Policy Framework is a presumption in favour of sustainable development, which should be seen as a

golden thread running through both plan-making and decision-taking... For

decision-taking this means (unless material

considerations indicate otherwise)...”

“and where the development plan is absent, silent or relevant policies are out-of-date, granting permission unless:”

The Council cannot demonstrate a 5-year housing land supply and such the policies relating to housing are now out-of-date and should not form the basis for the determination of this application. The National Planning Policy Framework should be applied to the decision making process of this application in light of this and other non-compliant policies.


“ –any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole;”

There are a number of significant economic and social benefits associated with the proposed development that outweigh any adverse impacts.


“or specific policies in this Framework indicate development should be restricted (SSSI, Green Belt, AONB etc.).”

The Site represents an acceptable location on the edge of a sustainable settlement. The Site is not covered by any of the designations listed in by NPPF Footnote 9.


Appendix 2: Delivery Table, December 2014

Gladman Delivery Table – December 2014

SITE ADDRESS NUMBER OF

DWELLINGS

% AFFORDABLE OUTLINE/IN PRINCIPLE PLANNING APPLICATION DETERMINATION DATE

COMMITTEE OR APPEAL DECISION (IF RELEVANT)

DATE LAND SOLD

PURCHASER RESERVEDMATTERS/MATTERS SPECIFIED BY CONDITION DETERMINATION DATE

COMMENCEMENT OF DEVELOPMENT

TIMESCALE FROM INITIAL PLANNING PERMISSION TO SITE START

North Dean Avenue, Keighley West Yorks

190 15% (28NO) 12 May 2010 Committee May 2011 Barratt Homes Reserved matters approved May 2011 (it was submitted in December 2010)

June 2011 13 months

Golden Nook Farm Cuddington Cheshire

150 30% (45NO) 20 Feb 2012 Committee July 2012 Bovis Homes Approved August 2012

September 2012 (road & demolition works)

7 months

Henthorn Road Clitheroe Lancashire

270 30% (81NO) 26 March 2012 Committee December 2012 Barratt Homes & Taylor Wimpey

Approved March 2013

March 2013 12 months

Wigan Road Clayton le Woods Lancashire

300 30% (90NO) 21 July 2011 Committee December 2012 David Wilson Homes/ Taylor Wimpey

Approved March 2013

May 2013 22 months

Loachbrook Farm Congleton Cheshire

200 30% (60NO) 20 March 2013 (date of High Court Challenge).

High Court Approval ‐ 20 March 2013

Subject to planning, anticipated Nov 2013

Bovis Homes 14 June 2013 November 2013 8 months

Byefield Road Woodford Halse, Daventry

200 30% (60NO) 15 February 2013 Committee Conditional exchange of contracts October 2013

Taylor Wimpey July 2014 Expected Autumn 2014

21 months

Warmingham Lane Middlewich Cheshire

194 30% (58NO) 9 January 2013 Committee June 2014 Morris Homes March 2014 June 2014 17 months

Hannay Road Steventon Oxfordshire

50 40% (20NO) 23 April 2013 Committee July 2013 David Wilson Homes

May 2014 May 2014 13 months

Queens Drive Nantwich Cheshire

270 30% (81NO) 1 March 2013 Committee September 2014

Barratt Homes & Bovis Homes

July 2014 September 2014(programmed start)

18 months

Eliburn Livingston West Lothian

87 15% (13NO) 3 March 2014Committee

Sale agreed when s.75 signed in early 2014

Barratt Homes Submitted March 2014, approved June 2014.

Sale concluded July 2014, site works underway in August 2014.

5 months

Appendix 3: Draft Heads of Terms, December 2014

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Land off Church Road, Stowupland

Draft Heads of Terms for Section 106 Agreement

Proposed Development: Proposed Residential Development of up to 190 dwellings (use class C3) with all matters reserved, save for access; incorporating elements of open space, children’s play and associated infrastructure. Local Planning Authority: Mid Suffolk District Council 131 High Street Needham Market Ipswich IP6 8DL Obligations:

1. Open Space The Agreement will require the Developer to provide onsite informal open space and an equipped children’s play area. Appropriate phasing requirements will be specified together with the requirement to agree with the Council off site commuted sums as applicable. The open space will be put into a management company in perpetuity. 2. Education The Agreement will require the Developer to make a contribution to the Education Authority to mitigate the impact of the development for School pupils arising from the proposed development, where demonstrated this is necessary.

3. Public Rights of Way

The Agreement will require the Developer to provide a contribution of £20,000 for the upgrade of Public Rights of Way adjoining the site to the north and south.

