Aecom 230109 East Bergholt Site Options and Assessment Final Report.pdf

East Bergholt
Neighbourhood Plan
Site Options and Assessment 2022

East Bergholt Parish Council (the ‘Qualifying Body’)

9
th
January 2023

Quality information
Prepared by Checked by Verified by Approved by
Jessica Cooke
Planner
Lauren Ielden
Senior Planner
Yanny Tsang
Senior Planner
Una McGaughrin
Associate Director
Una McGaughrin
Associate Director
Una McGaughrin
Associate Director

Revision History
Revision Revision date Details Authorized Name Position
V1 14/07/2022 Draft Report UM Una
McGaughrin
Associate
Director
– 01/08/2022 Review by East Bergholt Parish Council
V2 04/10/2022 Draft Final
Report
UM Una
McGaughrin
Associate
Director
– 01/11/2022 Review by East Bergholt Parish Council
V3 12/12/2022 Revised Draft
Final Report
UM Una
McGaughrin
Associate
Director
– 04/01/2022 Locality Review
V4 09/01/2022 Final Report UM Una
McGaughrin
Associate
Director

Prepared for:
East Bergholt Parish Council (the ‘Qualifying Body’)

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Disclaimer
This document is intended to aid the preparation of the Neighbourhood Plan and can be used to guide
decision making and as evidence to support Plan policies, if the Qualifying Body (QB) so chooses. It
is not a Neighbourhood Plan policy document. It is a ‘snapshot’ in time and may become superseded
by more recent information. The QB is not bound to accept its conclusions. If landowners or any other East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 2

party can demonstrate that any of the evidence presented herein is inaccurate or out of date, such
evidence can be presented to the Neighbourhood Plan at the consultation stage. Where evidence
from elsewhere conflicts with this report, the QB should decide what policy position to take in the
Neighbourhood Plan and that judgement should be documented so that it can be defended at the
Examination stage.
Table of Contents
Executive Summary ………………………………………………………………. 5
Introduction ………………………………………………………………….. 6
Policy Context ………………………………………………………………. 8
National Planning Policy Framework (Revised in July 2021) ………………………………. 8
Planning Practice Guidance on Renewable and Low Carbon Energy ………………….. 11
‘Saved’ policies of the Babergh Local Plan (June 2006) …………………………………… 12
Adopted Babergh Local Plan: Core Strategy and Policies (February 2014) …………. 13
Draft Babergh and Mid Suffolk Joint Local Plan ………………………………………………. 15
‘Made’ East Bergholt Neighbourhood Plan 2015- 2030 (September 2016) …………… 19
Adopted Suffolk Minerals and Waste Local Plan (July 2020) …………………………….. 20
Methodology ………………………………………………………………. 22
Task 1: Site Identification ……………………………………………………………………………… 22
Task 2: Site Assessment and Review …………………………………………………………….. 22
Task 3: Consolidation of Results …………………………………………………………………… 26
Task 4: Indicative Development Capacity ……………………………………………………….. 26
Site Assessment …………………………………………………………. 27
Conclusions ……………………………………………………………….. 41
Affordable Housing ……………………………………………………………………………………… 42
Next Steps …………………………………………………………………………………………………. 42
Appendix A Site Assessment Proforma
Appendix B SHELAA Review

Figures
Figure 1 East Bergholt Neighbourhood Area ……………………………………………………. 7
Figure 2 All Sites Identified for Assessment ……………………………………………………. 25
Figure 3 Site Assessment Conclusions ………………………………………………………….. 40

Tables
Table 1 Sites identified for assessment ………………………………………………………….. 23
Table 2 AECOM Indicative Housing Density Calculation …………………………………… 26
Table 3 Site Assessment Summary ……………………………………………………………….. 28

East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 3

Abbreviations used in the report
AONB Area of Outstanding Natural Beauty
BDC Babergh District Council
BMSJLP Babergh and Mid Suffolk Joint Local Plan
DLUHC Department for Levelling Up, Housing and Communities
Ha Hectare
NPPF National Planning Policy Framework
SOA Site Options and Assessment
SHELAA Strategic Housing Economic Land Availability Assessment
TPO Tree Preservation Order
East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 4

Executive Summary
This report is an independent assessment of potential development sites for the East
Bergholt Neighbourhood Plan Review. The work undertaken was agreed with East
Bergholt Parish Council (the ‘Qualifying Body’) and the Department for Levelling Up,
Housing and Communities (DLUHC) as part of the national Neighbourhood Planning
Technical Support Programme led by Locality.

The Parish Council intends to allocate sites for housing (including market and
affordable) and other uses beyond residential, that support the growth of East
Bergholt, and are likely to include renewable energy and recreational uses.

A total of thirteen sites in East Bergholt have been identified for assessment through
the neighbourhood- scale ‘Call for Sites’ from November 2021 to January 2022 and
the Babergh and Mid Suffolk Joint Local Plan Strategic Housing and Economic Land
Availability Assessment (SHELAA).

The assessment has found that of the thirteen sites considered, three sites (SS0181,
SS0182 and SS1197) already have planning permission for residential development
and would not need to be allocated in the Neighbourhood Plan Review, although
support for development at these locations could be demonstrated through an
allocation.

One site, EB01 White Horse Farm, is considered potentially suitable for market or
affordable housing, and therefore appropriate for allocation in the Neighbourhood
Plan with an indicative capacity of 16 dwellings. There should be evidence that the
site is available and viable for the proposed development if selected for allocation.
EB01 is also found to be potentially suitable for small-scale solar farm development,
if it is demonstrated to be available for this use and subject to further investigation.

The remaining nine sites (EB02, EB03, EB04, SS0180, SS0183, SS0239, SS0432,
SS0829 and SS1182) were found to be unsuitable for residential or solar energy
generation development and t herefore not appropriate for allocation in the plan.

Three of these nine sites (EB02, EB03 and SS0180) are potentially suitable for
recreation use subject to further consultation with the landowners, Babergh District
Council and Sports England.

The assessment of sites for renewable energy use in this report has been limited to
solar energy generation and has not considered other uses (e.g. wind turbines ).
Sites assessed as unsuitable for solar farms may be suitable for other forms of
renewable energy generation, such as active solar technology (photovoltaic and
solar water heating) on or related to buildings.

This site assessment is the first step in the process of making site allocations. It is
recommended that the next step would be for the Parish Council to engage with
Babergh District Council, the community and landowners to select sites for allocation
in the Neighbourhood Plan Review that best meet the objectives of the
Neighbourhood Plan and the development needs of the area. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 5

Introduction
1.1 This report is an independent assessment of potential development sites for the
East Bergholt Neighbourhood Plan Review on behalf of East Bergholt Parish
Council (the ‘Qualifying Body’). The work undertaken was agreed with the
Parish Council and the Department for Levelling Up, Housing and Communities
(DLUHC) as part of the national Neighbourhood Planning Technical Support
Programme led by Locality. Figure 1 provides a map of the designated East
Bergholt Neighbourhood Area, which covers the whole Parish.
1.2 East Bergholt is situated in rural South Suffolk overlooking the Stour Valley and
Dedham Vale, an Area of Outstanding Natural Beauty. It is rich in heritage
assets with tracts of land owned by the National Trust and parts are protected
by a Conservation Area designation. The village contains 89 listed buildings (5
Grade I, 7 Grade II* and 77 Grade II) and a Scheduled Ancient Monument.
1.3 The A12 is located to the north of the Parish and provides links to Ipswich to the
north and Colchester to the south. The closest train station is Manningtree
which provides regular links to Ipswich, Norwich, Harwich and London. The
village is served by some bus routes providing relatively infrequent services to
Colchester and Ipswich.
1.4 The East Bergholt Neighbourhood Development Plan was first made in
September 2016. The Parish Council is currently updating the Neighbourhood
Plan and has conducted a Call for Sites from November 2021 to January 2022
to encourage local communities and landowners in putting forward sites for
potential allocation through the Neighbourhood Plan Review.
1.5 A minimum housing requirement of 241 dwellings is proposed for the East
Bergholt Neighbourhood Area in the draft Babergh and Mid Suffolk Joint Local
Plan
1
. This draft housing requirement has already been met as of August 2022
through outstanding planning permissions.
1.6 The Parish Council intends to allocate land for market and/or affordable
housing and is exploring other uses including renewable energy (a solar farm)
on sites that accord with the strategic policies of the Local Plan and the
objectives of the Neighbourhood Plan. It also seeks to identify potential
opportunities for recreational space.
1.7 The purpose of this S ite Options and Assessment (SOA) report is to produce a
clear and evidence- based assessment as to whether the sites submitted
through the Call for Sites are appropriate for allocation for their proposed uses
in the emerging Neighbourhood Plan Review. It also includes a review of sites
identified through the Babergh and Mid Suffolk Joint Local Plan Strategic
Housing and Economic Land Availability Assessment (SHELAA) as these
should also be included for consideration as potential neighbourhood plan
allocations. This assessment does not consider whether the sites are suitable
for designation as Local Green Spaces.
1.8 It is important that the site assessment process is carried out in a transparent,
fair, robust and defensible way and that the same process is applied to each
1
Note that the relevant P olicy SP04 is currently proposed for deletion from the draft Babergh and Mid Suffolk Joint Local Plan East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 6

