Soundness Self-Assessment Checklist

Local Plan Examination

Soundness Self-Assessment Checklist June 2016

Site Allocations and Area Specific Policies &

Felixstowe Peninsula Area Action Plan Development Plan Documents

Suffolk Coastal District Council Soundness Self-Assessment Checklist June 2016 1

Suffolk Coastal District Council

Soundness Self-Assessment Checklist


Contents

Introduction ..................................................................................................................................................................................................................................... 3

Soundness ........................................................................................................................................................................................................................................ 5

Positively Prepared .......................................................................................................................................................................................................................... 5

Justified. ......................................................................................................................................................................................................................................... 31

Effective. ........................................................................................................................................................................................................................................ 34

Consistent with national policy. ..................................................................................................................................................................................................... 38

Planning policy for traveller sites ................................................................................................................................................................................................... 40


Introduction

This checklist has been completed by the Council, in advance of an examination, to ensure that the Submission Documents are sound and take into account the requirements of the National Planning Policy Framework (NPPF).

The following Development Plan Documents (DPDs) are assessed:

Site Allocations and Area Specific Policies (SAASP);

Felixstowe Peninsula Area Action Plan (Felixstowe Peninsula AAP).

The above DPDs form part of Suffolk Coastal District Council’s Local Plan and follow on from the adopted Core Strategy 2013 which sets out the long-term vision and objectives for the area. The Site Allocations and Area Specific Policies DPD and the Felixstowe Peninsula Area Action Plan (AAP) DPD will facilitate the delivery of the Core Strategy’s (CS) targets and objectives within their respective plan areas.

The purpose of this Soundness Self-Assessment Checklist is to demonstrate how the Council has prepared the DPD’s using the check tables and guidance

provided by the Planning Advisory Service (PAS) using a series of questions which provide the basis to test for soundness. The tables also include reference

to the Planning Policy for Traveler Sites (2012).

In summary – the key requirements of plan preparation are:

Has the plan been positively prepared i.e. based on a strategy which seeks to meet objectively assessed requirements?

Is the plan justified?

Is it based on robust and credible evidence?

Is it the most appropriate strategy when considered against the alternatives?

Is the document effective?

Is it deliverable?

Is it flexible?

Will it be able to be monitored?

Is it consistent with national policy?

The Tests of Soundness at Examination The starting point for the examination is the assumption that the Council has submitted what it considers to be a sound plan. Those seeking changes should demonstrate why the plan is unsound by reference to one or more of the soundness criteria.


The tests of soundness are set out in the National Planning Policy Framework (NPPF) (para 182): “The Local Plan will be examined by an independent inspector whose role is to assess whether the plan has been prepared in accordance with the Duty to Cooperate, legal and procedural requirements, and whether it is sound. A local planning authority should submit a plan for examination which it considers is ‘sound’, namely that it is:

1. Positively Prepared: based on a strategy which seeks to meet objectively assessed development and infrastructure requirements This means that the Development Plan Document (DPD) should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development. The NPPF, together with the Marine Policy Statement (MPS) set out principles through which the Government expects sustainable development can be achieved.

2. Justified: the most appropriate strategy when considered against the reasonable alternatives, based on proportionate evidence This means that the DPD should be based on a robust and credible evidence base involving:

Research/fact finding: the choices made in the plan are backed up by facts.

Evidence of participation of the local community and others having a stake in the area; and

The DPD should also provide the most appropriate strategy when considered against reasonable alternatives. These alternatives should be realistic and subject to sustainability appraisal. The DPD should show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved.

3. Effective: deliverable over its period based on effective joint working on cross-boundary strategic priorities This means the DPD should be deliverable, requiring evidence of:

Sound infrastructure delivery planning;

Having no regulatory or national planning barriers to delivery;

Delivery partners who are signed up to it; and

Coherence with the strategies of neighbouring authorities, including neighbouring marine planning authorities.

The DPD should be flexible and able to be monitored.

The DPD should indicate who is to be responsible for making sure that the policies and proposals happen and when they will happen. The plan should be flexible to deal with changing circumstances, which may involve minor changes to respond to the outcome of the monitoring process or more significant changes to respond to problems such as lack of funding for major infrastructure proposals. Although it is important that policies are flexible, the DPD should make clear that major changes may require a formal review including public consultation.

4. Consistent with national policy: enabling the delivery of sustainable development

The demonstration of this is a ‘lead’ policy on sustainable development which specifies how decisions are to be made against the sustainability criterion (see CS policy SP1A-Presumption in Favour of Sustainable Development).


Soundness Test and Key Requirements Evidence Provided

Positively Prepared: the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure

requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving

sustainable development.

Vision and Objectives

Has the LPA clearly identified what the issues are that the DPD is seeking to address? Have priorities been set so that it is clear what the DPD is seeking to achieve?

Objectives

The DPD’s (the Site Allocations and Area Specific Policies Development Plan Document and the Felixstowe Peninsula Area Action Plan Development Plan Document) will facilitate the delivery of the Core Strategy’s (CS) objectives, policies and proposals within their respective plan areas; the strategic issues having already been identified in the CS. The DPD’s clearly state their purpose as being:

To implement the CS ‘through settlement specific land use policies and the identification of new development’;

and that this key aim will be facilitated through the:

Provision of updated physical limits boundaries;

Identification of local infrastructure requirements; and

Replacement of remaining ‘saved’ policies from the previous 2001 Local Plan within their respective plan areas.

The relationship between the Submission Documents and other Local Plan documents such as Neighbourhood Plans is clearly illustrated.

The priority’s of the DPDs are clearly set by linking each DPD chapter to a corresponding CS Objective and citing the relevant strategic policy/ies to be facilitated through the implementation of policy within the DPD’s.

Does the DPD contain clear vision(s) and objectives which are specific to the place?

Clear Vision

The DPDs implement the vision and objectives of the CS in an area and site specific way. The approach taken for the two separate DPDs in expressing the objectives varies slightly as a result of one DPD being an Area Action Plan.

Within the SAASP a clear vision is provided through a preamble contained at the start of each chapter of the DPDs tied to the CS Objective the chapter is addressing. This text sets out issues raised, identifies the policy areas to be addressed in each chapter, cites key data and other evidence base documents, and explains the approach taken and the objectives of the policies presented. Chapter



topics for the DPD’s are:

SAASP Chapter headings cover: Housing, Economy, Retail, Tourism, Recreation and Green Infrastructure, and the Environment.

The Felixstowe Peninsula AAP contains its own bespoke ‘vision statement’ (see p13) providing detail to the CS objectives.

Additionally, a direct relationship is highlighted between the identified issues, the vision(s) and the 14 objectives cited in the Felixstowe Peninsula AAP p14 and the CS policy SP21-Felixstowe with Walton and the Trimley Villages objectives p75.

Felixstowe Peninsula AAP Chapter headings cover: Housing, Employment, Retail, Tourism and Sea Front, and the Environment.

For both DPDs place specific objectives are illustrated through the production of site specific maps as appropriate.

Is there a direct relationship between the identified issues, the vision(s) and the objectives?

Identified Issues

There is a direct relationship between the identified issues, the vision and the objectives. The vision and objectives within the DPDs are aimed at meeting the issues identified in the CS. The suggested approach taken has been informed and refined through rounds of public consultation and a robust evidence base.

2 rounds of public consultation (Issues and Options consultation held between 15.12.2014-27.02.2015 and Preferred Options consultation held between 19.10.2015-30.11.2015) afforded people the opportunity to comment on issues, suggested options and the approach taken.

The Issues and Options main documents along with accompanying Housing Market Area Maps, Sustainability Appraisal Scoping Report, a List of Documents Scoped and the Draft Sustainability Appraisal documents identify initial factors considered in meeting objectives. See: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/issues-and-options-consultation/

The Councils Preferred Options were published along with accompanying maps, an analysis of the Issues and Options representations received and the Council’s responses, an Interim Sustainability Appraisal and a Habitats Regulations Assessment identify key issues considered in meeting objectives. Documents can be viewed at: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/issues-and-options-consultation/

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/issues-and-options-consultation/

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/preferred-options-consultation/



allocations-and-area-specific-policies/preferred-options-consultation/

The consultations held have provided the opportunity for the Council to adequately identify key issues regarding the approach taken to achieving identified policy objectives.

To view the full comments received: Representations made to the Council can be viewed at:

http://suffolkcoastal.jdi-consult.net/localplan/

The Submission document library can be viewed at: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Is it clear how the policies will meet the objectives?

Are there any obvious gaps in the policies, having regard to the objectives of the DPD?

Clarity is provided through a preamble contained at the start of each chapter of the DPDs. This text sets out the issues raised through consultation, identifies the policy areas to be addressed in each chapter, cites key data and other evidence base documents, and explains the approach taken and the objectives of the policies presented.