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4. Travel Plan Monitoring

The Agreement will require the Developer to provide a contribution of £5,000 for the monitoring and support of a Travel Plan. 5. Legal Costs

The Agreement will require the Developer to provide reasonable legal costs for County Council and District Council monitoring. 6. Affordable Housing

1. The development shall not begin until a scheme for the provision of affordable housing as

part of the development has been submitted to and approved in writing by the local planning authority. The affordable housing shall be provided in accordance with the approved scheme and shall meet the definition of affordable housing in the National Planning Policy Framework and National Planning Practice Guidance. The scheme shall include:

a. the numbers, type, tenure and location on the Site of the affordable housing provision

to be made which shall consist of not less than 25% of housing units/bed spaces provided on-Site, with a monetary contribution to 15% affordable housing off-Site.

b. the timing of the construction of the affordable housing and its phasing in relation to

the occupancy of the market housing;

c. the arrangements for the transfer of the affordable housing to an affordable housing provider [or the management of the affordable housing] (if no Registered Provider is involved);

d. the arrangements to ensure that such provision is affordable for both first and

subsequent occupiers of the affordable housing;

e. the occupancy criteria to be used for determining the identity of occupiers of the affordable housing and the means by which such occupancy criteria shall be enforced; and

f. the timing of the payment of a commuted sum.

7. Other

Other contributions may be identified through the planning consultation process, and subject to meeting the appropriate tests of necessity and reasonableness, consideration will be given to their inclusion.

Appendix 4: Proposed Draft Conditions, December 2014

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Schedule of conditions in respect of outline planning permission granted for outline application for up to 190 dwellings (use class C3) with all matters reserved, save for access; incorporating elements of open space, children’s play and associated infrastructure. Time Period

1. Application for approval of reserved matters must be made not later than the expiration of 3 years from the date of this permission and the development must be begun not later than which ever is the later of the following dates:

(i) the expiration of 3 years from the date of this permission, (ii) the expiration of 2 years from the final approval of the reserved

matters or, in the case of approval on different dates, the final approval of the last such matter to be approved.

Reserved matters

2. Details of appearance, landscaping, layout, and scale, (hereinafter called "the reserved matters") shall be submitted to and approved in writing by the local planning authority before any development begins and the development shall be carried out as approved.

3. The approval of the plans and particulars of the reserved matters referred to in Condition 2 above can be produced in phases.

Approved Plans

4. The development hereby permitted shall comprise no more than 190 dwellings.

5. The development hereby permitted shall be carried out in accordance with the details shown on the approved access drawings ref: C14609 (October, 2014)

Site investigation / contaminated land

6. No part of the development hereby permitted shall be commenced on site unless and until:

a. A site investigation has been designed for the Site using the information obtained from the desktop investigation previously submitted in respect of contamination. This shall be submitted to and approved in writing by the Local Planning Authority prior to the investigation being carried out on the Site; and

b. The site investigation and associated risk assessment have been undertaken in accordance with details submitted to and approved in writing by the Local Planning Authority; and

c. A method statement and remediation strategy, based on the information obtained from ‘b’ above, including a programme of works, have been submitted to and approved in writing by the

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Local Planning Authority. The development shall be carried out in accordance with the approved remediation strategy.

Tree protection measures

7. The development hereby approved, shall be carried out in accordance with recommendations of the approved FPCR Arboricultural Assessment dated December 2014 submitted with the application. No development shall begin until details of the means of protecting trees and hedges within and immediately adjacent to the Site of the particular phase, including root structure from injury or damage prior to or during the development works have been submitted to and approved in writing by the Local Planning Authority. Such protection measures shall be implemented before any works are carried out and retained during building operations and furthermore, no excavation, Site works, trenches or channels shall be cut or laid or soil, waste or other materials deposited so as to cause damage or injury to the root structure of the trees or hedges.

Habitat Protection Measures

8. No development shall begin until details of the means of protecting retained habitats on Site, identified in the submitted FPCR Ecological Appraisal dated December 2014, has been submitted to and approved in writing by the Local Planning Authority. Such protection measures shall be implemented before any works are carried out and retained during building operations.

Nesting Birds

9. No clearance of trees and shrubs in preparation for (or during the course of) development shall take place during the bird nesting season (March - August inclusive) unless a bird nesting survey has been submitted to and approved in writing by the Local Planning Authority to establish whether the Site is utilised for bird nesting. Should the survey reveal the presence of any nesting species, then no development shall take place within those areas identified as being used for nesting during the period specified above.