potential site. Equally important is the way in which the work is recorded and
communicated to interested parties.
1.9 This assessment in itself does not allocate sites for development. It is the
responsibility of East Bergholt Parish Council to decide, guided by this report
and other relevant available information, whether to allocate sites and if so,
which sites to select to best address local needs and Neighbourhood Plan
objectives.
Figure 1 East Bergholt Neighbourhood Area (Source: Babergh District Council)
2

2
Available at https://www.babe rgh.gov.uk/assets/Neighbourhood- Planning/East-Bergholt-NP-Map.pdf East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 7

Policy Context
2.1 All Neighbourhood Development Plan policies, including allocations, must be in
general conformity with the strategic policies of the adopted Local Plan and
should have regard to emerging Local Plan policies. A number of sources have
been reviewed in order to understand the context for potential site allocations.
This includes national policies, local policies and relevant evidence base
documents.

2.2 National policy is set out in the National Planning Policy Framework (Revised in
July 2021) and is supported by the Planning Practice Guidance (PPG). The
NPPF is a high- level document which sets the overall framework for the more
detailed policies contained in Local and Neighbourhood Plans.
2.3 The statutory local plan- making authority is Babergh District Council. At the
local level, the relevant development plan documents for East Bergholt include:
• The ‘saved’ policies of the Babergh Local Plan (2006)
3
;
• The adopted Babergh Local Plan Core Strategy & Policies (2014)
4
;
• The emerging Babergh and Mid Suffolk Joint Local Plan (BMSJLP)
5
;;
• The ‘made’ East Bergholt Neighbourhood Development Plan (2016)
6
;
and,
• The adopted Suffolk Minerals & Waste Local Plan (July 2020)
7

2.4 A number of supporting evidence base documents have also been reviewed in
order to understand the context for potential site allocations, including the
Babergh and Mid Suffolk Joint Local Strategic Housing and Economic Land
Availability Assessment (SHELAA) (October 2020)
8
, the Babergh and Mid
Suffolk District Council Landscape Sensitivity Assessment (September 2020)
9
,
the East Bergholt Landscape Sensitivity and Capacity Appraisal (July 2015)
10
,
the Historic Landscape Study of East Bergholt and Cultural Legacy of John
Constable (November 2020), and Sports England’s Planning for Sport
Guidance (June 2019)
11
.
National Planning Policy Framework (Revised in
July 2021 )
2.5 The National Planning Policy Framework (NPPF)
12
sets out the Government’s
planning policies and how these should be applied. It provides a framework
3
Available at https://www.babergh.gov.uk/planning/planning-policy/adopted- documents/babergh- district-council/saved- policies/
4
Available at https://www.midsuffolk.gov.uk/planning/planning- policy/adopted- documents/babergh- district-council/core- strategy/
5
Available at https://www.midsuffolk.gov.uk/planning/planning- policy/new- joint-local-plan/
6
Available at https://www.midsuffolk.gov.uk/assets/Neighbourhood- Planning/East-Bergholt-NP-July16.pdf
7
Available at https://www.suffolk.gov.uk/planning- wa ste-and-environment/minerals-and-waste-policy/suffolk-minerals-and-
waste-development-scheme/
8
Available at https ://www.babergh.gov.uk/assets/Strategic-P lanning/JLPExamination/CoreDocLibrary/E-
EvidenceBase/Housing- EH/EH06-BMSDC-Joint-SHELAA- Report-Oct-2020.pdf
9
Available at https://www.midsuffolk.gov.uk/planning/planning- poli cy/evidence- base/current-evidence/landscape- sensitivity-
assessment/
10
Available at https://www.babergh.gov.uk/assets/Neighbourhood-Planning/East -Bergholt-NP-D8D14.pdf
11
Available at https://sportengland- produc tion-files.s3.eu- west-2.amazonaws.com/s3fs-public/2020- 01/planning- for-sport-
guidance.pdf?VersionId=V91Twg6jajoe7TpardJDn9h6s9AiSqw0
12
Available at https://www.gov.uk/government/publications/national -planning- policy-framework–2 East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 8

within which locally prepared plans for housing and other development can be
produced.
2.6 Paragraph 8 outlines that achieving sustainable development means that the
planning system has three overarching objectives, which are interdependent
and need to be pursued in mutually supportive ways, so that opportunities can
be taken to secure net gains across the economic, social and environmental
objectives.
2.7 Paragraph 10 states that there is a presumption in favour of sustainable
development.
2.8 Paragraph 13 states that Neighbourhood Plans should support the delivery of
strategic policies contained in local plans or spatial development strategies; and
should shape and direct development that is outside of these strategic policies.
2.9 Paragraph 60 emphasises that to support the Government’s objective of
significantly boosting the supply of homes, it is important that a sufficient
amount and variety of land can come forward where it is needed, that the
needs of groups with specific housing requirements are addressed and that
land with permission is developed without unnecessary delay.
2.10 Paragraph 62 states that the size, type and tenure of housing needed for
different groups in the community should be assessed and reflected in planning
policies.
2.11 Paragraph 65 notes that where major development involving the provision of
housing is proposed, planning policies and decisions should expect at least
10% of the homes to be available for affordable home ownership, unless this
would exceed the level of affordable housing required in the area, or
significantly prejudice the ability to meet the identified affordable housing needs
of specific groups.
2.12 Paragraph 70 states that neighbourhood planning groups should give
particular consideration to the opportunities for allocating small and medium-
sized sites (up to 1 H a, consistent with paragraph 69 a) suitable for housing in
their area.
2.13 Paragraph 78 states that in rural areas, planning policies should be responsive
to local circumstances and support housing developments that reflect local
needs. Local planning authorities should support opportunities to bring forward
rural exception sites that will provide affordable housing to meet identified local
needs, and consider whether allowing some market housing on these sites
would help to facilitate this.
2.14 Paragraph 80 highlights the need to avoid the development of isolated homes
in the countryside.
2.15 Paragraph 98 highlights the importance of access to a network of high quality
open spaces and opportunities for sport and physical activity for the health and
well-being of communities, the nature and in addressing climate change.
Planning policies should be based on robust and up- to-date assessments for
need for open space, sport and recreation facilities (including quantitative or
qualitative deficits or surpluses) and opportunities for new provision. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 9