Those parts of the District covered by designated Neighbourhood Plan areas (as at 31.03.2016) will be responsible for setting land use policies in their respective areas unless they wish the Council to fulfil this role. A map (SAASP p7 Map 1) is provided showing the situation with Neighbourhood Plans as at 31st March 2016. Text is provided explaining the relationship between Neighbourhood Plans and the DPD’s in the SAASP pp5-6 and the Felixstowe Peninsula AAP p5.

Have reasonable alternatives to the quantum of development and overall spatial strategy been considered?

Reasonable Alternatives considered

The Proposed Submission Sustainability Appraisal (SA) Report contained in each DPD considers the compatibility of the objectives and provides the reasons for rejecting reasonable alternatives. The SA report also assesses alternative policy options considered for sites.

Proposed Submission Sustainability Appraisal Reports were prepared for the respective DPD’s and can be viewed at: pp13-34 for the SAASP and pp14-19 of the Felixstowe Peninsula AAP. http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-and-Area-

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/preferred-options-consultation/

http://suffolkcoastal.jdi-consult.net/localplan/

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/



http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-and-Area-Specific-Policies/SSP-SA-report.pdf



Specific-Policies/SSP-SA-report.pdf

http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Felixstowe-AAP/FAAP-SA-report.pdf

Within each, is contained the respective Summary of all Sites Considered with reasons for site rejection.

Are the policies internally consistent?

Policies Internally Consistent

The Council considers the DPD’s to be internally consistent.

DPD’s have been subject to 2 rounds of public consultation and have been brought before a Meeting of the Scrutiny Committee which identified no internal inconsistency. Minutes of the Meeting of the Scrutiny Committee 10.03.2016 can be viewed at: http://apps.eastsuffolk.gov.uk/committeeminutes/showagenda.asp?id=21334

For each chapter in the DPDs, a preamble sets out the context within which the site and area specific policies therein will implement the CS strategic policies. It is the role of the DPD to deliver the strategic aims of the adopted CS. Therefore the SA objectives established for the CS, have been used to test the compatibility of DPD policies against identified SA objectives.

The cumulative effects of all the proposed submission policies on each sustainability objective were also tested within a cumulative effects matrix. The cumulative effect of the DPDs creates a positive effect against most Sustainability Objectives. This indicates a high degree of internal consistency based on the positive scorings which result when cumulative effects are assessed.

Are there realistic timescales related to the objectives?

Realistic Timescales Identified

Likely timescales for delivery of housing allocations identified in the DPD’s have been included in an Indicative Housing Trajectory 2010-2027. The trajectory is accompanied with a detailed breakdown of delivery throughout the plan period. Additionally, both DPDs include a Delivery Framework and a Monitoring Framework by which delivery rates can be monitored.

The SAASP follows the infrastructure table in the CS and as such, the Authority Monitoring Report (AMR) provides the mechanism to highlight issues and initiate required responses. See SAASP pp122-127.

To provide additional clarity, the Felixstowe Peninsula AAP DPD has a bespoke Infrastructure




http://apps.eastsuffolk.gov.uk/committeeminutes/showagenda.asp?id=21334



Framework which outlines key information required for monitoring the progress of delivery such as indicative phasing, potential sources of funding and the responsible agencies. See: pp93-108.

The annual infrastructure process for CIL spend and policy specific requirements identified in policies within the DPDs form the basis for identifying and addressing infrastructure requirements necessary to meeting identified timescales for delivery. Those infrastructure project/types that SCDC intends to use funds generated via the CIL Charging Schedule to contribute towards can be viewed at: http://www.eastsuffolk.gov.uk/planning/community-infrastructure-levy/suffolk-coastal-community-infrastructure-levy-rates/

Does the DPD explain how its key policy objectives will be achieved?

It is the purpose of the DPDs to implement the strategic policies of the CS to secure key policy objectives. An explanation is provided through a preamble contained at the start of each chapter of the DPDs.

The presumption in favour of sustainable development (NPPF paras 6-17)

Plans and decisions need to take local circumstances into account, so that they respond to the different opportunities for achieving sustainable development in different areas.

Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless:

––any adverse impacts of doing so would significantly and demonstrably outweigh

Opportunities for achieving sustainable development

New housing will be concentrated in those settlements identified in the CS as the most sustainable and for which an up-to-date physical limits boundary is identified. The DPD’s will contribute to ensuring that housing delivery is spread across the District in accordance with the approach to housing distribution outlined in the CS to deliver sustainable development.

The location and scale of housing identified in the DPDs accords with CS policy SP2-Housing Numbers and Distribution p28, which provides the broad distribution for the provision of housing across the District and CS policy SP19-Settlement Policy which establishes where individual settlements sit within the settlement hierarchy.

The DPD’s will facilitate the delivery of the CS’s minimum housing requirement of 7,900 dwellings between 2010-2027. The CS identifies a commitment to undertake a review of the Local Plan aimed at meeting the acknowledged shortfall as identified against an up-to-date Objectively Assessed Need. This review is underway and details can be viewed in the current 2015 Local Development Scheme (LDS). See: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/local-development-scheme/

http://www.eastsuffolk.gov.uk/planning/community-infrastructure-levy/suffolk-coastal-community-infrastructure-levy-rates/


http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/local-development-scheme/




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.

The DPD’s identify more precisely the amount of new housing appropriate for specific settlements and allocate specific sites for development. They seek to implement the strategic policies of the CS at an area and site level. An identified over delivery based on a housing capacity of 8,620 dwellings provides the DPDs with sufficient flexibility regarding the need to adapt to rapid change.

The DPD’s Evidence Base included an Analysis of Preferred Options consultation responses, Sustainability Appraisal Report, and a Habitats Regulations Assessment which can be viewed at: Submission Document Library.


Policies in Local Plans should follow the approach of the presumption in favour of sustainable development so that it is clear that development which is sustainable can be approved without delay. All plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally.

See CS policy SP1A-Presumption in Favour of Sustainable Development p24.

DPD sites set out clear policy requirements which provide certainty and inform development proposals across the District which accord with the principles of sustainable development in the NPPF and the CS policies. The DPDs are seeking to deliver the CS policies in a positively planned manner further in accordance with the NPPF principles of sustainable development.

Objectively assessed needs

The economic, social and environmental needs of the authority area addressed and clearly presented in a fashion which makes effective use of land and specifically promotes mixed use development, and take account of cross-boundary and strategic issues.

Note: Meeting these needs should be subject to the caveats specified in Paragraph 14 of the NPPF (see above).

The DPD’s will facilitate the delivery of the CS’s minimum housing requirement of 7,900 dwellings between 2010-2027. The CS identifies a commitment to undertake a review of the Local Plan aimed at meeting the acknowledged shortfall as identified against an up-to-date Objectively Assessed Need. This review is underway and details can be viewed in the current 2015 LDS. See: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/local-development-scheme/

The DPDs provide key housing information showing how many dwellings are still to be delivered across the District. See: Fig. 3 Housing Delivery Position as of 1st April 2015 and Table 1. Housing Delivery Position 2010-2027 for the District. (SAASP pp13-14 and Felixstowe Peninsula AAP pp16-17).

The economic, social and environmental needs of the authority area are further considered by the Proposed Submission Sustainability Appraisal Reports.







Background evidence papers demonstrating requirements based on population forecasts, employment projections and community needs can be viewed in the CS Evidence Base.

NPPF Principles: Delivering sustainable development

Building a strong, competitive economy (paras 18-22)

Set out a clear economic vision and strategy for the area which positively and proactively encourages sustainable economic growth (21),

Set out a clear economic vision and strategy for the area

CS policy SP5-Employment Land sets out the spatial strategy for employment land uses, including B1, B2 and B8 in addition to complementary ancillary uses. The policy identifies strategic employment sites and general employment sites i.e. other employment sites that are significant at a District level.

In addition to identifying 30 ha of new employment land, the DPDs will seek to protect, as appropriate, existing employment sites.

Site specific employment land allocations and accompanying policies are identified within both DPDs.

The SAASP sets out a framework within which business can operate and expand. The SAASP identifies a new site capable of satisfying the 8.5ha CS requirement for additional employment land at Ransomes, Nacton Heath (SSP20-Ransomes, Nacton Heath) as a Strategic Employment Area. Policies SSP21-27 identify other general employment areas and update policy for large rural employment sites including the type of employment uses appropriate for these locations.

The Felixstowe Peninsula AAP sets out a framework within which business can operate and expand. FPP9 covers the strategic employment site of the Port of Felixstowe and provides policy detail regarding the future development of the port and the type of employment uses appropriate for this location. FPP10-12 identify sites and update policy for other general employment sites with the AAP area.

The maps accompanying the DPD’s show the extent of the Strategic and General Employment Areas across the District.