Construction / Protection Method Statement

10. No development shall take place, including any works of demolition, until a Construction Method Statement has been submitted to, and approved in writing by, the Local Planning Authority. The approved Statement shall be adhered to throughout the construction period. The Statement shall provide for:

a. the parking of vehicles of site operatives and visitors b. loading and unloading of plant and materials

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c. storage of plant and materials used in constructing the development

d. the erection and maintenance of security hoarding including decorative displays and facilities for public viewing, where appropriate

e. wheel washing facilities f. measures to control the emission of dust and dirt during

construction g. a scheme for recycling/disposing of waste resulting from

demolition and construction works h. a scheme to control noise during the construction phase.

Flooding and Drainage

11. The development hereby permitted shall be carried out in accordance with the Flood Risk Assessment prepared by Enzygo, December 2014.

12. No development, other than the formation of the site access, shall begin until a surface water drainage scheme, including details of a surface water regulation system for the site, based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development has been submitted to and approved in writing by the Local Planning Authority. If required, such details shall be submitted and approved on a phased basis. The submission(s) shall include details of how the scheme shall be maintained and managed after completion of the development and shall subsequently be implemented in accordance with the approved details before the development is completed.

Landscape Implementation

13. All planting, seeding or turfing comprised in the approved details of landscaping shall be carried out in the first planting and seeding seasons following first occupation of the buildings hereby approved or the completion of the development, whichever is the sooner. Any trees or plants which, within a period of five years from the completion of the development, die, are removed or become seriously damaged or diseased shall be replaced in the next planting season with others of similar size and species unless the Local Planning Authority gives written consent to any variation.

Travel Plan

14. Prior to the first occupation of any dwelling, an Interim Travel Plan shall be submitted to and approved in writing by the Local Planning Authority. Thereafter and prior to the occupation of the 50th dwelling, a Final Travel Plan shall be submitted to and approved in writing by the Local Planning Authority. This Final Travel Plan shall include objectives,

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targets, mechanisms and measures to achieve targets and implementation timescales, monitoring and review provisions and provide for the appointment of a travel plan co-ordinator. The development shall thereafter be implemented in accordance with the approved Travel Plan.

Job Training

15. Prior to the commencement of development a scheme for the creation of job training opportunities shall be submitted for approval to the local planning authority.

Appendix 5: The Planning Balance, December 2014

Stowupland – Material Planning Benefits and Negative Factors

Purpose

The purpose of this supplementary document is to encapsulate the relevant material considerations, and demonstrate in the planning balance that the benefits demonstrably outweigh the negative factors, and thus harm, of the proposal.

Sustainable development is about positive growth – making economic, environmental and social progress for this and future generations. The document will demonstrate that the proposal strongly accords with the three dimensions of sustainable development; economic, social and environmental.

Economic

Material Consideration Description Positive Benefit or Negative Factor

New Jobs The development will support around 400construction jobs (full time equivalent) during the construction period. There are around 25 people in Mid Suffolk claiming Job Seekers Allowance and seeking work in the construction and development sector (as of mid‐2014). As such, the proposed development could contribute to enabling unemployed construction workers in the area to find employment.

Positive Benefit

Labour Force/ Demography

The proposed development would accommodate around 418 new residents. The scheme will directly contribute to ensuring the availability of local labour force. This would contribute to supporting the area’s economy by meeting local needs for affordable housing and providing housing that working residents in lower skilled and lower paid occupations could afford. This is also of direct benefit to local businesses. The increase in population would also generate additional demand and support for local education and health services, nurseries, schools and colleges. Potential to deliver aspirational housing to rebalance housing market; attract and retain business leaders; secure inward investment and support economic growth objectives.

Positive Benefit

Resident Expenditure Residents of the proposed development couldgenerate annual household expenditure of £1.3 million to be spent within the region. Household moves generated by the development would bring significant benefits to the local economy through expenditure with local firms on services such as estate agents and conveyancers, as well as on new fixtures and fittings.

Positive Benefit

New Homes Bonus Mid Suffolk would receive an estimated total of £1.4million in New Homes Bonus (NHB).

Positive Benefit

Council Tax The Council will also receive Council Tax rates in perpetuity from occupiers of the new development provide an important source of revenue funding for the Local Authority in delivering services as well as investing in the locality.

Positive Benefit

Vitality & Viability The additional residents of 190 households will increase demand for and use of local services and businesses (including retail outlets, pubs, cafes etc.) This increased demand and spending will help to maintain and enhance the services available and accessible within the village and increase their viability.