2.16 Paragraph 119 notes that planning policies and decisions should promote an
effective use of land in meeting the need for homes and other uses, while
safeguarding and improving the environment and ensuring safe and healthy
living conditions.
2.17 Paragraph 159 states that inappropriate development in areas at risk of
flooding should be avoided by directing development away from areas at
highest risk. Where development is necessary in such areas, it should be made
safe for its lifetime without increasing flood risk elsewhere.
2.18 Paragraph 161 sets out that plans should apply a sequential, risk-based
approach to the location of development in order to avoid flood risk to people
and property. Paragraph 158 explains that the purpose of the sequential test is
to steer development to areas with the lowest risk of flooding, and that
development should not be allocated or permitted if there are reasonably
available sites for the proposed development in areas with a lower risk of
flooding.
2.19 Paragraph 163 states that where it is not possible to locate development in
zones at lower risk of flooding, the exception test may have to be applied,
according to the potential vulnerability of the site and the nature of the
proposed development. The exception test is set out in Paragraph 164, which
states that it should be demonstrated that the development would provide wider
sustainability benefits that outweigh the flood risk, and that the development
would be safe for its lifetime, without risking flood risk elsewhere, and where
possible reducing overall flood risk.
2.20 Paragraph 175 states that plans should allocate land with the least
environmental or amenity value, where consistent with other policies in the
NPPF. Footnote 58 suggests that where significant development of agricultural
land is demonstrated to be necessary, areas of poorer quality land should be
preferred to those of a high quality.
2.21 Paragraph 176 outlines that great weight should be given to conserving and
enhancing landscape and scientific beauty in Areas of Outstanding Natural
Beauty. Paragraph 177 states that when considering applications for
development within AONBs permission should be refused for major
development
13
other than in exceptional circumstances, and where it can be
demonstrated that the development is in the public interest.
2.22 Paragraph 199 states that when considering the impact of a proposed
development on the significance of a designated heritage asset, great weight
should be given to the asset’s conservation. Paragraph 201 goes on to
emphasises that where a proposed development will lead to substantial harm to
(or total loss of significance of) a designated heritage asset, local planning
authorities should refuse consent, unless it can be demonstrated that the
substantial harm or total loss is necessary to achieve substantial public benefits
that outweigh that harm or loss.
13
Footnote 60 of the NPPF clarifies that for the purpose of paragraphs 176 and 177, whether a proposal is ‘major development’
is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant
adverse impact on the purposes for which they area has been designated and defined. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 10

Planning Practice Guidance on Renewable and Low
Carbon Energy
2.23 The Planning Practice Guidance identifies key planning considerations for
renewable and low carbon energy development (published June 2015)
14
. Local
planning authorities are responsible for renewable and low carbon energy
development of 50 megawatts or less installed capacity, under the Town and
Country Planning Act 1990.
2.24 Paragraph 004 states that neighbourhood plans are an opportunity for
communities to plan for community led renewable energy developments .
Neighbourhood Development Orders and Community Right to Build O rders can
be used to grant planning permissions for renewable energy development. As
part of a neighbourhood plan, communities can also look at developing a
community energy plan to underpin the neighbourhood plan.
2.25 Paragraph 005 sets out some of the key factors for identifying suitable areas
for renewable and low carbon energy, including the requirements of the
technology, the potential impacts (including cumulative impacts) on the local
environment and the views of local communities likely to be affected.
2.26 Paragraph 006 provides examples of the technical considerations relating to
renewable energy technologies that can affect their sitting including proximity of
grid connection infrastructure and site size.
2.27 Paragraph 007 sets out the key considerations for criteria-based policy for
renewable energy in planning, particularly:
• The need for renewable or low carbon energy does not automatically
override environmental protections;
• Cumulative impacts require particular attention, especially the increasing
impact that wind turbines and large scale solar farms can have on
landscape and local amenity as the number of turbines and solar arrays in
an area increases;
• Local topography is an important factor in assessing whether wind
turbines and large scale solar farms could have a damaging effect on
landscape and recognise that the impact can be as great in predominantly
flat landscapes as in hilly or mountainous areas;
• Great care should be taken to ensure heritage assets are conserved in a
manner appropriate to their significance, including the impact of proposals
on views important to their setting;
• Proposals in National Parks and Areas of Outstanding Natural Beauty,
and in areas close to them where there could be an adverse impact on
the protected area, will need careful consideration; and,
• Protecting local amenity is an important consideration which should be
given proper weight in planning decisions.
14
Available at https://www.gov.uk/guidance/renewable- and-low-carbon- energy East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 11

2.28 Paragraph 013 outlines the particular planning cons iderations that relate to
large scale ground- mounted solar photovoltaic farms
15
, including:
• Encouraging the effective use of land by focusing large scale solar farms
on previously developed land and non- agricultural land, provided that it is
not of high environmental value;
• Where a proposal involves greenfield land, whether (i) the proposed use
of any agricultural land has been shown to be necessary and poorer
quality land has been used in preference to higher quality land; and (ii) the
proposal allows for continued agricultural use where applicable and/or
encourages biodiversity improvements around arrays;
• That solar farms are normally temporary features and planning conditions
can be used to ensure that the installations are removed where no longer
in use and the land is restored to its previous use;
• The proposal’s visual impact, the effect on of landscape of glint and glare
and on neighbouring uses and aircraft safety;
• The extent to which there may be additional impacts if solar arrays follow
the daily movement of the sun;
• The need for, and impact of security measures such as lights and fencing;
• Great care should be taken to ensure heritage assets are conserved in a
manner appropriate to their significance, including the impact of proposals
on views important to their setting. As the significance of a heritage asset
derives not only from its physical presence, but also from its setting,
careful consideration should be given to the impact of large scale solar
farms on such assets. Depending on their scale, design and prominence,
a large scale solar farm within the setting of a heritage asset may cause
substantial harm to the significance of the asset;
• The potential to mitigate landscape and visual impacts through, for
example, screening with native hedges;
• The energy generating potential, which can vary for a number of reasons
including, latitude and aspect.
‘Saved’ policies of the Babergh Local Plan (June
2006)
2.29 The Babergh Local Plan Alteration No.2 was adopted by Babergh District
Council in June 2006 with some of its policies ‘saved’ by the Secretary of State
in 2009. It sets out the detailed planning policies and proposals for the District.
The majority of policies contained in the Babergh Local Plan 2006 have been
superseded due to changes in planning regulation and the adoption of the
Babergh Local Plan: Core Strategy and Policies in 2014. The relevant live
‘saved’ policies include:
2.30 Policy HS28 states that development proposals for infilling or groups of
dwellings will be refused where the site’s undeveloped nature is an important
15
Note that the key considerations are different to active solar technology (photovoltaic and solar water heating) on or related to
a particular building, which is often permitted development provided that the installation is not of an unusual design, or does not
involve a listed building, and is not in a designated area as set out in the Paragraph 012 of the relevant Planning Practice
Guidance. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 12

feature in visual or environmental terms; the proposal represents
overdevelopment to the detriment of the environment, the character of the
locality, residential amenity and highway safety; the layout provides an
unreasonable standard of privacy, garden size or public open space; and the
proposal is of a scale, density or form which would be out of keeping with
adjacent and nearby dwellings or other buildings.
2.31 Policy CR02 safeguards the landscape of Dedham Vale and the Suffolk Coast
and Heaths Areas of Outstanding Natural Beauty.
2.32 Policy CR19 states that proposals for conversions of barns or other redundant
or under-used buildings the countryside into dwellings or housing
accommodation will only be permitted if it can be demonstrated that the
alternative uses for business, community and leisure uses have been
thoroughly explored and can be discounted.
2.33 Policy CN08 requires development proposals within or have an impact on
views into or out of a Conservation Area to preserve or enhance the character
of the Conservation Area and its setting; retain all elements of components,
including spaces, which contribute to the special character of the area; be of an
appropriate scale, form and detailed design to harmonise with its setting;
include fenestration which respects its setting; use materials and components
that complement or harmonise with the character and appearance of the area;
and ensure that natural features such as trees and hedges are retained and
integrated into any development proposals.
Adopted Babergh Local Plan: Core Strategy and
Policies (February 2014)
2.34 The Babergh Local Plan: Core Strategy and Policies was adopted in February
2014. The document sets out the vision for the area to 2013 and aims to
provide certainty for local people, developers and others about planning
decisions for the area. The relevant policies include:
2.35 Policy CS1 Applying the Presumption in Favour of Sustainable
Development in Babergh recognises that, when considering development
proposals, the Council will take a positive approach that reflects the
presumption in favour of sustainable development contained in the National
Planning Policy framework.
2.36 Policy CS2 Settlement Pattern Policy sets out the development strategy for
Babergh to 2031. Most new development (including employment , housing and
retail) in Babergh will be directed sequentially to the towns/urban areas, and to
the Core Villages and Hinterland Villages. East Bergholt is classified as a ‘Core
Village’. East End is not identified as a settlement in the adopted Core Strategy.
2.37 Policy CS2 also states that in all cases the scale and location of development
will depend upon the local housing need, the role of settlements as employment
providers and retail/service centres, the capacity of existing physical and social
infrastructure to meet forecast demands and the provision of new / enhanced
infrastructure, as well as having regard to environmental constraints and the
views of local communities as expressed in neighbourhood plans. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 13