Recognise and seek to address potential barriers to investment, including poor environment or any lack of infrastructure, services or housing (21)

A criteria-based policy which meets identified needs

Criteria based policy which meets identified needs is cited in the Employment chapter’s preamble for both DPDs. The criteria consist of: position within settlement hierarchy, ability to meet the needs of business, ability to support the growing sectors of the local economy, potential to contribute to regeneration and, in the case of the Felixstowe Peninsula AAP, achieve a better balance between port and non-port related employment opportunities.

An up-to-date assessment of the deliverability of allocated employment sites

The DPD’s seek to address potential barriers to investment by identifying existing and additional employment land capacity, and providing up-to-date NPPF compliant policies. The SCDC Employment Land Availability Study annually updates the uptake of employment land and the availability of land within key employment sites. This annual assessment and other Employment Land evidence was used to underpin the DPDs and confirmed that the District’s main employment sites remain appropriate to use and are likely to continue to prove attractive areas for business to locate. Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Ensuring the vitality of town centres (paras 23-37)

Policies should be positive, promote competitive town centre environments, and set out policies for the management and growth of centres over the plan period (23)

Definition of networks and hierarchies

Within the CS, policy SP9-Retail Centres identifies a retail hierarchy. The main Retail Centres are the 5 market towns of Aldeburgh, Framlingham, Leiston, Saxmundham and Woodbridge and the major centre of Felixstowe with a second tier of District Centres also identified across the District. The scale of new floorspace provision associated with each is set out in SP19-Settlement Hierarchy.

Defining town centres

The boundaries of relevant town and district centres have been reviewed and where necessary updated to reflect recent planning permissions, developments and national policy requirements. Communities that are designated as Neighbourhood Plan areas are not included within the DPDs as these town centres will be defined through individual Neighbourhood Plans. Alongside the town and





district centre boundaries, the DPD’s identify primary and secondary shopping frontages and primary shopping areas to ensure that local retail policies are consistent with national policies. Revised boundaries and designations are shown on the maps accompanying the DPDs.

In addition, the SAASP defines a tertiary tier of retail centres referred to as local retail centres. Within the defined retail boundaries, bespoke retail policy is provided for each centre.

SAASP: See SSP28-Aldeburgh Town Centre, SSP29-Saxmundham Town Centre, SSP30-District Centres, SSP31-Local Centres pp76-89.

Felixstowe Peninsula AAP: See FPP13-Felixstowe Town Centre, FPP16-District Centres pp54-64. Within defined town centres, Primary and Secondary shopping frontage is defined as well as the Primary shopping area.

See: AMR, Retail Vitality Survey 2015 (undertaken on an annual basis) and 2015 Suffolk Coastal Retail Capacity Refresh: FINAL REPORT October 2015 See: Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Allocate a range of suitable sites to meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community services and residential development needed in town centres (23)

An assessment of the need to expand (the) town centre(s), considering the needs of town centre uses.

The Council conducts a Retail Monitoring Survey annually which is used to inform an assessment of retail provision in the District. The most recent monitoring information has been used to inform the policy requirements detailed within the DPDs to provide a range of suitable sites that ensure the vitality of town centres across the District.

In addition to work done for the CS, the Council commissioned a Retail Capacity Refresh Report setting out updated retail projections for Suffolk Coastal, October 2015 which has informed the DPD’s to ensure consistency with national retail policy See: Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Supporting a prosperous rural economy (para 28)



http://www.suffolkcoastal.gov.uk/assets/Documents/District/Planning-policy/Local-Plan/SCDC-Retail-Capacity-Refresh-2015.pdf





Support sustainable economic growth in rural areas. Planning strategies should promote a strong rural economy by taking a positive approach to new development. (28)

CS policy SP7-Economic Development in the Rural Areas seeks to maintain and expand on the existing employment opportunities in accordance with the tiering of the settlement hierarchy, to encourage small scale farm and other rural enterprises diversification initiatives, to support agriculture and to promote the expansion of rural tourism in accordance with the aims of SP8-Tourism.

The SAASP identifies a number of Large Rural Employment Sites 3.15-3.35 pp63-69 and General Employment Sites located in rural areas or within smaller settlements 3.36-3.48 pp70-74. The policy recognises that these sites represent an important source of local employment and aims to maintain and facilitate the expansion of appropriate uses.

CS policy SP8-Tourism identifies tourism as an important sector within the local economy and in many of the smaller rural communities provides an important source of local employment. Tourism depends on a variety of factors including visitor attractions, town centre offer, a high quality environment and enjoyment of seaside and estuarine activities which supports economic growth in the urban and rural areas of the District.

The DPD’s include specific policies in respect of rural tourism, such as FPP22: Visitor Management – Special Protection Areas, and SSP23-Visitor Management –European Sites that aim to manage the overlapping and potentially competing interests of the various elements that together contribute to the tourist offer within the District and thereby encourage sustainable tourism. SSP33-Snape Maltings-aims to promote rural tourism whilst seeking to protect the character of heritage and natural environmental assets of the area.

The Recreational Avoidance and Mitigation Strategy (RAMS) (to be prepared for Babergh District Council, Ipswich Borough Council and Suffolk Coastal District Council and adopted by March 2017) will seek to provide improved access to the countryside and other green infrastructure to mitigate pressure on the SPAs. The network of Public Rights of Way shall be maintained to facilitate enjoyment of rural parts of the DPD areas. The provision of links from new residential developments to the existing Public Rights of Way network which allow opportunity to create circular routes and encourage access away from the estuaries and other European Sites which are designated Special Protection Areas will be encouraged.



Promoting sustainable transport (paras 29-41)

Facilitate sustainable development whilst contributing to wider sustainability and health objectives. (29)

Balance the transport system in favour of sustainable transport modes and give people a real choice about how they travel whilst recognising that different policies will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas. (29)

Encourage solutions which support reductions in greenhouse gas emissions and congestion (29) including supporting a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport. (30)

Local authorities should work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development. (31)

Opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure. (32)

Ensure that developments which generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised (34)

Facilitate sustainable development whilst contributing to wider sustainability and health objectives. (29)

All housing and employment site allocations identified have been informed by the use of SA scorings to help identify the most sustainable locations including access to public transport and travel distances to key services.

Supporting a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport. (30,34)

All housing sites identified for development accord with Table 3.3 which accompanies CS policy SP2-Housing Numbers and Distribution p28, and provides the broad distribution for the provision of housing across the District. CS policy SP19-Settlement Policy pp61-65, and supporting Tables 4.1 and 4.2 establish where individual settlements sit within the settlement hierarchy. In part, a settlements positioning within the settlement hierarchy is determined by its identification as a transport hub according to the availability of public transport.

Employment and retail locations are also located in accordance with CS policy SP19-Settlement Policy pp61-65, and supporting Tables 4.1 and 4.2 establish where individual settlements sit within the settlement hierarchy.

Develop strategies for the provision of viable infrastructure necessary to support sustainable development. (31,32)

Sites allocated to help accommodate mitigation requirements of neighbouring local authority – Ipswich Garden Suburb which utilises Sustainable transport modes such as Westerfield train station. Policy requirements to provide cycle and pedestrian links as appropriate e.g. Felixstowe Peninsula AAP policy FPP4 p32.

Plans should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. (35,37)



Plans should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. (35)

Policies should aim for a balance of land uses so that people can be encouraged to minimize journey lengths for employment, shopping, leisure, education and other activities. (37)

For larger scale residential developments in particular, planning policies should promote a mix of uses in order to provide opportunities to undertake day-to-day activities including work on site. Where practical, particularly within large-scale developments, key facilities such as primary schools and local shops should be located within walking distance of most properties. (38)

The setting of car parking standards including provision for town centres. (39-40)

Local planning authorities should identify and protect, where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen transport choice. (41)

New housing and employment sites have been subject to SA and can be seen in the Sustainability Appraisal Report including reasons for discounting sites (as seen in the Summary of all Sites Considered and Reasons for Rejection SAASP pp13-34 and Felixstowe peninsula AAP pp14-19.

SA considered site access to bus stops and train stations, and access to the Public Rights of Way network, and bus and cycle lanes.

SAASP: http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-and-Area-Specific-Policies/SSP-SA-report.pdf

Felixstowe Peninsula AAP: http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Felixstowe-AAP/FAAP-SA-report.pdf

Ensure that developments which generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised (34)

As required by the Local Highways Authority, the need for Transport Assessments to be undertaken has been written into site specific policy.

A Cumulative Impact Assessment for the Felixstowe Peninsula examining additional evidence base work looking at road and junction capacity has been commissioned and can be viewed at: Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

(38) N/A

(39-40) Suffolk County Council car parking standards not adopted as deemed inappropriate for the rural nature of the District.

