EAST BERGHOLT PARISH COUNCIL
DRAFT RESPONSE TO RE -CONSULTATION ON PLANNING APPLICATION DC/22/03043

The Parish Council has been invited to comment further on application DC/22/03043 by BDC
because of a Housing Needs Assessment prepared on behalf of the applicant that had been
received on 31/08/2022.
The Parish Council’s substantive comments on this application which are largely opposed to
both the nature and scale of the development proposed were approved by the Parish Council on
14th July 2022 and submitted to BDC within the 21 day statutory consultation period on 26th
July. These remain the position of the Council and the additional comments set out below
should be read alongside and in addition to our first submission.
Since this first submission, the applicant has made various changes to the proposals. Various
new reports supporting the application and other consultee comments have also been added to
the document library. The consultation period has been a moving feast since mid July and the
latest Housing Needs Report prepared by Pioneer Property Services on behalf of the applicant
is just the latest addition which has apparently required a further consultation period until 21st
September 2022.
The Parish Council wishes to comment on the Housing Need Report and a number of the new
documents that have been submitted since its first submission to BDC in July 2020.

COMMENTS ON THE HOUSING NEEDS REPORT
This report has been prepared on behalf of Langham Property Company, the applicant. It is
referred to by BDC in their reason for re-consultation as a Housing Needs Assessment. This, it
is not. It is a Report that reviews the housing policy context as it applies to East Bergholt, and
the established evidence of need. But it then adopts what it calls an “appropriate” study area for
its modelling. One it refers to as a “functional cluster” which is much larger than the Parish. For
this sub area it models various future housing needs scenarios using a range of demographic
assumptions and by adopting a larger area than the Parish of East Bergholt and applying a
methodology that chooses to pro rata districtwide growth without any justification it arrives at
highly exaggerated housing need figures requiring between 550 and 799 new homes over the
period 2022- 37 in the cluster. This compares to a Neighbourhood Plan requirement for a
minimum of 86 homes (2015-30) in East Bergholt.
The functional cluster approach for assessing housing needs is neither proven nor tested. The
functional cluster construct is based on 2010 data and has never been adopted by Babergh for
this type of analysis. The assumed district growth rates are based on historic patterns of growth
and their validity in today’s low growth recessionary world are not even considered. Taking the
Babergh wide growth patterns and projecting these across the functional area assuming “all
things are equal” is fraught with difficulty and just wrong, and the resulting projections 1a),
1b),1c),2,3 are all based on “rear view mirror” assumptions.
The Parish Council has called upon a highly experienced planning and real estate consultant to
review this report. Their experience of modelling and forecasting was the basis of their 40 year
career. They were in the vanguard of applying forecasting techniques to real estate markets
from the1980’s. They fully understand the technical approach adopted by Pioneer but advise
that the report’s untested and novel methodology coupled with its extreme results cannot in all

seriousness be used to determine East Bergholt’s housing needs nor should Babergh rely on it
in any way for this purpose.
The report also makes frequent reference to the NPPFs requirement for “objectively assessed
need” for determining housing requirements. A technically driven, assumptions based modelled
approach is simply not this. The report also mentions that the East Bergholt Neighbourhood
Plan is now 6 years old. This is fully recognised and as such the PC is seeking to update the
plan. A 2018 Housing Needs Survey for East Bergholt prepared by CAS and funded by Babergh
DC found that East Bergholt’s housing needs were unchanged from 2015. The Parish Council
also engaged in a “call for sites” as part of this NP review in January 2022. The applicant did not
put the site behind the Lion forward for consideration. One can only wonder why not!
In conclusion the Parish Council believes the Housing Needs Report prepared by Pioneer
Property Services provides a thoroughly unreliable basis from which to rewrite the housing
needs for the Parish of East Bergholt. As such It should not be considered as reliable evidence
from which to assess the application in question and so the Parish Council recommends that
Babergh discount this attempt to inflate the housing needs numbers for East Bergholt. The 241
homes already approved and allocated in the JLP are already significantly in excess of
objectively assessed need for the village and whilst the Parish Council has accepted this
allocation it will seriously question the need for more.
A rewriting of the housing needs methodology and numbers based on forward modelling is
perhaps something that might be unpicked at an enquiry but it’s highly unusual to expect
consultees on a planning application to critique such a report. A report of this type will always
beg the question of exactly what brief the consultant had been given. In any event the Parish
Council would in usual circumstances only be expected to comment on the merits of the
application in question based on planning grounds alone (and not the validity of supporting
evidence) which it has already done in some detail. The Parish Council believes its
recommendations to refuse the housing component of this scheme are fully justified and robust
on planning grounds.This report and the reason for re-consultation changes absolutely nothing
in that respect and it is considered important that Babergh District Council also recognises this
fact.