Positive Benefit

Ageing Population Rural Solutions set out in the Sustainability Assessment that the highest rate of growth in Mid Suffolk has been seen in the population aged over 65, which has increased by 153 residents between 2001‐2011. There were declines in all other age groups (including children and those of working age). In Stowupland, the population of people over 65 increased from 386 in 2001 to 539 in 2011. By providing a range of family housing, especially three and four bed homes, the proposed development is expected to attract families and some key workers. This will help to respond to the challenges of an ageing population in Mid Suffolk such as reduced local spend and increased pressure on local services and the labour market. The development will also make provision of smaller homes for older residents to meet the requirement of the growing number of residents over 65 to down‐size, thereby releasing larger family properties.

Positive Benefits

Economic Recovery Delivery of this Site will assist economic recovery more quickly than emerging allocations in the District.

Positive Benefit

Retention of Skills Having a wider choice of quality homes will allow people to stay in the area helping retain skills and available labour force.

Positive Benefit

New Anglia Strategic Economic Plan

House building is noted as a powerful stimulus for growth. It states that housing can attract skilled labour, entrepreneurs and inward investment which are all key drivers of growth. Each home built in the LEP area would equate to £36,700 in GVA. Through providing 190 homes and introducing 290 economically‐active people, the proposal will support the aspirations of the Economic Plan.

Positive Benefit

Affordability Currently, house prices are over seven times higher than lower quartile earnings in Mid Suffolk. This makes the housing market in Mid Suffolk particularly difficult to access, especially for first time buyers or those on low incomes. Provision of affordable homes will allow those with low income to live in the area and have access to employment opportunities.

Positive Benefit

Stowmarket Area Action Plan

Paragraph 6.2 in the Stowmarket Area Action Plan states that there is a need to allocate further areas of greenfield land on the fringe of the town to meet future housing requirements. Stowupland exists as a settlement on Stowmarket’s fringe, within the AAP policy area. The development would contribute to the identified housing need of the area.

Positive Benefit

Job Training The development will provide for the creation of job training opportunities of for construction trade apprentices.

Positive Benefit

Social

Material Consideration Description Positive Benefit or Negative Factor

Housing Need ‐ Market The provision of this type of site for housing is a very efficient way of meeting existing housing needs quickly. The site is easy to develop and has very few constraints. This will ensure that the site will rapidly contribute to increasing the supply of housing. It meets an identified Housing Need for people in both the market and affordable housing sectors which will “ensure choice and competition in the market for land” (NPPF para 47). New market and affordable homes here are a major planning benefit due to their contribution to remediating a severe shortage of housing land supply. New homes here will enable people to access the housing market locally rather than being forced to move away due to a lack of available housing. The proposal will assist in helping keep work, family and friendship connections that improve both quality of life and the vitality of the community (NPPF para 55). The mix of house types to attract the economically active and improve economic competitiveness, diversify local age structure and contribute to the “objective of creating mixed and balanced communities” (NPPF paragraph 50).

Positive Benefits

Housing Need ‐ Affordable

As discussed above. Positive Benefit

Building Sustainable Communities

Assists in building and maintaining a mixed and balanced community that will help sustain the vitality of community life in Stowupland. Development of new homes allows the settlement to play its part in delivering sustainable development in the rural area as proposed in National Planning Practice Guidance (Reference ID: 50‐001‐20140306)

Positive Benefit

Design & Access (Social Dimension)

Demonstrates that the proposal sets a framework to enable delivery of a high quality residential development. Existing and new residents of the settlement will benefit from the additional social infrastructure provision on‐Site of improvements to the existing footpaths, new areas of open space. The planning permission would enable delivery of a mix of housing ‐ up to 190 new dwellings, offering 1‐5 bedroom properties, comprising a range of house types from linked townhouses to detached properties. This will add to the choice of high quality homes available in the District.

Positive Benefits

Recreational Landscape and Countryside Links

The development will provide linkages to the wider network of paths in surrounding countryside and the existing settlement. Strategic areas of landscape and open space will include formal recreation and footpaths. The existing vegetation along the boundaries will be reinforced with new tree and hedgerow planting, which will benefit people and wildlife alike.

Positive Benefit

Public Open Space Provision

There will be the provision of 2.77 ha of public open space and landscaping which will benefit existing as well as new residents.

Positive Benefit

Children’s Equipped Play Area

An equipped children’s play area will be provided; this will be accessible to new and existing residents.