2.38 Policy CS3 Strategy for Growth and Development stipulates that
employment and housing growth will be accommodated within Babergh’s
existing settlement pattern and in new mixed and balanced communities on the
edges of towns and the Babergh Ipswich fringe. Babergh District Council will
make provision for 5,975 new dwellings between 2011 and 2031 in the District.
These dwellings are planned as follows: 1,100 between 2011 – 2016; and 4,875
between 2017- 2031. The housing target will be achieved by:
• Existing commitments as identified in the trajectory;
• Allowing for a windfall figure of 1,640 dwellings;
• Making provision for 2,500 new dwellings to be built in the following
locations:
─ Sudbury and Great Cornard – 850 dwellings
─ Hadleigh – 250 dwellings
─ Ipswich Fringe – 350 dwellings
─ Core & H interland Villages – 1,050 dwellings.
2.39 Policy CS11 Strategy for Development for Core and Hinterland Villages
states that proposals for development for Core Villages will be approved where
proposals score positively when assessed against Policy CS15 and the
following matters are addressed to the satisfaction of the local planning
authority where relevant and appropriate to the scale and location of the
proposal:
• The landscape, environmental and heritage characteristics of the village;
• The locational context of the village and the proposed development
(particularly the AONBs, Conservation Areas, and heritage assets);
• Site location and sequential approach to site selection;
• Locally identified need – housing and employment, and specific local
needs such as affordable housing;
• Locally identified community needs; and
• Cumulative impact of development in the area in respect of social,
physical and environmental impacts.
2.40 Policy CS11 also encourages new retail, leisure and community uses
appropriate in scale and character to the role, function and appearance to their
location in Core and Hinterland Villages, subject to other policies in the Core
Strategy.
2.41 Policy CS15 Implementing Sustainable Development in Babergh notes that
proposals for development must respect the local context and character of the
different parts of the district, and where relevant should demonstrate how the
proposal addresses the key issues and contributes to meeting the objectives of
the Local Plan.
2.42 Policy CS20 Rural Exception Sites states that the Council take a flexible
approach to the location of rural exception sites in the district, and will allow
proposals adjacent, or well related, to the settlement development boundaries
of Core and Hinterland Villages where: East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 14

• The development complies with other relevant policies in the Core
Strategy and Policies document, particularly Policy CS15;
• The proposed development by virtue of its size, scale and type will not
exceed the identified local need (including need identified in other
settlements within the same or adjacent / adjoining functional cluster(s);
• The type of dwellings to be provided are consistent with the needs
identified by the housing needs survey and agreed in advance by the
District Council and where; and,
• The proposed development is appropriate to the size / scale and
character of the village, and is acceptable in terms of other detailed
considerations such as site location and circumstances, design, layout,
materials, landscaping, biodiversity, impacts on the countryside, amenity
and access, etc.
2.43 The supporting note for Policy CS20 states that the following criteria will be
used to assess whether a proposal is well related to the host village:
• Physical distance / degree of separation – a sequential approach to site
selection will be used (that is, sites adjacent to the boundary need to be
explored first, with sites at increasing distance being sequentially less
preferable in principle);
• The location of the site in relation to the facilities, services and other
sustainability assets (such as recreation provision, employment
opportunities) of that village
• Accessibility to the village (primarily by non -car transport modes) and
ability to improve it; and
• Visual impacts and ability to integrate the development into the landscape.
Draft Babergh and Mid Suffolk Joint Local Plan
2.44 The Babergh and Mid Suffolk Joint Local Plan provides the strategy for
development in Babergh and Mid Suffolk up to 2037. It was submitted to the
Secretary of State for independent examination in March 2021.
2.45 Draft Policy SP01 Housing Needs states that the Joint Local Plan will seek to
deliver a minimum of 7,904 net additional dwellings (416 dwellings per annum)
within the Babergh district over the plan period (2018- 2037).
2.46 Draft Policy SP03 Settlement Hierarchy (proposed for significant
modification to make clear where new housing development will be
permitted) defines the role of settlements within the District. Draft Policy SP03
states that in all cases the scale and location of development will depend upon
the role of settlements within the settlement hierarchy defined in the policy table
and the spatial distribution, the capacity of existing physical and social
infrastructure or new/enhanced infrastructure, as well as having regard to the
built and natural environment. Development which would lead to visual or
physical coalescence of settlements will not be supported. East Bergholt is
classified as a ‘Babergh Core Village’ while the East End of East Bergholt is
identified as a ‘Babergh Hinterland Village’. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 15

2.47 Draft Policy SP04 Housing Spatial Distribution (proposed for deletion)
states that from April 2018 to March 2037, the broad distribution of new
additional housing provision will equate to 2,699 total new homes within the
Babergh Core Villages. The East Bergholt Neighbourhood Area is required to
deliver a minimum of 241 homes (including Outstanding Planning Permissions).
2.48 Draft Policy LP01 W indfall Development in Hamlets and Dwellings
Clusters (proposed for significant modification to make clear where new
housing development will be permitted) confirms that proposals for windfall
development within dwelling clusters and/or a defined hamlet may be
acceptable, subject to the following criteria:
• It would not be detrimental to the character and appearance of the
settlement, landscape (including the AONB), residential amenity or any
heritage, environmental or community assets.
• It would not result in consolidating sporadic or ribbon development or
result in loss of gaps between settlements resulting in coalescence. The
cumulative impact of the proposal on the location, context and
infrastructure is considered acceptable.
• The scale of development is infill only for a single dwelling and or pair of
semi-detached dwellings.
• Special regard shall be given to development proposals preserving and
enhancing the AONB and to protecting and enhancing biodiversity and
geodiversity affected by the proposal.
• All new development will be expected to minimise dependence on fossil
fuels and make the fullest contribution to the mitigation of climate change
through implementation of sustainable construction practices and
renewable energy technologies.
2.49 Draft Policy LP08 Affordable, Community Led and Rural Exception
Housing states that up to 35% of market housing on rural exception sites will
be supported, only where it is finan cially necessary in order to secure and
deliver additional local affordable housing. A financial appraisal must be
submitted to evidence the need for open market housing to cross-subsidise
affordable housing on the rural exception site.
2.50 Draft Policy LP17 Environmental Protection seeks to prioritise development
on previously developed land, where appropriate, to minimise the loss of the
best and most versatile agricultural land. Where development needs to take
place on greenfield land, avoidance of the best and most versatile agriculture
land should be prioritised.
2.51 Draft Policy LP18 Biodiversity and Geodiversity requires all development to
follow a hierarchy of seeking firstly to enhance habitats, avoid impacts, mitigate
against harmful impacts, or as a last resort compensate for losses that cannot
be avoided or mitigated for. In particular, development should:
• Protect designated land. Proposed development which is likely to have an
adverse impact upon designated and potential designated sites, or that
will result in the loss or deterioration of irreplaceable biodiversity or
geological features or habitats (such as ancient woodland and
veteran/ancient trees) will not be supported. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 16

• Protect and improve sites of geological value and in particular geological
sites of international, national and local significance
• Conserve, restore and contribute to the enhancement of biodiversity and
geological conservation interests including priority habitats and species.
• Plan positively for the creation, protection, enhancement and
management of local networks of biodiversity with wildlife corridors that
connect areas.
• Identify and pursue opportunities for securing measurable net gains,
equivalent of a minimum 10% increase, for biodiversity.
• Apply additional measures to assist with the recovery of species listed on
S41 of the NERC Act 2006
2.52 Draft Policy LP19 Landscape seeks to protect and enhance the landscape
character of Babergh and Mid Suffolk. Development must:
• Integrate positively with the existing landscape character of the area and
reinforce the local distinctiveness and identity of individual settlements
• Proposals must be sensitive to their landscape and visual amenity
impacts (including on dark skies and tranquil areas); subject to siting,
design, lighting, use of materials and colour, along with the associated
mitigation measures
• Enhance and protect landscape character and values and heritage assets
• Consider the topographical cumulative impact on landscape sensitivity
2.53 Draft Policy LP20 Area of Outstanding Natural Beauty supports
development in or near the AONBs that conserves and enhances the
landscape and scenic beauty. Development proposals are required to integrate
positively with the character of the area and reinforces local distinctiveness of
the AONB; be sensitive to their landscape and visual impacts (including on dark
skies and tranquil areas) subject to siting, design, lighting, use of materials and
colours, along with associated mitigation measures; support the provision and
maintenance of local services and facilities and assets (including affordable
housing) so long as it is commensurate with the character and objectives of the
AONB; and, demonstrate special regard to proposals that enhance and protect
landscape character and values and heritage assets in the AONB such as
locally characteristic landscape features, archaeological and historic patterns of
settlement and land use and designations.
2.54 Draft Policy LP27 Energy Sources, Storage and Distribution supports
renewable, decentralised and community energy generating proposals subject
to:
• The impact on (but not limited to) landscape, highway safety, ecology,
heritage, residential amenity, drainage, airfield safeguarding and the local
community has been fully taken into consideration and where appropriate,
effectively mitigated
• Where renewable energy infrastructure is to be incorporated within a
development, an integrated approach is taken, using technology that is
suitable for the location and designed to maximise operational efficiency
without comprising amenity; East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 17