COMMENTS ON ADDITIONAL DOCUMENTS
The Parish Council notes and wishes to highlight various issues for the Case Officer’s
consideration of this application as follows;
– The Environmental Response (18July 2020) made reference to various concerns
regarding the potential for noise, odour, light and smoke pollution arising from the
construction phase of the project, the impact of the Lion’s growing business on the
residents of nearby housing and also potential impacts resulting from the housing
element too. These need to be given serious consideration in assessing the impacts of
the proposal and any conditions that might be applied.
– Suffolk Highways concern regarding the requirement for a segregated footpath for those
requiring to use the public toilets has been incorporated in a recent alteration to the
drawings. However the proposed footpath around the car park boundary to the relocated

and distant public toilets, is in practice very unlikely to encourage people not to take the
obvious straight line route across the car park to the new toilets. There is no obvious
need to relocate the public conveniences. Their proposed new location is simply not
being planned with the users in mind; just the requirement to have it positioned as far
from the Lion as possible and to allow space for the unwarranted housing scheme.
– The Historic England report is broadly to be expected as the organisation had informed
the pre application discussions, however it is of note that it highlights concerns about the
excessive roof heights and scale of the new buildings which do not respect the back land
nature of the plot, are likely to impact on the amenity of nearby residents and which are
contrary to NPPF requirements.
– The Economic Development report highlights concerns over the conflicting requirements
between village use of the car park and the additional demand for car parking spaces as
the Lion grows its customer base. It also points to the impact on amenity of the Lion
business and potential conflict with the proposed housing scheme located cheek by jowl.
– The Design Access and Heritage Statement suggests that the approval of the nearby 10
houses in Hadleigh Road somehow lends weight to the justification for this housing
scheme. This is a totally misleading and incorrect interpretation of the JR ruling. The
Hadleigh Road development was approved contrary to local development plan policies
on the basis of the “tilted balance” and in the absence of a 5 YHLS. This does not apply
today whilst the Development Plan policies do.
– Planning Application DC/22/01688 at the Lion has now been granted approval. This will
allow for the growth of the Lion business and 6x B&B rooms. However Condition 5 of the
approval requires the applicant to have agreed and implemented a parking plan for his
B&B customers with dedicated parking spaces established prior to any B&B use
commencing. This highlights Babergh’s concern about the need for additional parking,
notwithstanding the additional requirements that will stem from further business growth
and residential parking if this application (DC/22/03043) is approved. Unless dedicated
spaces are on the backland behind the Lion it seems difficult to imagine how this
condition will be achieved. Already the car park with 32 spaces operates on an average
day at 75% capacity and the public would be seriously impacted by the loss of any public
spaces to dedicated Lion use. Any overflow onto The Street should clearly be avoided
too.
– The Design document dated 2nd August 2022 referred to 30 Lion staff and owners
associated with the business. Whilst not all will be at work at the same time, this number
highlights the parking pressures that could arise just from staff, let alone guests and
customers. It also further demonstrates why redesigning the car park and making it
smaller makes no sense and why the further parking requirements from 5 additional
homes (10 spaces) for residential use plus extra for visitor use will add further to the
pressure. This all illustrates just one of the many weaknesses in the proposed scheme
as currently conceived; it cannot even be justified on parking grounds.

The Parish Council requests that Babergh District Council takes all these comments into
account when determining planning application DC/22/03043. The opportunity to provide
additional comments in this re-consultation has reinforced East Bergholt Parish Council’s view

that this scheme is in most respects without merit, and largely contrary to planning policy. It
recommends that the housing and car parking components of the scheme should be refused
planning permission and that the Housing Needs Report is not a material consideration in
determining this application.