Positive Benefit

Improvements to the Footpath Network

A contribution is made to the enhancement of the immediate Public Right of Way to encourage usage and enjoyment by existing and new residents. The development will increase pedestrian and cycle linkages for new and existing residents to the surrounding Public Rights of Way and local facilities in Stowupland.

Positive Benefit

Road Safety The 30mph limit is proposed to be extended past the potential access point on Gipping Road, greatly improving safety considering there is no footpath on this road.

Positive Benefit

Travel Plan The Travel Plan (TP) promotes sustainable travel awareness and encourages sustainable travel choices other than single occupancy vehicle journeys. This Framework TP is prepared taking account of currently available best practice guidance (DfT 2009) and complementary residential guidance (DfT 2005). The TP will be managed and operated by the Travel Plan Coordinator (TPC,) to be appointed by the residential developer(s), and to be in post six months prior to first occupation of the first house at the Site.

Positive Benefit

As this is a new development sustainable travel habits can be encouraged from the outset of occupation. The early appointment of the Travel Plan Coordinator will maximise this opportunity to influence travel choices. In seeking to reduce reliance on the Private Car, the Travel Pack and Co‐Ordinator will contribute towards meeting the Council’s Travel Plan Team’s objectives.

Travel Plan “Welcome Pack”

All new residents will be issued with travel welcome packs promoting alternative transport modes. These packs will promote national and international initiatives such as ‘Walk to Work Week’, ‘Bike Week’, ‘In Town Without My Car’ and ‘Walk to School Week’. The welcome packs will also include information on public transport such as the cost, timetables and services available given new residents information on ways to access local facilities without the use of private cars, this will benefit new and existing residents. The welcome pack will also include a map identifying pedestrian friendly routes surrounding the Site providing new residents with information on how to access local facilities by walking or cycling. Leaflets will also be provided to all new residents encouraging cycle safety training provided by the council

Positive Benefit

Travel Notices Boards To continue to promote sustainable transport, including walking and cycling routes, notice boards will be set up in the Sites communal areas. These notice boards will promote: car sharing, local taxi services, internet websites on sustainable transport and journey planning. These boards will benefit new residents but will also help to inform existing residents of sustainable transport within the area.

Positive Benefit

Car Sharing The Travel Plan will encourage new residents to sign up to local car sharing schemes such as the lift share scheme run by Suffolk County Council. Car sharing schemes can also be set up by the Travel Plan Coordinator, this will be open to both new residents but existing residents can join helping reduce the amount of journeys by private car within the village. It is unlikely that a scheme like this would take place otherwise.

Positive Benefit

Bus Stops New shelters, seating and Real‐Time Information at bus stops on Gipping Road and Church Road will benefit new and existing residents using public transport.

Positive Benefit

Resident’s Sustainable Travel Group

The Travel Plan Coordinator will encourage new residents to create or join a resident’s sustainable travel steering group. The group will organise social events such as organised cycle rides which will be extended to include existing residents. This will help promote sustainable patterns of travel between both new and existing residents benefiting the village as a whole and promoting a healthy life style. Existing residents and Parish members can also join.

Positive Benefit

Social Mobility This development will provide up to 46 affordable homes on‐Site and a contribution for the provision of 15% off‐Site, and increase the choice of homes for first time buyers, enhancing social mobility.

Positive Benefits

Social Capacity 418 people arising from 190 homes will broaden the social capacity of Stowupland, enhancing inclusivity, and broadening and enhancing community skills base.

Positive Benefit

Allowing Younger Families to enter into the Housing Market

Having a wider choice of homes will allow younger families, who may be living at home or not be the head of their own household, enter the housing market.

Positive Benefit

Environmental

Material Consideration Description Positive Benefit, Neutral, or Negative Factor

Landscape & Visual Impact

The wider context of the Site is of low‐mediumsensitivity to change and has built development to the west. The proposed development would represent a landscape impact to the existing land, mainly due to the loss of greenfield agricultural land to developed residential land and vehicular/pedestrian/cycle routes. However, the impact of these can be offset by the proposed retention and enhancement of the field boundaries, hedgerows, trees, the existing Site topography and the addition of new green infrastructure. Effects on local landscape character are therefore considered to be moderate/major adverse at year 1, but with scope to improve to minor adverse as landscaping establishes. The proposed housing within the Site will affect relatively few residential receptors, these are limited to views from Gipping Road, Church Road, Trinity Walk and Columbyne Close. By the time tree planting establishes on the Site, the impact will be moderate to negligible for properties in this area.