(41) Felixstowe Peninsula AAP policy FPP4, identifies the need for provision of a link road between










Candlet Road and High Street, Walton.

Supporting high quality communications infrastructure (paras 42-46)

Support the expansion of the electronic communications networks, including telecommunications’ masts and high speed broadband. (43)

Local planning authorities should not impose a ban on new telecommunications development in certain areas, impose blanket Article 4 directions over a wide area or a wide range of telecommunications development or insist on minimum distances between new telecommunications development and existing development. (44)

There are no specific policies with in the DPDs aimed at supporting high quality communications infrastructure however;

CS policy SP18-Infrastructure seeks to meet infrastructure needs and address identified deficiencies including communications infrastructure. In addition, the Council has now adopted a Community Infrastructure Levy (CIL) Charging Schedule and charges have been in effect since Monday 13 July 2015. Information regarding infrastructure prioritisation is contained within the CIL Infrastructure List (Regulation 123 list) and can be viewed at: http://www.eastsuffolk.gov.uk/planning/community-infrastructure-levy/suffolk-coastal-community-infrastructure-levy-rates/

New residential sites identified in the SAASP and the Felixstowe Peninsula AAP will be CIL liable.

Delivering a wide choice of high quality housing (paras 47-55)

Identify and maintain a rolling supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements; this should include an additional buffer of 5% or 20% (moved forward from later in the plan period) to ensure choice and competition in the market for land. 20% buffer applies where there has been persistent under delivery of housing(47)

To provide five years’ worth of housing against their housing requirements

The Council’s current 5 year housing land supply position statement identifies a 6.3 years supply +5% buffer. See: Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

This housing supply figure includes a small annual windfall allowance (48).

A Strategic Housing Land Availability Assessment (SHLAA) was completed in 2014 to provide the DPD development process with an up-to-date evidence base regarding land availability. Sufficient deliverable/ developable sites were identified to accommodate the current housing target. See: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-






http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/evidence-base/strategic-housing-land-availability-assessment-shlaa/



plan/evidence-base/strategic-housing-land-availability-assessment-shlaa/

Identify a supply of developable sites or broad locations for years 6-10 and, where possible, years 11-15 (47).

Both DPDs contain the Indicative Housing Trajectory that identifies a supply of developable sites or broad locations for years 6-10 and, years 11-15.

Illustrate the expected rate of housing delivery through a trajectory; and set out a housing implementation strategy describing how a five year supply will be maintained. (47)

The DPD’s contain a housing trajectory ‘Indicative Housing Trajectory 2010-2027’. See: SAASP p129 and Felixstowe Peninsula AAP p102.

The annually produced AMR will provide up-to-date information regarding monitoring of completions and permissions.(47)

The current SHLAA will be updated in 2016. (47)

Set out the authority’s approach to housing density to reflect local circumstances (47).

Bespoke research was undertaken for the SHLAA regarding the density of development aimed at reflecting local circumstances. This work, together with other site specific analysis including viability analysis has informed identified site densities. See SCDC Viability Study 2016 See: Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Plan for a mix of housing based on current and future demographic and market trends, and needs of different groups (50) and caters for housing demand and the scale of housing supply to meet this demand. (para 159)

The DPD’s seek to provide a mix of housing opportunities to meet housing demand across the District through providing a range of house types and tenures, in accordance with national policies and the CS. The DPD’s demonstrate how the Council will deliver housing distributions as outlined in the CS Settlement Hierarchy.

DPDs make reference to the provision of dwellings to cater for all sections of the community - smaller units, bungalows, units for older people etc. Detail regarding housing mix to cater for market trends and the needs of different groups can be viewed at: SAASP Housing Allocation 2.23-2.28 pp22-23 and Housing Allocation Policies pp26-58 and: Felixstowe Peninsula AAP Housing Allocation 3.31 – 3.35 pp24-25 and Housing Allocation Policies pp27-43.

Background evidence papers demonstrating requirements based on population forecasts, employment projections and community needs can be via the CS Evidence Base. Specifically, Housing Assessments and Studies, including the SHMA 2008.

In rural areas be responsive to local circumstances and plan housing development to reflect local needs,

The CS contains a series of strategic policies and Development Management policies which are applied to help meet the requirement for affordable housing, including through rural exception sites

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/evidence-base/strategic-housing-land-availability-assessment-shlaa/






particularly for affordable housing, including through rural exception sites where appropriate (54).

In rural areas housing should be located where it will enhance or maintain the vitality of rural communities.

where appropriate. See DM1-Affordable Housing on Exception Sites, DM2-Affordable Housing on Residential Sites and DM3-Housing in the Countryside. The DPD’s will support the policies in the CS to ensure the continued vitality of rural communities.

Across the District, a number of rural communities are committed to producing Neighbourhood Plans for their areas. The Neighbourhood Plans will reflect local housing needs and seek to deliver housing broadly in accordance with the levels of growth detailed in the CS and the DPD’s.

Requiring good design (paras 56-68)

Develop robust and comprehensive policies that set out the quality of development that will be expected for the area (58).

All proposals will be determined in accordance with policies in the NPPF, adopted CS and DM Policies, and the DPD’s. See CS policy SP15-Landscape and Townscape and; DM21-Design: Aesthetics and DM22-Design: Function.

Site specific policies have been developed through feedback received through 2 rounds of public consultation with residents; Historic England, Suffolk County Council, district, town and parish Councils; developers and land owners; statutory consultants, infrastructure providers, local members working groups, and others. Site specific policies have also been informed by an Interim Sustainability Appraisal and a Habitats Regulations Assessment.

Officers have undertaken visits to each site and, as appropriate, have sought additional input from Development Management, Landscape and Arboriculture, and Conservation colleagues to inform design requirements.

Promoting healthy communities (paras 69-77)

Policies should aim to design places which: promote community interaction, including through mixed-use development; are safe and accessible environments; and are accessible developments (69).

CS policy SP16-Sport and Play seeks to provide, protect and enhance sports and recreational facilities. The play space ‘national standard’ is applied in calculating required levels of provision. Provision is to be met through developer contributions.

CS policy SP17-Green Space seeks to ensure communities have access to a greenspace hierarchy and that identified deficiencies within particular schemes are mitigated through developer contributions or CIL.

The Haven Gateway Green Infrastructure Strategy (HAGGIS) for the Ipswich Policy Area has been updated to provide analysis of provision and deficiencies of accessible natural greenspace (according to the Natural England standards set out in Nature Nearby) across the Ipswich Policy Area. See: Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-





documents/core-document-library/

CS policy SP18-Infrastructure seeks to meet infrastructure needs and address identified deficiencies including community infrastructure – services and facilities. Provision of leisure and community facilities will be met, in part, through CIL.

The Council has now adopted a CIL Charging Schedule and charges have been in effect since Monday 13 July 2015. Information regarding infrastructure prioritisation is contained within the CIL Infrastructure List (Regulation 123 list) and can be viewed at: http://www.eastsuffolk.gov.uk/planning/community-infrastructure-levy/suffolk-coastal-community-infrastructure-levy-rates/

The SCDC Leisure Strategy has informed the recreational requirements in some areas. Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Both DPD’s seek to implement policies aimed at promoting healthy communities such as:

provision of accessible natural greenspace (ANG);

encouraging linking sites to the existing Public Rights of Way network and cycle lanes;

improving pedestrian linkage to adjacent Badingham pocket park;

provision of pedestrian crossing points across roads;

identifying opportunities for mixed use schemes (employment and tourism/commercial sites in Felixstowe/community car park in Shottisham);

securing the retention or alternative provision of Felixstowe rifle club;

Each DPD contains a chapter dedicated to environmental policy. Each chapter contains area and site specific policies covering conservation, protection, enhancement, or management of the environment.

SAASP: See policies SSP37 – SSP43 pp103-117.

Felixstowe Peninsula AAP: See policies FFP25 – FFP28 pp79-85.

Community interaction may be further promoted through protecting local retail provision i.e. through the identification of new district retail centres and the creation of a new designation of ‘local’ retail centre.

SAASP: SSP31-Local Centre pp87-89.









Felixstowe Peninsula AAP: FPP16-District Centres pp61-64.

Policies should plan positively for the provision and use of shared space, community facilities and other local services (70).

As above.

Identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities; and set locally derived standards to provide these (73).

Identification of specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area has been undertaken via the SCDC Leisure Strategy 2014-24. The strategy, informed by a comprehensive evidence base, acts as a guide to the Council’s leisure development and operational partners as they look to improve leisure and recreational opportunities across the District. The Leisure Strategy has helped inform planning for the provision of new or improved leisure facilities in Suffolk Coastal identified in the DPDs.

See: SCDC Leisure Strategy - Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Enable local communities, through local and neighbourhood plans, to identify special protection green areas of particular importance to them – ‘Local Green Space’ (76-78).