• The impact of on and off-site power generation infrastructure (for example
over-head wires, cable runs, invertors, control buildings, security fencing
and highway access points), is acceptable to the Local Planning Authority;
• The provision of mitigation, enhancement and compensation measures
when necessary; and,
• Approval of connection rights, and capacity in the UK power network, to
be demonstrated as part of the planning applications (where applicable).
2.55 Draft Policy LP27 also states where proposals for renewable and low carbon
energy are located in nature conservation sites, the Area of Outstanding
Natural Beauty, or impact on the setting of heritage asset (including
Conservation Areas), and any other designated sites (include but not exclusive
to SSSI, SAC, SPA, National Nature Reserves, Ramsar Sites and Local Nature
Reserves), the applicant must be able to demonstrate to the satisfaction of the
Local Planning Authority that potential harm resultant from development can be
effectively mitigated and that there are no alternative sites available within the
District. This includes providing underground power lines and cabling.
2.56 Draft Policy LP30 Designated Open Spaces states that development in
excess of 1 hectare will be required to provide on- stie open space provision to
meet identified needs/deficits unless there is a Council preference to make
improvements to existing open space within the locally in an equally or more
accessible location than the proposed development.
2.57 Draft Policy LP31 Services and Facilities within the Community supports
proposals for new community services and facilities or improving existing
facilities where they are well related to and meets the needs of the local
community, and would reduce the need to travel to other settlements. The
facility should be a proportionate scale to the settlement and would not
adversely affect existing facilities. Development should be of a high- quality and
sympathetic to the surrounding landscape and townscape, with no adverse
effects on heritage assets and their settings.
2.58 Part 3 of the Babergh and Mid Suffolk Joint Local Plan (proposed for
deletion) sets out the relevant BDC Place Maps and Policies. Three sites have
been allocated for a total of 229 dwellings within the Neighbourhood Area,
including:
• LA059: Land West of Hadleigh Road, East Bergholt (0.85ha site area) –
10 dwellings;
• LA060: Land North West of Moores Lane (9.0ha site area) – 144
dwellings; and
• LA061: Land South of Heath Road (9.0ha site area) – 75 dwellings.
2.59 In December 2021, correspondence between the Babergh and Mid Suffolk
District Councils and the Inspectors (document G09 and G10) indicate that the
emerging Local Plan will be divided into two parts, in which the existing housing
allocation policies would be deleted from the emerging Local Plan with the
settlement boundaries in the adopted (as opposed to proposed) policies map to
be retained (among other modifications including a review of the settlement
hierarchy). These elements are considered to be unsound at present and would
require further review upon up- to-date and robust evidence base. They would East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 18

be considered in the preparation and adoption of a ‘Part 2’ Local Plan which is
expected to start as soon as possible after the adoption of ‘Part 1’ of the
emerging Local Plan. A Local Development Scheme is currently being prepared
to reflect this change. As of April 2022, it is anticipated that the main
modifications for Part 1 of the Local Plan will be consulted in Autumn 2022.
‘Made’ East Bergholt Neighbourhood Plan 2015-2030
(September 2016)
2.60 The ‘made’ East Bergholt Neighbourhood Plan forms part of the development
plan framework for Babergh and guides planning decisions in East Bergholt up
to 2030.
2.61 Policy EB1 Housing Numbers requires a minimum of 86 new homes to be
developed in East Bergholt during the plan period of 2015 to 2030.
2.62 Policy EB2 Development Size and Location supports housing development
within or immediately adjacent to the village built up boundaries provided that
the development:
• Would not have an unacceptable adverse impact on the Dedham Vale
Area of Outstanding Natural Beauty, Local Green Spaces or sites of
biodiversity and geodiversity importance;
• Conserves, enhances and respects the Conservation Area, heritage
assets and built character of the local area, respecting the density,
rhythm, pattern, proportions and height of existing development in the
street scene;
• Would not have an unacceptable adverse impact on the local highway
network;
• Would be of an acceptable size and scale that contributes to the character
and the ‘sense of place’; and
• Is within 800 metres of the Village Heart or Focal Points.
2.63 Policy EB2 also states that housing development outside of the built up area or
800 metres zone will be supported where they satisfy the special circumstances
set out in the National Planning Policy Framework. Rural exception affordable
housing will be encouraged on sites adjacent to or well related to the built up
area boundaries.
2.64 In addition, Policy EB2 prefers housing development of 15 homes that is well
designed and integrated into the village. Developments of 15 or more dwellings
will be supported where they deliver exceptional benefits to meet the housing
needs of the community including affordable and low cost market housing
suitable for newly forming households, young families and homes for older
people.
2.65 Policy EB3 Village Heart supports small scale infill housing development that
does not harm the historic environment within the village heart. Development,
including backland development, on large gardens that adversely affects the
character of the Conservation Area and setting of listed buildings will not be
supported. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 19

2.66 Policy EB5 Increasing the choice of housing options for older people
supports small scale infill development of older people’s housing within 400
metres of St Mary’s Church where they provide homes with easy access to the
facilities in the Village Heart.
2.67 Policy EB6 Landscape and Views requires development proposals to
demonstrate that they comply with the policies and guidance relating to the
Dedham Vale AONB and its setting. They should take full account of the
capacity assessment set out the Landscape Sensitivity and Capacity
Assessment and would not have an unacceptable adverse impact on the
landscape setting of the village demonstrated through a Landscape and Visual
Impact Assessment.
2.68 Policy EB7 Local Green Space seeks to protect the identified Local Green
Space.
2.69 Policy EB8 Biodiversity requires development proposals to protect and
enhance biodiversity and geodiversity.
2.70 Policy EB17 Agricultural Land seeks to avoid the loss of best and most
versatile agricultural land.
2.71 Policy EB18 New Development and Farm Vehicle requires new development
to have due regard to access routes or roads around East Bergholt that are
used by farmers to move their agricultural machinery and access fields while
maintaining and enhancing existing hedgerows and trees.
2.72 Policy EB19 Conversion of Agricultural Buildings supports the reuse of
redundant agricultural buildings of 15 or more year old.
Adopted Suffolk Minerals and Waste Local Plan
(July 2020)
2.73 The Suffolk Minerals and Waste Local Plan guides planning decisions for
minerals and waste development and safeguards the same from other forms of
competing development in Suffolk.
2.74 Policy MP10 Minerals Consultation and Safeguarding Areas stipulates that
the County Council will safeguard a) those Minerals Safeguarding Areas
located within the Minerals Consultation Areas identified on the Proposals Map
from proposed development in excess of 5ha, and b), areas falling within 250m
of an existing, planned or potential site allocated in the Plan for sand and gravel
extraction. The County Council will in principle object to such development
when consulted by the Local Planning Authority unless it can be shown that the
sand and gravel present is not of economic value, or not practically or
environmentally feasible to extract, or that the mineral will be worked before the
development. The whole parish of East Bergholt falls within the Minerals
Consultation Area defined in the Proposals Map
16
.
2.75 Policy WP18 Safeguarding of Waste Management Facilities seeks to
safeguard existing sites and sites proposed for waste management use.
16
Available at: https://www.suffolk.gov.uk/assets/planning- was te-and-environment/Minerals-and-
Waste-Policy/Minerals-and-Waste-SMWLP- Adopted/Minerals-and-Waste-Safeguarding- and-
Proposals-Map-reduced.pdf East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 20