Negative Factor

New Tree Planting The Site will be enriched by new tree planting, including an area of woodland planting, to enhance the existing trees and hedgerows. In landscape terms, the assessment demonstrates that the Masterplan proposals respond well to the local landscape character of the site, recognising and responding to opportunities to retain views, extend local public open space and improve the existing urban edge. New landscaping will soften landscape impact over time.

Positive Benefit

Soils The site is dominated by Grade 3b agricultural land so there is no loss of Best and Most Versatile Agricultural Land.

Positive Benefit

Ecological Impact Features of value include the majority of thehedgerows, which are considered limited habitats of minor importance. Hedgerows and trees will be retained where possible and enhanced, as well as the provision of new trees and hedgerows to encourage local wildlife. There is a net biodiversity gain in accordance with requirements of 9 and 118 of the NPPF. The proposal aims to conserve and enhance biodiversity through: Provision of domestic gardens which provide an

opportunity to improve biodiversity over and above agricultural use.

Significant areas of planting to provide green

infrastructure, ecology and wildlife benefits eg. wildlife corridors, habitat etc.

Habitat creation measures to ensure biodiversity

is retained and enhanced hedgerow, and green corridors.

Positive Benefit

Flood Risk Assessment (FRA)

The surface water drainage design will attenuate water run‐off to mimic existing greenfield run‐off rate to take account of future climate change in accordance with National Planning Policy Guidance. This is a material environmental benefit. All drainage designs will include the appropriate climate change allowance, in this case 30% increase in rainfall.

Positive Benefit

Health and Well Being

Residents of the new housing will benefit from the new recreational and open space infrastructure available within the Parish which will integrate with the existing Public Rights of Way network and provides greater opportunities for access to existing residents.

Positive Benefit

Reducing the Reliance on Private Cars

Sustainable modes of transport will be promoted to all new residents through the Travel Plan and Travel

Positive Benefit

Plan Coordinator seeking to reduce the reliance on private car journeys. Work with the Councils Travel Plan Team, through the Travel Plan Coordinator, will be established to encourage sustainable modes of travel seeking to reduce the reliance on the private car and contribute to meeting the Council’s Travel Plan objectives.

Suffolk County Council Transport Plan

Promoting sustainable transport in turn meetsaspirations of Suffolk County Council’s Transport Plan.

Positive Benefit

Archaeology Further archaeological investigations will be secured by condition. Such investigations will provide information as to the archaeological interest of the Site.

Planning Balance

Positive Benefits Negative Impacts of the Scheme

New jobs Landscape and Visual Impact

Residential Expenditure

New Homes Bonus

Council Tax

Vitality and Viability

Ageing Population

Economic Recovery

Retention of Skills

New Anglia Strategic Economic Plan

Affordability

Stowmarket Area Action Plan

Job Training

Housing Need – Market

Housing Need ‐ Affordable

Building Sustainable Communities

Design and Access (Social Dimension)

Recreational Landscape and Countryside Links

Provision of Public Open Space

Children’s Equipped Play Area

Improvements to the Footpath Network

Road Safety

Travel Plan

Travel Plan “Welcome Pack”

Travel Notice Boards

Car Sharing

Bus Stops

Resident’s Sustainable Travel Group

Social Mobility

Social Capacity

Allowing Younger Families to enter into the Housing Market New Tree Planting

Soils

Ecological Impact

Flood Risk Assessment

Health and Well Being

Reducing the Reliance on Private Cars

Suffolk County Council Transport Plan

Archaeology

Appendix 6: Utilities Appraisal, December 2014

Utilities Appraisal – Stowupland

Electricity

The plans supplied by UK Power Networks indicate that there high voltage (HV) overhead lines crossing the south eastern corner of the site; the proposed development framework has allowed for these to remain in place so no diversions will be required. There are existing HV and LV (low voltage) cables within the vicinity of the proposed site entrances; no major diversions will be required.

It is anticipated that the new development could be supplied by the existing network; the point of connection off the existing network would need to be confirmed once the detailed design was completed, but is anticipated to be from the existing network within Gipping Road/Trinity Walk. A new secondary substation will be required with associated LV mains and service connections.

Gas

Plans supplied by National Grid indicate there are no existing mains within the site boundary. There are low pressure (LP) mains within Gipping Road to the north of the site and Church Road to the south and an extensive LP mains network feeding the existing residential properties to the west of the site. No diversions are expected.

It is anticipated this existing gas network could be extended to feed the proposed development; a new mains gas infrastructure would be laid on site with associated service connections.