Areas can be designated as Local Green Space when these areas are ‘special to a local community and hold a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife’.

The DPD’s do not contain specific policies aimed at delivering Local Green Space. Within the District, a comprehensive green infrastructure network is to be achieved by various alternative policy means.

CS policy SP17-Green Space seeks to ensure communities have access to a greenspace hierarchy and that identified deficiencies within particular schemes are mitigated through developer contributions or CIL.

The Haven Gateway Green Infrastructure Strategy (HAGGIS) for the Ipswich Policy Area has been updated to provide an up-to-date analysis of provision and deficiencies of accessible natural greenspace (according to the Natural England standards set out in Nature Nearby) across the Ipswich Policy Area. See: HAGGIS - Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/








The Council is providing advice, guidance and support through service level agreements to several Neighbourhood Plans (NP) at various stages of progression. The District also has one ‘made’ plan to date. NP steering groups may wish to identify ‘Local Green Space’ as part of a Neighbourhood Plan.

Protecting Green Belt land (paras 79-92)

Local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. (81)

Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. (83)

When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. (84)

Boundaries should be set using ‘physical features likely to be permanent’ amongst other things (85)

SCDC has no statutory Green Belt within its area.

Meeting the challenge of climate change, flooding and coastal change (paras 93-108)

Adopt proactive strategies to mitigate and adapt to climate change taking full account of flood risk, coastal change and water

Flood risk:

Strategic Flood Risk Assessment (SFRA) was used to help determine the CS broad scales and



supply and demand considerations. (94) distribution of new development and in the formulation of relevant Development Management Policies.

Regard has also been given to advice in the NPPF (paragraphs 93-108) and the accompanying Technical Guidance in respect of flood risk.

As part of the SHLAA 2014 and DPD site assessment process, potential housing sites located within Flood Zone 2 or 3 were discounted. With the exception of Felixstowe Peninsula AAP site FFP3-Sunday Market Site, Sea Road, Felixstowe and SAASP site SSP19-Land at Street Farm, Witnesham (Bridge) no housing allocations are located within Flood Zones 2 or 3.

Climate Change: SP12-Climate Change.

The site selection process has been informed by Sustainability Appraisals. Proposed Submission Sustainability Appraisal Reports consider the compatibility of sustainability objectives and provide the reasons fro rejecting reasonable alternatives. The SA report assesses alternative policy options considered for sites.

Key questions potentially affecting Climate Change considered include:

To improve access to key services for all sectors of the population;

To use water and mineral resources efficiently, and re-use and recycle where possible;

To reduce waste;

To reduce the effects of traffic on the environment; and

To encourage efficient patterns of movement in support of economic growth.

Proposed Submission Sustainability Appraisal Reports prepared for the respective DPD’s can be viewed at: http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-and-Area-Specific-Policies/SSP-SA-report.pdf pp13-34 for the SAASP and pp14-19 of the Felixstowe Peninsula AAP http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Felixstowe-AAP/FAAP-SA-report.pdf







Coastal change

CS policy SP30-The Coastal Zone identifies the need for Integrated Coastal Zone Management. This includes endorsing Estuarine Management Plans such as the Deben Estuary Plan and the implementation of Coastal Change Management Areas.

Felixstowe Peninsula AAP: pp87-88. The Shoreline Management Plan (SMP) policy is to primarily “hold the line” along that section of the Felixstowe coast line covered by the Felixstowe Peninsula AAP, therefore the Council does not consider it appropriate to introduce a Coastal Change Management Area (CCMA) for the Felixstowe Peninsula AAP area.

SAASP: pp112-117. Policy SSP42-Coastal Change Management Area (CCMA) seeks to resist residential development within the designated CCMA and will only permit other forms of non-residential development within the CCMA where it can be demonstrated (through the use of Coastal Erosion Vulnerability Assessments (CEVAs)) that there will be no increase in risk from coastal erosion.

Policy SSP43-Relocation and Replacement of Development Affected by Coastal Erosion Risk seeks to reduce the number of buildings and community facilities at risk from coastal erosion by permitting relocation or replacement development outwith the CCMA but close to the original coastal location.

Help increase the use and supply of renewable and low carbon energy through a strategy, policies maximising renewable and low carbon energy, and identification of key energy sources. (97)

The Code for Sustainable Homes (CfSH), which aimed to increase the use and supply of renewable and low carbon energy, has now been revoked and as such, CS policy DM24-Sustainable Construction is also revoked. See: https://www.gov.uk/government/speeches/planning-update-march-2015

Therefore, energy and water performance requirements will be implemented through Building Regulations at a level equivalent to CfSH Level 4. The higher energy and water requirement was considered as part of the Examination of the Development Management policies and found sound by the Planning Inspector.

Future housing energy standards will be expected to accord to Building Regulations and will not fall under the purview of planning policy except for legacy cases.

Minimise vulnerability to climate change and manage the risk of flooding (99)

As above.

https://www.gov.uk/government/speeches/planning-update-march-2015



Take account of marine planning (105)

SCDC, the Marine Management Organisation (MMO) and others are members of the Suffolk Coastal Forum; a body created to facilitate an integrated approach to coastal area management. See CS policy SP30-The Coastal Zone. SCDC has taken account of MMO advice to ensure that policies across the land/sea boundary are integrated.

Engagement with the MMO resulted in amendments to the Port of Felixstowe policy supporting text to include specific reference to policies within the East Inshore and East Offshore Marine Plans.

In particular, reference is made to MMO East Inshore and East Offshore Marine Plans policy PS3 ‘Consideration of future opportunity for expansion of ports and harbours’ with regards the Port of Felixstowe and MMO policy. See https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/312496/east-plan.pdf and Felixstowe Peninsula AAP paragraph 4.06 p46.

The objectives of East Inshore and East Offshore Marine Plans climate change policies (CC1 and CC2) as applicable to the SAASP and Felixstowe Peninsula AAP, will be dealt with through existing policies and regulations.

Manage risk from coastal change (106) Anticipated shorelines in a 100 years time are identified by Shoreline Management Plans (SMP). In accordance with NPPF paragraph 106, reducing the risk from coastal change through the identification of Coastal Change Management Areas is undertaken where rates of shoreline change are significant over the next 100 years, taking account of climate change.

Felixstowe Peninsula AAP: pp87-88. The Shoreline Management Plan (SMP) policy is to primarily “hold the line” along that section of the coast line covered by the Felixstowe Peninsula AAP, therefore the Council does not consider it appropriate to introduce a Coastal Change Management Area (CCMA) for the Felixstowe Peninsula AAP DPD.

SAASP: Coastal Change Management Area pp112-117.

Policy SSP42-Coastal Change Management Area seeks to resist residential development within the designated CCMA and will only permit other forms of non-residential development within the CCMA where it can be demonstrated (through the use of Coastal Erosion Vulnerability Assessments (CEVAs)) that there will be no increase in risk from coastal erosion.

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/312496/east-plan.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/312496/east-plan.pdf



Policy SSP43-Relocation and Replacement of Development Affected by Coastal Erosion risk seeks to reduce the number of buildings and community facilities at risk from coastal erosion by permitting relocation or replacement development outwith the CCMA but close to the original coastal location.

Conserving and enhancing the natural environment (paras 109-125)

Protect valued landscapes (109) DPD policies SSP37-Parks and Gardens of Historic or Landscape Interest p106 and FPP25-Historic Parks and Gardens p81 will be implemented through Supplementary Planning Guidance (SPG) 6 - Historic Parks and Gardens.

Within the District, a comprehensive biodiversity and green infrastructure network is to be achieved by various policy means.

Identified housing allocations located within the AONB stipulate the requirement for high quality design and that Landscape Visual Impact Appraisals been undertaken with appropriate mitigation to be provided as required.

The Council is providing advice, guidance and support through service level agreements to several Neighbourhood Plans (NP) at various stages of progression. The District also has one ‘made’ plan to date. NP steering groups may wish to identify ‘Local Green Space’ as part of a Neighbourhood Plan.

CS policy SP14-Biodiversity and Geodiversity seeks to protect a network of Designated sites; Wildlife corridors and links; The rivers, estuaries and coast; Identified habitats and geodiversity features; Landscape character areas; and Protected species. River valleys are included as Special Landscape Areas.

These policies will be implemented through the DPDs:

SAASP: Chapter 7 ‘Environment’ policies SSP37-SSP38 pp103-108.

Felixstowe Peninsula AAP: Chapter 7 ‘Environment’ policies FPP25-FPP28 pp79-85 and FPP22-Visitor Management-Special Protection Areas. See also:

Sustainability Appraisal Report. Areas designated as AONB/ Special Landscape Area captured



through SA sites scoring process.