Development proposals in close proximity to existing sites should demonstrate
that they would not prejudice or be prejudiced by a waste management facility.
Within the Neighbourhood Area, a water recycling centre is located in East
Bergholt (AW53 East Bergholt Stw). East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 21

Methodology
3.1 The approach to site assessment is based on the Government’s Planning
Practice Guidance. The relevant sections are the Housing and Economic Land
Availability Assessment (March 2015)
17
, Neighbourhood Planning (updated
February 2018)
18
and Locality’s Neighbourhood Planning Site Assessment
Toolkit
19
. These all support assessing whether a site is appropriate for
allocation in a Neighbourhood Plan based on whether it is suitable, available
and achievable. In this context, the methodology for identifying, appraising and
reviewing sites is presented below.
Task 1: Site Identification
3.2 The first task is to identify which sites should be considered as part of the site
assessment for the East Bergholt Neighbourhood Plan Review. A
neighbourhood- scale ‘call for sites’ was completed between November 2021
and January 2022, in which a total of four sites have come forward for
residential development. One of the four sites, Park Road Site, is also
promoted for community uses and/or a solar farm. In addition, the Babergh and
Mid Suffolk Joint Local Plan SHELAA (October 2020) identified 9 potential sites
within the parish that would need to be considered in this report, resulting in 13
sites for assessment. All of the 9 potential sites identified through the BMSJLP
SHELAA are promoted for residential development.
Task 2: Site Assessment and Review
3.3 For sites that have already been assessed in the Babergh and Mid Suffolk Joint
Local Plan SHELAA, a thorough review of the report conclusions is conducted
to establish whether there is any new or additional evidence available that
would change the findings; whether the conclusions that have been applied in
the Local Plan context can also be applied to the Neighbourhood Plan; and
whether the assessment conclusions are fully supported by evidence. All review
forms are presented in Appendix B of this report.
3.4 All remaining new sites are assessed using a site appraisal proforma
developed by AECOM for allocation in the Neighbourhood Plan. It is based on
the Government’s National Planning Practice Guidance and the Locality Site
Assessment Toolkit. The purpose of the proforma is to enable a consistent
evaluation of each site against an objective set of criteria. All completed
proformas are presented in Appendix A of this report.
3.5 The proforma used for the assessment enables a range of information to be
recorded, including the following:
• General information:
─ Site location and use; and
─ Site context and planning history.
• Context:
17
Available at https://www.gov.uk/guidance/housing- and-economic-land-availability-assessment
18
Available at https://www.gov.uk/guidance/neighbourhood- planning– 2
19
Available at https://neighbourhoodplanning.org/toolkits -and-guidance/assess-allocate- sites-development/ East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 22

─ Type of site (greenfield, brownfield etc.); and
• Suitability:
─ Site characteristics;
─ Environmental considerations;
─ Heritage considerations;
─ Community facilities and services; and
─ Other key considerations (e.g. flood risk, agricultural land, tree
preservation orders).
• Availability
3.6 Completion of the site proformas was done through a combination of desktop
assessment and a site visit in June 2022. The desktop assessment involved a
review of the conclusions of the existing evidence and using other sources
including Google Maps/Streetview, MAGIC maps and Local Authority data in
order to judge whether a site is suitable for the use proposed. The site visit
allowed the team to consider aspects of the site assessment that could only be
done visually. It was also an opportunity to gain a better understanding of the
context and nature of the neighbourhood area.
3.7 The assessment on renewable energy generation use in this report only
explore site’s potential suitability as a solar farm, as the promoted land use.
Other forms of renewable energy generation have not been investigated.
3.8 Table 1 and Figure 2 summarise all sites identified and their respective
assessment approach.
Table 1 Sites identified for assessment
Site
Ref.
Site Name Area
(Ha)
Proposed Uses Site Source Detailed
Proforma /
Review
Form
EB01 White Horse Farm 1.37 Housing –
market,
affordable and
self-build.
East Bergholt
NDP Review:
Call for Sites
Appendix A
EB02 Harvey and
Doubles
9.50 Housing –
market,
affordable and
self-build.
East Bergholt
NDP Review:
Call for Sites
Appendix A
EB03 Park Road Site 8.09 Housing –
market and
affordable.
Residential care
home, holiday
accommodation,
community
uses, solar farm.
East Bergholt
NDP Review:
Call for Sites
Appendix A East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 23

Site
Ref.
Site Name Area
(Ha)
Proposed Uses Site Source Detailed
Proforma /
Review
Form
EB04 Quintons Road
Site
0.20 Housing –
market,
affordable and
self-build.
Holiday
accommodation.
East Bergholt
NDP Review:
Call for Sites
Appendix A
SS0180 Land north east of
Hadleigh Road,
East Bergholt
11.7 Residential
development
BMSJLP
SHELAA
October 2020
Appendix B
SS0181 Land north of west
of Moores Lane,
East Bergholt
8.80 Residential
development
BMSJLP
SHELAA
October 2020
Appendix B
SS0182 Land south of
Heath Road, East
Bergholt
9.00 Residential
development
BMSJLP
SHELAA
October 2020
Appendix B
SS0183 Land west of
Woodgates Road
1.58 Residential
development
BMSJLP
SHELAA
October 2020
Appendix B
SS0239 Land south of
Bentley Road, East
Bergholt
1.11 Residential
development
BMSJLP
SHELAA
October 2020
Appendix B
SS0432 Land south of
Willets Pond, East
Bergholt
2.10 Residential
development
BMSJLP
SHELAA
October 2020
Appendix B
SS0829 Land south of
Quintons Corner,
East Bergholt
1.34 Residential
development
BMSJLP
SHELAA
October 2020
Appendix B
SS1182 Land north west of
Quintons Road
0.47 Residential
development
BMSJLP
SHELAA
October 2020
Appendix B
SS1197 Land west of
Hadleigh Road,
East Bergholt
0.85 Residential
development
BMSJLP
SHELAA
October 2020
Appendix B East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 24

Figure 2 All Sites Identified for AssessmentEast Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 25

Task 3: Consolidation of Results
3.9 A ‘traffic light’ rating of all sites has been given based on whether the site is an
appropriate candidate for allocation in the Neighbourhood Plan. The traffic light
rating indicates ‘green’ for sites that show no or very few constraints and are
thus appropriate as site allocations, ‘amber’ for sites which are potentially
suitable if constraints can be resolved and ‘red’ for sites which are not
considered currently to be suitable. The judgement on each site is based on the
three ‘tests’ of whether a site is appropriate for allocation
– i.e. whether or not
the site is suitable, available and achievable for a proposed use.
Task 4: Indicative Development Capacity
3.10 Where sites were previously included in the BMSJLP SHELAA or draft Local
Plan, the indicative development capacity shown in these documents has been
used as a starting point, unless more updated information has been submitted.
If site promoters have put forward an indicative development capacity, this has
been used as appropriate.
3.11 Where a site was neither included in previous evidence base documents and
the landowner or developer did not submit a capacity figure, based on
development density of recently allocated and permitted sites, an indicative
density range of 15dph to 30dph has been used in reflection of the rural nature
of East Bergholt to make the assessment as consistent as possible
.. Table 2
below shows how the net density is calculated for sites within different contexts.
3.12 The indicative densities and capacities stated for each site in this assessment
should however be considered as a starting point only and are only relevant if
the entire site was developed. Different densities than suggested in this report
may be appropriate to apply to the sites in the Neighbourhood Area (resulting in
different capacities) based on site specific circumstances (such as for example
the characteristics of the individual site location).
Table 2 AECOM Indicative Housing Density Calculation
Site Area Gross to net ratio standards
Up to 0.4 Ha 90%
0.4 to 2 Ha 80%
2 Ha to 10 Ha 75%
Over 10 Ha 50%

East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 26

Site Assessment
4.1 Table 3 provides the assessment results of all 13 sites identified through the
neighbourhood- scale ‘Call for Sites’ and the BMSJLP SHELAA. The final
column within the table provides the ‘traffic light rating’ for each site, indicating
whether the site is appropriate for allocation for housing or solar farm in the
Neighbourhood Plan Review. Red indicates the site is not appropriate for
allocation through the Neighbourhood Plan and Green indicates the site is
appropriate for allocation. Amber indicates the site is less suitable or may be
appropriate for allocation through the Neighbourhood Plan if certain issues can
be resolved or constraints mitigated.
4.2 The summary table should be read alongside the completed proformas and
review forms presented in Appendix A and Appendix B.
4.3 A plan illustrating the assessment ratings is shown in Figure 3 . East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 27

Table 3 Site Assessment Summary
Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
EB01 White
Horse
Farm
1.37 Housing – market,
affordable and
self-build.
To be read in conjunction with Appendix A

A greenfield site partially within and partially adjacent to the existing Built Up Area
Boundary of East Bergholt. It is in close proximity to local shops, bus stops and the
secondary school. The site is currently served by two existing agricultural accesses which
could be potentially improved to support development subject to consultation with Suffolk
County Council.