Water

The plans supplied by Anglian Water indicate there no existing mains within the site boundary. There are mains within Gipping Road to the north of the site and Church Road to the south of the site; only minor diversions will be required to form the new site entrances.

It is anticipated this existing water network could be extended to feed the proposed development. A new mains infrastructure would be laid on site to serve the new domestic properties.

Telecoms

BT records indicate there is no existing plant within the site boundary. There is underground plant to the south of the site within Church Road and overhead plant running along Gipping Road to the north. Only minor diversions will be required to allow for the formation of the site entrance off Church Road.

The proposed new site could be fed by extending this existing infrastructure. Broadband connections are available within this area although fibre connections are not yet installed.

GPSS Oil

There is a GPSS oil pipeline running across the site; the associated easement width and access has been accommodated within the proposed layout.

Summary

Initial investigations have not highlighted any concerns or engineering difficulties with servicing the proposed development with new gas, water, electric or telecommunication connections.

No engineering difficulties are anticipated for the anticipated connection works.

New infrastructure and service connection costs are anticipated to be in line with those expected for a standard development of this scale.

It should be noted that all Utility Providers have a licence obligation to ensure that any connections to the system comply with all relevant regulations, legislation and Engineering Recommendations so therefore do not have an adverse effect to the supply and quantity of supply to existing customers.

Appendix 7: Affordable Housing Statement, December 2014

Land off Church Road, Stowupland

Affordable Housing Statement

1.1.1 This Affordable Housing Statement accompanies a Planning Application submitted to Mid

Suffolk District Council (referred to herein as ‘MSDC’) by Gladman Developments Ltd (referred

to herein after as ‘the Applicant’) in support of a planning application for Outline Planning

Permission for Residential Development of up to 190 Dwellings, on land off Church Road,

Stowupland.


dwellings with associated open space, associated infrastructure, with all matters reserved,

save for access.

1.1.3 The Applicant approached the Strategic Housing Team from MSDC by way of email on the 5th

November 2014 to request information on affordable housing needs in the District, but

received no response.

1.1.4 Policy H4: A Proportion of Affordable Housing in New Housing Developments of the 2006

Alteration of the Mid Suffolk Local Plan 1998 requires developments within Mid Suffolk to

provide 35% affordable dwellings. This policy does not give a breakdown of the preferred

level of intermediate and social market housing, but according to a phone conversation with

MSDC identify a preference of “75% social rented and 25% low-cost home ownership”. This

is based on information from the 2012 SHMA, previous District Housing Need Surveys and an

as-of-yet unfinished updated District Housing Need Survey. However, as set out in the

proceeding paragraphs the Applicant does not consider a tenure split of 75% social rented

and 25% ‘low-cost home ownership’ in line with up-to-date National policy.

1.1.5 The application puts forward the proposal to exceed this policy requirement by providing 46

affordable dwellings on-Site (25%) and a monetary contribution for the provision of 15% off-

Site, a total of 40%. The affordable dwellings on-Site will be located throughout the scheme.

1.1.6 The Planning Statement which accompanies this application confirms that the proposals will

exceed the requirement of 35% affordable dwellings, through the provision of 25% on-Site

and 15% off-Site. This is subject to discussions with officers.

1.1.7 In 2010, the Chancellor of the Exchequer announced the creation of a new affordable housing

tenure – Affordable Rent in the statement which accompanied the Comprehensive Spending

Review. Registered providers were given greater flexibility to set rents at levels up to 80% of

the open market rent for the property and to issue shorter tenancies – originally as short as

2 years although 5 years was subsequently made the norm.

1.1.8 The introduction coincided with a shift in the Government’s philosophical approach to

affordable housing and a radical withdrawal of capital funding for new affordable homes.

1.1.9 With Capital funding for new affordable housing (especially affordable housing delivered by

means of planning obligations) cut back to a bare minimum, the intention behind the higher

rents associated with affordable housing was to increase the price that Registered Providers

could pay for affordable homes and thus to maintain the output of much needed affordable

homes at a time when output might otherwise have fallen sharply.

1.1.10 In its options appraisal for the introduction of the new tenure, the Government explicitly

considered the question of whether it would be more beneficial to secure a larger number of

less subsidised Affordable Rented homes or whether it would be better to continue to deliver

a smaller number of more deeply subsidised Social Rented homes. It found in favour of the

former. In doing so, it assumed that households moving into rented affordable housing came

mostly from the private sector, where they needed to be supported by significantly higher

levels of housing benefit. The higher rents associated with affordable housing would blunt

the savings to the benefit bill in individual cases but, in aggregate, the higher capital values

would deliver more affordable homes and thus spread the benefits further.