HRA is used to assess whether policies within that DPD’s, and the guidance they provide, are likely to have any adverse effect upon the integrity of any European sites.

Sustainability Appraisal Report, and a Habitats Regulations Assessment can be viewed at: http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-and-Area-Specific-Policies/SSP-SA-report.pdf

http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-and-Area-Specific-Policies/Site-Allocations-HRA.pdf

http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-and-Area-Specific-Policies/Site-Allocations-and-Area-Specific-Policies-Proposed-Submission-Document.pdf

http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Felixstowe-AAP/Felixstowe-Peninsula-Area-Action-Plan-Proposed-Submission-Document.pdf


http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Felixstowe-AAP/Felixstowe-HRA.pdf

Prevent unacceptable risks from pollution and land instability (109)

Prevent unacceptable risks from pollution

CS policy DM23-Residential Amenity addresses amenity and pollution issues. Consultation with SCDC Environmental Services regarding Air Quality Management Areas (AQMAs) has helped inform the site selection process. Advice from the Local Highways Authority regarding junction capacities and likely associated air quality issues has also been considered.

Prevent unacceptable risks from land instability

Land stability is not a major issue in the District other than in conjunction with coastal cliff instability.















Shoreline Management Plan SMP7 Lowestoft Ness to Felixstowe Landguard Point. See Policy Development Zone 3 and Zone 4: http://www.suffolksmp2.org.uk/publicdocuments/finalsmp2/SMP%20May%202012%20Proof%203.pdf

Planning policies should minimise impacts on biodiversity and geodiversity (117)

Planning policies should plan for biodiversity at a landscape-scale across local authority boundaries (117)

CS policy SP17-Green Space seeks to ensure communities have access to a greenspace hierarchy and that identified deficiencies within particular schemes are mitigated through developer contributions or CIL. The Haven Gateway Green Infrastructure Strategy for the Ipswich Policy Area has been updated to provide an analysis of provision and deficiencies of accessible natural greenspace (according to the Natural England standards set out in Nature Nearby) across the Ipswich Policy Area. See: HAGGIS - Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Sites whether put forward by way of planning applications or through the site allocations process are subject as a minimum to a desk top study to identify and take into consideration any known biodiversity features. In the DPDs these are referenced in relation to individual sites. In addition, adopted policies SP14-Biodiversity and Geodiversity and DM27-Biodiversity and Geodiversity in the CS would still apply.

CS policy SP14-Biodiversity and Geodiversity seeks to protect a network of Designated sites; Wildlife corridors and links; The rivers, estuaries and coast; Identified habitats and geodiversity features; Landscape character areas; and Protected species. See: SAASP: Chapter 7 ‘Environment’ policies SSP103-SSP38 pp103-108. See: Felixstowe Peninsula AAP: Chapter 7 ‘Environment’ policies FPP25-FPP28 pp79-85 and FPP22-Visitor Management-Special Protection Areas.

HRA is used to assess whether policies within that DPD’s, and the guidance they provide, are likely to have any adverse effect upon the integrity of any European sites.

Habitats Regulations Assessment which can be viewed at: http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-and-Area-Specific-Policies/Site-Allocations-HRA.pdf


http://www.suffolksmp2.org.uk/publicdocuments/finalsmp2/SMP%20May%202012%20Proof%203.pdf

http://www.suffolksmp2.org.uk/publicdocuments/finalsmp2/SMP%20May%202012%20Proof%203.pdf










Conserving and enhancing the historic environment (paras 126-141)

Include a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk (126)

A strategy for the historic environment based on a clear understanding of the cultural assets in the plan area, including assets most at risk.

A map/register of historic assets.

A policy or policies which promote new development that will make a positive contribution to character and distinctiveness. (126)

A positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk has been taken through the researching, consultation and production of the DPDs:

The site selection and policy development process has been informed through identifying at an early stage any Heritage Assets (as defined by English Heritage) i.e. listed buildings, scheduled monuments, historic parks and gardens, historic battlefields and shipwrecks within the District. Consultation advice from English Heritage has helped inform policy and the site selection process. A map/register of historic assets: can be viewed via: https://historicengland.org.uk/listing/the-list/

Advice regarding archaeological sites has been received from the Suffolk County Council Archaeological Unit and has helped inform policy and the site selection process.

Non designated heritage assets: The Council has adopted ‘Criteria for the identification of non-designated heritage assets that are buildings’ to enable communities to identify potential buildings for designation. The criteria are technical guidance in support of CS policy SP15-Landscape and Townscape. See: http://www.eastsuffolk.gov.uk/planning/design-and-conservation/non-designated-heritage-assets-2/suffolk-coastal-identification-of-non-designated-heritage-assets/

As appropriate, Conservation Areas Appraisals have helped inform policy and the site selection process.

DPD policies SSP37-Parks and Gardens of Historic or Landscape Interest p106 and FPP25-Historic Parks and Gardens p81 will be implemented through Supplementary Planning Guidance (SPG) 6 - Historic Parks and Gardens.

Sites within designated Heritage Coastline have been considered against NPPF policy paragraph 114.

CS policy SP21-Felixstowe with Walton and the Trimley’s recognises the value of Felixstowe’s Edwardian heritage. As such, Felixstowe Peninsula AAP seeks to implement the heritage

https://historicengland.org.uk/listing/the-list/

http://www.eastsuffolk.gov.uk/planning/design-and-conservation/non-designated-heritage-assets-2/suffolk-coastal-identification-of-non-designated-heritage-assets/





aspects of this policy via policies FPP28-Areas to be protected from development, which designates areas important in preventing coalescence, or in contributing to the character or setting of listed buildings; and policies FPP17-FPP21 which identify distinct character areas along the seafront and the role that heritage plays in maintaining that character.

CS policy SP22-Aldeburgh recognises the town’s location within the AONB and Heritage Coast designations. As such, SAASP policy SSP42-The Garret Era Area, Aldeburgh, seeks to preserve and enhance the distinctive character of the area.

CS policy DM21-Design: Aesthetics. Policy or policies which promote new development that will make a positive contribution to character and distinctiveness.

Facilitating the sustainable use of minerals (paras 142-149)

It is important that there is a sufficient supply of material to provide the infrastructure, buildings, energy and goods that the country needs. However, since minerals are a finite natural resource, and can only be worked where they are found, it is important to make best use of them to secure their long-term conservation (142)

Minerals planning authorities should plan for a steady and adequate supply of industrial materials (146)

SCDC is not the minerals planning authority for the District. The supply of minerals is addressed through the Suffolk County Council Minerals CS which was adopted by Suffolk County Council on 25th September 2008.

As appropriate Minerals Safeguarding Areas have been identified as potential constraints to development through the DPD site selection process which forms part of the DPD’s evidence base.



Justified: The plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate

evidence.

To be ‘justified’ a DPD needs to be:

• Founded on a robust and credible evidence base involving: research / fact finding demonstrating how the choices made in the plan are backed up by facts; and evidence of participation of the local community and others having a stake in the area.

• The most appropriate strategy when considered against reasonable alternatives.

Participation

Has the consultation process allowed for effective engagement of all interested parties?

The Council has an adopted Statement of Community Involvement (SCI) September 2014, which has been complied with in undertaking public engagement and consultation. Public engagement has followed the principles set out in the SCI. See: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/statement-of-community-involvement/ and:

The Consultation Statement - Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Research / fact finding

Is the plan justified by a sound and credible evidence base? What are the sources of evidence? How up to date and how convincing is it?

What assumptions were made in preparing the DPD? Were they reasonable and justified?

The plan is justified by a sound and credible evidence base being up-to-date and convincing

The studies, reports and technical papers that provide the evidence for the policies set out in the DPDs, and the date of preparation and who they were produced by can be viewed in the Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

The DPD’s identify more precisely the amount of new housing appropriate for specific settlements and allocates specific sites for development. They seek to implement the strategic policies of the CS at an area and site level.

Sections of the DPDs and SA Reports which illustrate how evidence supports the strategy, policies and proposals included an Analysis of Preferred Options consultation responses, Sustainability Appraisal Reports, and Habitats Regulations Assessments which can be viewed http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/statement-of-community-involvement/

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/statement-of-community-involvement/









and-Area-Specific-Policies/SSP-SA-report.pdf




The evidence base includes updated evidence e.g. retail study refresh, Strategic Housing Land Availability Assessment, Green Infrastructure study, Cycling Strategy, Leisure Strategy, Marine Plan and Deben Estuary Plan and other evidence. Further evidence can be viewed at: Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

The approach taken is reasonable and justified, being subject to public consultation and underpinned by a robust evidence base.