The site is located within the Dedham Vale Area of Outstanding Natural Beauty.
Development of the site should preserve and enhance the landscape and scenic beauty of
the AONB through sensitive design in accordance with Paragraphs 176 and 177 of the
NPPF, Policy CR02 of the ‘saved’ policies of the Babergh Local Plan and draft Policy
LP20 of the emerging Babergh and Mid Suffolk Local Plan. It should also be informed by
Dedham Vale AONB Management Plan.

The site is considered to be of medium landscape and visual sensitivity. Development of
the site is likely to form a natural extension of the village and provide opportunities to
facilitate the soft transition between the built up area of East Bergholt and the adjacent
valley landscape.

The site is in close proximity to a Grade II listed building. Development of the site may
impact the setting of the designated heritage assets, which would need to be mitigated.

The site consists of Grade 2 Very Good Agricultural Land and Grade 3 Good to Moderate
Agricultural Land. Paragraph 171 of the National Planning Policy Framework states that
plans should allocate land with the least environmental or amenity value. Footnote 53
suggests that where significant development of agricultural land is demonstrated to be
necessary, areas of poorer quality land should be preferred to those of higher quality.

The site is available for residential development (including market, affordable and self-
build housing) and was put forward to the East Bergholt NDP Review Call for Sites by the
Potentially
suitable
(indicative
capacity of
16
dwellings)
Potentially
suitable
but not
currently
available East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 28

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
landowner. The site is potentially suitable for market and/or affordable housing and
allocation in the Neighbourhood Plan subject to mitigation of constraints in relation to
access, biodiversity, landscape, heritage impacts and the loss of the best and most
versatile agricultural land and consultation with Natural England. There should be
evidence that the site is economically viable if proposed for affordable housing allocation.
Development in excess of 1 hectare will be required to provide on-site open space
provision to meet identified needs or deficits in accordance with the open space standards
referenced in the draft Local Plan.

Availability for other land uses is unknown at present and there is no indication the site is
available for solar energy generation. If solar energy generation was considered and
agreed with a landowner, consultation is advised with Babergh District Council and Natural
England, as well as consideration of the mitigation of constraints in relation to access,
biodiversity, landscape, heritage and the loss of the best and most versatile agricultural
land.
EB02 Harvey
and
Doubles
9.50 Housing – market,
affordable and
self-build.
To be read in conjunction with Appendix A

A greenfield site in the open countryside. While a small part of the site is adjacent to the
existing built-up area and settlement boundary to the southwest along Gandish Road, the
site is largely removed from the existing built-up area and is remote from key services and
facilities. This is likely to change when the committed mixed-use development at SS0182
is delivered immediately north of the site although the site will remain removed from the
main settlement by a designed landscape gap as part of the mixed use development.
Suitable access could be potentially facilitated via Mill Road and Gandish Road to support
development on site subject to consultation with Suffolk County Council.

The site is adjacent to the Dedham Vale Area of Outstanding Natural Beauty.
Development of the site is likely to adversely impact identified views along the AONB from
publicly accessible viewpoints, its landscape character and the setting of East Bergholt,
contrary to Paragraph 176 and 177 of the NPPF, Policy CR02 of the ‘saved’ policies of the
Babergh Local Plan, Policy CS11 of the adopted Babergh Local Plan Core Strategy and
Policies and draft Policy LP20 of the emerging Babergh and Mid Suffolk Local Plan.
Development of the site will also impact an identified view of the ‘made’ East Bergholt
Not
suitable
Not
suitable East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 29

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
Neighbourhood Plan contrary to Policy EB6. Development of the site will adversely impact
the existing settlement pattern of East Bergholt by merging the northern and southern
housing clusters and encroaching into the open countryside beyond the established rural
edge at Mill Road. It is unlikely that partial development of the site can adequately mitigate
the significant impacts on the landscape and settlement pattern of East Bergholt.

The site falls within the SSSI Impact Risk Zone. Residential development of 50 dwellings
or more and solar schemes with a footprint larger than 0.5 Ha on the site would need to be
consulted with Natural England for its potential impacts on the Stour and Orwell Estuaries
SPA and Ramsar.

The site wraps around the Old Mill House, a Grade II listed building. Development of the
site is likely to have a significant and direct impact on the rural setting in which it is
experienced subject to further heritage assessments, contrary to Paragraphs 199 and 201
of the NPPF.

The site is crossed by overhead power lines and their transmission towers at present.
Development of the site would need to be consulted with National Grid to ensure that the
legally-binding safety clearances for the overhead powerlines or an underground cable
easement are maintained.

Development of the site would lead to a significant loss of Grade 2 Agricultural Land.
Paragraph 171 of the National Planning Policy Framework states that plans should
allocate land with the least environmental or amenity value. Footnote 53 suggests that
where significant development of agricultural land is demonstrated to be necessary, areas
of poorer quality land should be preferred to those of higher quality.

The site is located within the Minerals Consultation Area and is in excess of 5 Ha, where
Suffolk County Council will in principle object to development unless it can be shown that
the sand and gravel present are not of economic value, or not practically or
environmentally feasible to extract, or that the mineral will be worked before the
development in accordance with Policy MP10 of the Suffolk Minerals and Waste Local
Plan. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 30

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm

The site is available for residential development (including market, affordable and self-
build housing) and was put forward to the East Bergholt NDP Review Call for Sites by the
landowners. Availability for other land uses is unknown at present and there is no
indication the site is available for solar energy generation.

Given the significant adverse impacts development would have on the AONB, designated
heritage assets, identified views and the settlement and landscape character of East
Bergholt, as well as the adopted and emerging Local Plan policies relating to new
development, it is not considered to be suitable for housing or solar farm development.

The site is adjacent to a committed large scale residential development and could be
accessed via public and active modes of travel. It may be a potentially appropriate location
for recreational uses to address identified demand in East Bergholt, subject to consultation
with Babergh District Council and Sports England and appropriate mitigation or resolution
of the identified constraints. The site has not been promoted for recreational uses at
present, and would need to be demonstrated as available and viable if proposed for
allocation.
EB03 Park Road
Site
8.09 Housing – market
and affordable.
Residential care
home, holiday
accommodation,
community uses,
solar farm.
To be read in conjunction with Appendix A

The site is a grazing paddock in the open countryside largely outside of and not connected
to the existing built up area and settlement boundary of East End. It is at a remote and
unsustainable location with poor accessibility to key services and facilities, albeit in close
proximity to the local farm shop. It is served by existing agricultural access which could be
potentially improved to support development subject to further consultation with Suffolk
County Council.

The open nature of the site makes a significant positive contribution to the landscape
character of the settlement and plays a key role in supporting the transition of East End to
the open countryside. Full development of the site would represent a significant growth at
East End inappropriate to its current scale and role and encroachment into the open
countryside, contrary to Policy HS28 of the ‘saved’ policies of the Babergh Local Plan,
Policy CS11 of the Babergh Local Plan Core Strategy and policies and Policy HB2 of the
Not
suitable
Not
suitable East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 31

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
‘made’ East Bergholt Neighbourhood Plan. Development of the site is likely to adversely
impact existing views from the surrounding Public Rights of Way. The significant adverse
impacts on landscape character are unlikely to be effectively mitigated through screening
and may be exacerbated by the potential glint and glare, movements of solar arrays and
impacts from any security measures required for the solar farm.

The site is in close proximity to a number of Grade II listed buildings including Tudor
Cottage and Park House. Development of the site is likely to be visible and may impact
the setting of the designated heritage assets, which would need to be mitigated.