1.1.11 Nor did the Government see this as a short terms solution limited to the provision of new

homes whilst its top priority of reducing the national deficit precluded significant capital

funding for affordable homes. In fact, the Chancellor announced that Registered Providers

would be permitted to transfer existing Social Rented homes to the new tenure as they fell

vacant and became available for re-letting. This was to allow the RPs to use the higher rents

to release capital to be reinvested in the delivery of new affordable homes.

1.1.12 This marks a philosophical shift. There are two ways to support people in need of affordable

housing – either through subsidising the individuals concerned through housing benefit or by

subsidising the homes themselves. The view of the present Government is that large subsidies

to the homes themselves (through the provision of social rented housing) is inefficient. The

theory being that households might be allocated to the home at a uniquely vulnerable moment

in their lives perhaps following a redundancy but, once provided with an affordable home,

their circumstances should improve. If the household’s circumstances subsequently change

such that they no longer require the subsidy it is then impossible to make the subsidised

home available to a household with a present need because social rented tenancies are

granted for life.

1.1.13 The new tenure is intended to support households at their time of need rather than

indefinitely. The intention is that, as households get back on their feet, they either move into

the private sector or, alternatively buy a share in the equity of the home, thus releasing a

subsidy which can be used to help others.

1.1.14 That Affordable Rent should be the primary form of affordable housing delivery across the

country is built into the framework of the Affordable Homes Programme, the government’s

flagship programme for new affordable homes. The framework to the AHP makes it

abundantly clear that the Homes and Communities Agency sees the provision of new social

rented housing as making up only the most marginal element of the overall programme.

“Affordable Rent is expected to be the main element of the product offer from providers both

for new supply and conversion of re-lets. But we want providers to respond appropriately to

a range of local needs and development opportunities. We will therefore consider the inclusion

of affordable home ownership in proposals, where it is a local priority and offers value for

money.

Funding for social rented housing may be considered in exceptional cases.” 1

1.1.15 Just how exceptional those cases would be is set out later in the same document.

“Social rent provision will only be supported in limited circumstances. For example, social rent

could be considered in regeneration schemes where decanting existing social tenants into

new homes is necessary.

In all cases providers, supported by the relevant local authorities, will have to make a strong

case to demonstrate why Affordable Rent would not be a viable alternative. All such cases

will be considered on their individual merits.

Alternatively a local authority may wish to support the provision of social rent through the

application of its own resources, for example, the provision of free land or its own funding.

1 Affordable Homes Programme Framework para 4.1-2 HCA 2010

The HCA will consider such cases where this results in the level of HCA funding requested

offering similar value for money to that achieved for Affordable Rent offers.” 2

1.1.16 The published statistics on the output of new homes under the Affordable Homes Programme

up to the end of June 2013 contains not a single instance of social rented housing3. This data

contains the funding details of some 38,000 new homes, including those which did not receive

any public funding.

1.1.17 However, we recognise that not all elements of the Government’s programme have been

implemented. In particular, conversions of existing social rented homes to affordable rent

have been relatively rare and, even if the absence of new social rented homes in the AHP

turns out to be a reporting error (which is possible) – it is possible to deliver affordable homes

outside the Affordable Homes Programme. Frustratingly, despite being the regulator for the

entire affordable housing sector, the HCA has no statistics at all on delivery outside the AHP

and was unable to confirm or deny whether such delivery was taking place or to what extent.

1.1.18 In summary, the Government is seeking to maximise the delivery of affordable housing and.

In order to ensure this, its view and that of the HCA is that all new rented affordable homes

should take the form of Affordable Rent rather than Social Rent. Moreover, it is clearly the

case, both in theory and in practice that many development sites in Mid Suffolk are struggling

to deliver the amount of affordable housing sought by policy.

1.1.19 We conclude that there is room for a discussion with the Council’s and partners as to what

the Affordable Rent should be, but in order to give the maximum level of certainty, the Council

should accept that Affordable Rented housing is accessible to all and meets the identified

housing need in the Borough. As such, provision of affordable rented units complies fully with

adopted policy.

1.1.20 The Applicant’s commitment to the provision of affordable housing is detailed in the Heads of

Terms agreement and the tenure split is for determination throughout the Reserved Matters

stage.

2 Affordable Homes Programme Framework para 4.20-22 HCA 2010 3 http://www.homesandcommunities.co.uk/sites/default/files/our-work/2011-15_ahp_-_schemes_confirmed_by_the_hca_end_of_june_2013.xlsx