Assumptions made in preparing the DPD

That the DPD’s will implement the strategic policies set out in the adopted CS and will provide the policy framework at a more detailed and local level for the development and use of land over the next 10 -15 years for the District (excluding ‘made’ and ‘designated’ Neighbourhood Development Plan areas (as of 31.03.2015) and the Adastral Park strategic housing site);

That during the period 2016 - 2027, the Adastral Park strategic housing site will deliver at least 1,575 dwellings; that Neighbourhood Development Plans will deliver at least 820 dwellings; and that windfall delivery will contribute at least 550 dwellings. See SAASP/Felixstowe Peninsula AAP: Fig.3 Housing Delivery Position as of 1 April 2015;

That the Council can, ahead of adoption of the DPD’s make good progress towards achieving a five year housing land supply. That the strategy and sites identified in the DPD’s will enable













the Council to continue to demonstrate an annual rolling five year supply position through the plan period and demonstrate a five year housing land supply based on a plan led approach. See: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/evidence-base/housing-land-supply-assessment/

That the Council will embark on a Local Plan review as detailed in the Local development Scheme (LDS) and as committed to in the Core Strategy . See: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/local-development-scheme/

That the documents will evolve in response to comments received at each consultation stage. See Consultation Statement.

Alternatives

Can it be shown that the LPA’s chosen approach is the most appropriate given the reasonable alternatives? Have the reasonable alternatives been considered and is there a clear audit trail showing how and why the preferred approach was arrived at? Where a balance had to be struck in taking decisions between competing alternatives, is it clear how and why the decisions were taken?

Does the sustainability appraisal show how the different options perform and is it clear that sustainability considerations informed the content of the DPD from the start?

The approach taken, given the reasonable alternatives, is the most appropriate and has been arrived at through the plan making process.

An audit trail showing the reasons for rejecting sites is provided by viewing the DPD Evidence Base.

The Proposed Submission Sustainability Appraisal Reports contained in each DPD which considers the compatibility of the objectives and provides the reasons for rejecting reasonable alternatives. The SA report also assesses alternative policy options considered for sites.

Site and area specific Sustainability Appraisals were undertaken for the DPDs and show how the different options perform and make clear that sustainability considerations informed the content of the DPD from the start. See: Proposed Submission Sustainability Appraisal Reports prepared for the respective DPD’s: http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Site-Allocations-and-Area-Specific-Policies/SSP-SA-report.pdf

pp13-34 for the SAASP and pp14-19 of the Felixstowe Peninsula AAP http://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Felixstowe-AAP/FAAP-SA-report.pdf

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/evidence-base/housing-land-supply-assessment/

http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/evidence-base/housing-land-supply-assessment/









Effective: the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.

To be ‘effective’ a DPD needs to:

• Be deliverable

• Demonstrate sound infrastructure delivery planning

• Have no regulatory or national planning barriers to its delivery

• Have delivery partners who are signed up to it

• Be coherent with the strategies of neighbouring authorities

Demonstrate how the Duty to Co-operate has been fulfilled

• Be flexible

• Be able to be monitored

Deliverable and Coherent

• Is it clear how the policies will meet the Plan’s vision and objectives? Are there any obvious gaps in the policies, having regard to the objectives of the DPD?

• Are the policies internally consistent?

• Are there realistic timescales related to the objectives?

• Does the DPD explain how its key policy objectives will be achieved?

Objectives

The DPDs will facilitate the delivery of the CS vision and objectives, policies and proposals within their respective plan areas; the strategic issues having already been identified in the CS. The DPDs clearly state their purpose as being:

To implement the CS ‘through settlement specific land use policies and the identification of new development’;

and that this key aim will be facilitated through the:

Provision of updated physical limits boundaries;

Identification of local infrastructure requirements; and

Replacement of remaining ‘saved’ policies from the previous 2001 Local Plan within their respective plan areas.

The relationship between the Submission Documents and other Local Plan documents such as Neighbourhood Plans is clearly illustrated.

Each DPD chapter relates to a corresponding CS Objective and cites the relevant strategic policy/ies to be facilitated through the implementation of policy within the DPD’s.

Clear Vision (Gaps In The Policies?)

Clear vision is provided through a preamble contained at the start of each chapter of the DPDs. This



text sets out the issues raised through consultation, identifies the policy areas to be addressed in each chapter, presents key data and other evidence, and explains the approach taken and the objectives of the policies presented. DPD policies are set in context by linking them to relevant NPPF and CS policy. Chapter topics for the DPD’s are:

SAASP-Housing, Economy, Retail, Tourism, Recreation and Green Infrastructure, and the Environment.

Felixstowe Peninsula AAP- Housing, Employment, Retail, Tourism and Sea Front, and the Environment.

Additionally, a direct relationship between the identified issues, the vision(s) and the objectives cited in the Felixstowe Peninsula AAP p15 can be viewed in the CS policy SP21-Felixstowe with Walton and the Trimley Villages p75.

Parts of the District covered by designated Neighbourhood Plan areas (as at 31.03.2015) will be responsible for setting land use policies in their respective areas unless they wish the Council to fulfil this role. The DPD’s contain a map showing the situation as at March 2016. Text is provided explaining the relationship between Neighbourhood Plans and the DPP’s in SAASP pp5-6 and the Felixstowe Peninsula AAP p5.

Internal consistency

The Council considers the DPD’s to be internally consistent.

DPD’s have been subject to 2 rounds of public consultation and have been brought before a Meeting of the Scrutiny Committee. Minutes of the Meeting of the Scrutiny Committee 10.03.2016 can be viewed at http://apps.eastsuffolk.gov.uk/committeeminutes/showagenda.asp?id=21334

For each chapter in the DPDs, a preamble sets out the context within which the site and area specific policies therein will implement the CS strategic policies. It is the role of the DPD to deliver the strategic aims of the adopted CS. Therefore the SA objectives established for the CS, have been used to test the compatibility of DPD policies against identified SA objectives.

The cumulative effects of all the proposed submission policies on each sustainability objective were also tested within a cumulative effects matrix. The cumulative effect of the DPDs will create a positive effect on most Sustainability Objectives. This indicates a high degree of internal consistency based on the positive scorings which result when cumulative effects are assessed.

Realistic timescales

Likely timescales for delivery of housing allocations identified in the DPDs have been included in an Indicative Housing Trajectory 2010-2027. The trajectory is accompanied with a detailed breakdown of

http://apps.eastsuffolk.gov.uk/committeeminutes/showagenda.asp?id=21334



delivery.

Table 6.1 pp122-125 of the CS outlines the level of infrastructure necessary, which along with the annual infrastructure process for CIL spend and policy specific requirements identified in policies within the DPDs form the basis for identifying and addressing infrastructure requirements.

Those infrastructure project/types that SCDC intends to use funds generated via the CIL Charging Schedule to contribute towards can be viewed at: http://www.eastsuffolk.gov.uk/planning/community-infrastructure-levy/suffolk-coastal-community-infrastructure-levy-rates/

If through the monitoring process, the Council’s planning policy outcomes are not being delivered, consideration will be given to revising the plan or element s of the plan accordingly. The Monitoring Framework can be viewed in CS Table 6.2 pp126-129. The latest Authority’s Monitoring Report (AMR) can be viewed at: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/evidence-base/authority-monitoring-reports/

Infrastructure Delivery

• Have the infrastructure implications of the policies clearly been identified?

• Are the delivery mechanisms and timescales for implementation of the policies clearly identified?

• Is it clear who is going to deliver the required infrastructure and does the timing of the provision complement the timescale of the policies?

The infrastructure implications of the policies have been clearly identified along with the delivery mechanisms and timescales for implementation and are set out in the DPD Infrastructure Delivery and Monitoring Frameworks.

The SAASP follows the infrastructure table in the CS and as such, the AMR provides the mechanism to highlight issues and initiate required responses. See SAASP pp122-127.

The Felixstowe Peninsula AAP has a bespoke Infrastructure Framework which outlines key information required for monitoring the progress of delivery such as indicative phasing, potential sources of funding and the responsible agencies.

Felixstowe Peninsula AAP See: pp93-98 which along with the annual infrastructure process for CIL spend and policy specific requirements identified in policies within the DPDs form the basis for identifying and addressing infrastructure requirements.

Co-ordinated Planning

Does the DPD reflect the concept of spatial planning? Does it go beyond traditional land use planning by bringing together and

The Council has consulted widely during the production of the DPDs to afford the opportunity for issues to be raised and comments to be received. Comments were received from residents; Suffolk County Council, district, town and parish Councils; developers and land owners; statutory consultants, infrastructure providers, local members working groups, and others in bringing together and



http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/evidence-base/authority-monitoring-reports/




integrating policies for the development and use of land with other policies and programmes from a variety of agencies / organisations that influence the nature of places and how they function?

integrating policies for the development and use of land with other policies and programmes.

DPD’s have been produced under the Duty to Cooperate with a range of service providers and delivery partners to ensure that planning policies bring together land use issues as well as the infrastructure and community needs highlighted. See: Duty to Cooperate Statement - Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Flexibility

• Is the DPD flexible enough to respond to a variety of, or unexpected changes in, circumstances?

• Does the DPD include the remedial actions that will be taken if the policies need adjustment?

As the DPDs will implement the CS strategic aims and policies, key output indicators are already being reported in the AMR. As such, the AMR coupled with the DPD Infrastructure Implementation and Delivery Frameworks provide the mechanism to highlight these issues and initiate required responses to changes in circumstances.

Flexibility is provided by the DPDs identifying sufficient sites to deliver more than the identified housing and employment land target within the plans life time. An identified over delivery based on a housing capacity of 8,620 dwellings provides the DPDs with sufficient flexibility regarding the need to adapt to rapid change.

Furthermore, the opportunity to adjust policies can be taken up through the Local Plan Review process.

Co-operation

• Is there sufficient evidence to demonstrate that the Duty to Co-operate has been undertaken appropriately for the plan being examined?

• Is it clear who is intended to implement each part of the DPD? Where the actions required are outside the direct control of the LPA, is there evidence that there is the necessary commitment from the relevant organisation to the implementation of the policies?

See: Consultation Statement and Duty to Co-Operate Self-Assessment - Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/

Monitoring The SAASP follows the infrastructure table in the CS and as such, the AMR provides the mechanism to








• Does the DPD contain targets, and milestones which relate to the delivery of the policies, (including housing trajectories where the DPD contains housing allocations)?

• Is it clear how targets are to be measured (by when, how and by whom) and are these linked to the production of the annual monitoring report?

• Is it clear how the significant effects identified in the sustainability appraisal report will be taken forward in the ongoing monitoring of the implementation of the plan, through the annual monitoring report?

highlight issues and initiate required responses. See SAASP pp122-127.

The Felixstowe Peninsula AAP has a bespoke Infrastructure Framework which outlines key information required for monitoring the progress of delivery such as indicative phasing, potential sources of funding and the responsible agencies. See: Felixstowe Peninsula AAP See: pp93-98.

Likely timescales for delivery of housing allocations identified in the DPD’s have been included in an Indicative Housing Trajectory 2010-2027. The trajectory is accompanied with a detailed breakdown of delivery.

If through the monitoring process, the Council’s planning policy outcomes are not being delivered, consideration will be given to revising the plan or elements of the plan accordingly through the Local Plan Review.

The latest Authority’s Monitoring Report (AMR) can be viewed at: http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/evidence-base/authority-monitoring-reports/

Significant negative effects identified in the Sustainability Appraisal Report are accompanied with proposed mitigation measures which will be implemented through DPDs area and site policies.

Additional supporting strategies such as the HAGGIS 2015 update and the Recreational Avoidance and Mitigation Strategy (to be prepared for Babergh District Council, Ipswich Borough Council and Suffolk Coastal District Council and adopted by March 2017) will seek to provide improved access to the countryside and other green infrastructure to mitigate pressure on the SPAs.

Consistent with national policy: the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

The DPD should not contradict or ignore national policy. Where there is a departure, there must be clear and convincing reasoning to justify the approach taken.

• Does the DPD contain any policies or proposals which are not consistent with national policy and, if so, is there local justification?

• Does the DPD contain policies that do not add anything to existing national guidance?

The Council is confident that the DPD’s are consistent with national policy and that the plans enable the delivery of sustainable development in accordance with the policies in the NPPF. (See The presumption in favour of sustainable development (NPPF paras 11-16)).

The evidence base for the DPDs is set out in the DPD Submission Document Library and baseline data is also included in the Sustainability Appraisal Reports. These provide a robust and credible evidence





If so, why have these been included? base on which the DPDs have been prepared and demonstrates that the documents are justified. See: Submission Document Library http://www.eastsuffolk.gov.uk/planning/local-plans/suffolk-coastal-district-local-plan/site-allocations-and-area-specific-policies/examination/submission-documents/core-document-library/





Planning policy for traveller sites

Planning Policy for Traveller Sites was published in 23 March 2012 and came into effect on 27 March 2012. Circular 01/06: Planning for Gypsy

and Traveller Caravan Sites and Circular 04/07: Planning for Travelling Showpeople have been cancelled. Planning Policy for Traveller Sites

should be read in conjunction with the National Planning Policy Framework, including the implementation policies of that document.

The government’s aim in relation to planning for traveller sites is:

‘To ensure fair and equal treatment for travellers, in a way that facilitates the traditional and nomadic life of travellers whilst respecting

the interests of the settled community’.

Government’s aims in respect of traveller sites are:

That local planning authorities (LPAs) make their own assessment of need for the purposes of planning

That LPAs work collaboratively, develop fair and effective strategies to meet need through the identification of land for sites

Plan for sites over a reasonable timescale

Plan-making should protect green belt land from inappropriate development

Promote more private traveller site provision whilst recognising that there will always be those travellers who cannot provide their own sites

Aim to reduce the number of unauthorised developments and encampments and make enforcement more effective.

In addition local planning authorities should:

Include fair, realistic and inclusive policies

Increase the number of traveller sites in appropriate locations with planning permission, to address under provision and maintain

an appropriate level of supply

Reduce tensions between settled and traveller communities in plan-making and decision-taking

Enable provision of suitable accommodation from which travellers can access education, health, welfare and employment

infrastructure

Have due regard to protection of local amenity and local environment


Policy Expectations Evidence Provided

Policy A: Using evidence to plan positively and manage development (para 6)

Early and effective community engagement with both settled and traveller communities.

The needs of the traveller community have been assessed through a joint Gypsy, Traveller and Travelling Showpeople Accommodation Assessment (GTAA) commissioned with neighbouring local authorities in 2007 and updated 2013. This has included liaison by the consultants with the traveller community.

The Council is co-operating with all other Suffolk authorities to identify three short stay transit sites across the county to meet the needs of gypsies and travellers. http://www.eastsuffolk.gov.uk/assets/Planning/Waveney-Local-Plan/Suffolk-GTAA-2013.pdf

Co-operate with travellers, their representative bodies and local support groups, other local authorities and relevant interest groups to prepare and maintain an up-to-date understanding of likely permanent and transit accommodation needs of their areas.

As above. In addition, bi-annual caravan counts are carried out by each local authority. Information on unauthorised encampments is monitored on a county wide basis.

Policy B: Planning for traveller sites (paras 7-11)

Set pitch targets for gypsies and travellers and plot targets for travelling showpeople which address the likely permanent and transit site accommodation needs of travellers in your area, working

As a minimum, SCDC is committed to looking to provide the 31 residential pitches identified for this District.

The annual caravan counts and regular updates to the GTAA are considered to be the most reliable

http://www.eastsuffolk.gov.uk/assets/Planning/Waveney-Local-Plan/Suffolk-GTAA-2013.pdf



collaboratively with neighbouring LPAs.

Set criteria to guide land supply allocations where there is identified need.

Ensure that traveller sites are sustainable economically, socially and environmentally.

local guide, and will be used as a key indicator, when monitoring the plan.

For the small number of gypsies identified in the GTAA , it is expected that individual households will approach the Council directly with regard to meeting their needs.

See CS policies SP4 and DM9 -Gypsies, Travellers and Travelling Showpeople

Policy C: Sites in rural areas and the countryside (para 12)

When assessing the suitability of sites in rural or semi-rural settings LPAs should ensure that the scale of such sites do not dominate the nearest settled community.

See: Suffolk Cross-Boundary Gypsy and Traveller Accommodation Assessment 2007 p108 and CS policy DM9-Gypsies, Travellers and Travelling Showpersons.

Policy D: Rural exception sites (para 13)

If there is a lack of affordable land to meet local traveller needs, LPAs in rural areas, where viable and practical, should consider allocating and releasing sites solely for affordable travellers’ sites.

As above.

Policy E: Traveller sites in Green Belt (paras 14-15)

Traveller sites (both permanent and temporary) in the Green Belt are inappropriate development.

Exceptional limited alteration to the defined Green Belt boundary (which might

SCDC has no statutory Green Belt.



be to accommodate a site inset within the Green Belt) to meet a specific, identified need for a traveller site ... should be done only through the plan-making process.

Policy F: Mixed planning use traveller sites (paras 16-18)

Local planning authorities should consider, wherever possible, including traveller sites suitable for mixed residential and business uses, having regard to the safety and amenity of the occupants and neighbouring residents.

CS policy DM9-Gypsies, Travellers and Travelling Showpersons allows for mixed residential and business uses where storage is required in relation to a travelling circus or show.

Policy G: Major development projects (para 19)

Local planning authorities should work with the planning applicant and the affected traveller community to identify a site or sites suitable for relocation of the community if a major development proposal requires the permanent or temporary relocation of a traveller site.

N/A.