Development of the site will lead to the loss of Grade 2 and 3 Agricultural Land. Paragraph
171 of the National Planning Policy Framework states that plans should allocate land with
the least environmental or amenity value. Footnote 53 suggests that where significant
development of agricultural land is demonstrated to be necessary, areas of poorer quality
land should be preferred to those of higher quality. Development of the site as a solar farm
will represent an ineffective use of the best and most versatile agricultural land contrary to
the Planning Practice Guidance on Renewable Energy and Low Carbon Energy and draft
Policy LP27 of the draft Babergh and Mid Suffolk Joint Local Plan.

The site is available for residential development (market, affordable and residential care
home) or solar farm and was put forward to the East Bergholt NDP Review Call for Sites East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 32

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
by the landowners. No detailed information has been submitted on the type and scale of
potential proposals for renewable energy on this site.

The site is not suitable for housing or solar farm development and allocation in the
Neighbourhood Plan at present due to significant constraints in relation to its location,
significant adverse impacts on the settlement and landscape character of East End and
potential impact on the setting of designated heritage assets.

Given its location adjacent to the farm shop / community hub and connectivity to the Public
Rights of Way network, the site is potentially suitable for recreational uses to strengthen
the existing services and facilities provision in East End, subject to consultation with
Babergh District Council and Sports England and appropriate mitigation or resolution of
the identified constraints.
EB04 Quintons
Road Site
0.20 Housing – market,
affordable and
self-build. Holiday
accommodation.
To be read in conjunction with Appendix A

The site is a small green space at a road junction within the built-up area and settlement
boundary of East Bergholt. Suitable access to the site as a private drive could be
potentially facilitated subject to further consultation with Suffolk County Council although it
would need to be carefully designed to ensure that adequate visibility splays are provided.

The site contains three oak trees protected under the Tree Preservation Order. Owing to
the small site size, development is unlikely to be possible without the removal of the
protected trees subject to further arboricultural assessment. The site is designated as a
Local Green Space under Policy EB7 of the ‘made’ East Bergholt Neighbourhood Plan
(LGS 2 Open area opposite entrance to the Hermitage on Quintons Road). It is also
identified as an area of visual and amenity value under saved Policy CN03 of the Babergh
Local Plan although this allocation has not been taken forward in the emerging Babergh
and Mid Suffolk Joint Local Plan. Development of the site would result in the unacceptable
loss of the Local Green Space contrary to Policy EB7.

Development of the site will lead to the loss of Grade 2 Very Good Agricultural Land.
Paragraph 171 of the National Planning Policy Framework states that plans should
allocate land with the least environmental or amenity value. Footnote 53 suggests that
Not
suitable
Not
suitable East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 33

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
where significant development of agricultural land is demonstrated to be necessary, areas
of poorer quality land should be preferred to those of higher quality.

The site is in close proximity to a number of Grade II* and II listed buildings including the
Chaplins, the Hermitage, Chaplains Cottage and the Hare and Hounds. Development of
the site may impact the setting of the designated heritage assets.

The site is available for residential development and was put forward to the East Bergholt
NDP Review Call for Sites by the landowners for one dwelling. The site is not indicated to
be available for other proposed uses at present.

It is not suitable for housing or solar farm development and allocation in the
Neighbourhood Plan at present due to significant constraints in relation to the loss of Local
Green Space, impacts on trees protected under the Tree Preservation Order and the
townscape and visual character of East Bergholt.

The site is a Local Green Space in an accessible location within the built-up area of East
Bergholt. However, the existing dense tree cover on site, combined with its small site size
and relatively unsafe and exposed location at the highways junction, there are limited
potential for further recreational facilities on site.
SS0180 Land north
east of
Hadleigh
Road, East
Bergholt
11.7 Residential
development
To be read in conjunction with Appendix B
A large greenfield site adjacent though not connected to the built up area boundary of East
Bergholt. The site was promoted and confirmed as available for residential development in
2020 and no information to the contrary has been received since. The site is not indicated
to be available for other proposed uses at present.

Development of the site would represent significant encroachment into the open
countryside beyond the existing settlement pattern taking into account the committed
development at SS0181. Development of the site is likely to have significant adverse
impacts on the landscape and scenic quality of the AONB, the setting of the designated
heritage assets within the AONB and an identified view, contrary to Paragraphs 176 and
177 of the NPPF, Policy CR02 of the ‘saved’ policies of the Babergh Local Plan, Policy
CS11 of the adopted Babergh Local Plan Core Strategy and Policies, Policy EB6 of the
Not
suitable
Not
suitable East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 34

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
‘made’ East Bergholt Neighbourhood Plan and draft Policy LP20 of the draft Babergh and
Mid Suffolk Local Plan. The site is unsuitable for housing and therefore not appropriate for
allocation or as a rural exception site in the Neighbourhood Plan.

Similarly, development of the site as a large scale solar farm is also likely to have
significant adverse impacts on the landscape and scenic quality of the AONB (including
the identified view and the setting of the designated heritage assets) and on the residential
amenity of nearby homes due to its proximity and likely prominence. The significant
adverse impacts are unlikely to be effectively mitigated through screening and may be
exacerbated by the potential glint and glare, movements of solar arrays and impacts from
any security measures required.

Development of the site as a large scale solar farm would also represent an ineffective
use of the best and most versatile agricultural land. The site falls within the SSSI Impact
Risk Zone where all solar schemes with a footprint larger than 0.5 Ha would need to be
consulted with Natural England on its impact on biodiversity. In line with the Planning
Practice Guidance on Renewable Energy and Low Carbon Energy and draft Policy LP27
of the draft Babergh and Mid Suffolk Joint Local Plan, the site is unsuitable for
development and allocation as large scale solar farms in the Neighbourhood Plan.

The site has planning permission for the erection of 144 dwellings. As the planning
permission has been granted, the site would not need to be allocated in the
Neighbourhood Plan (although support for development at this location could be
The site does not need
to be allocated in the
Neighbourhood Plan as East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 35

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
Lane, East
Bergholt
demonstrated through an allocation). planning permission
has been granted
SS0182 Land south
of Heath
Road, East
Bergholt
9.00 Residential
development
To be read in conjunction with Appendix B

The site has outline planning permission for mixed use development including the erection
of 75 dwellings. As the planning permission has been granted, the site would not need to
be allocated in the Neighbourhood Plan (although support for development at this location
could be demonstrated through an allocation).
The site does not need
to be allocated in the
Neighbourhood Plan as
planning permission
has been granted
SS0183 Land west
of
Woodgates
Road
1.58 Residential
development
To be read in conjunction with Appendix B

A greenfield site with a strong rural character adjacent though not connected to the East
Bergholt Built Up Area Boundary. The site was confirmed as available for residential
development in 2020 and no information to the contrary has been received since.
Availability for other land uses is unknown at present and there is no indication the site is
available for solar energy generation.
Development of the site would represent an unnatural and isolated extension of East
Bergholt, encroaching into the open countryside with significant adverse impacts on the
landscape and settlement character of East Bergholt. The site is not connected to a
continuous pedestrian network. The site is therefore unsuitable for housing and therefore
not appropriate for allocation or as a rural exception site in the Neighbourhood Plan at
present.
Similarly, development of the site as a large scale solar farm is also likely to have
significant adverse impacts on the landscape and settlement character of East Bergholt,
the rural setting of the Grade II Listed Woodgates Farmhouse and the residential amenity
of adjacent properties. Development of the site as a large scale solar farm would also
represent an ineffective use of the best and most versatile agricultural land. The site falls
within the SSSI Impact Risk Zone where all solar schemes with a footprint larger than 0.5
Ha would need to be consulted with Natural England on its impact on biodiversity. In line
with the Planning Practice Guidance on Renewable Energy and Low Carbon Energy and
draft Policy LP27 of the draft Babergh and Mid Suffolk Joint Local Plan, the site is
unsuitable for development and allocation as large scale solar farms in the Neighbourhood
Plan.
Not
suitable
Not
suitable East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 36

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
The site is not connected to a continuous pedestrian network and could not be safely
accessed via public and active modes of travel. Combined with significant landscape,
heritage and potential biodiversity impacts, the site is unsuitable for recreational
development and allocation in the Neighbourhood Plan.
SS0239 Land south
of Bentley
Road, East
Bergholt
1.11 Residential
development
To be read in conjunction with Appendix B
The site is outside of and disconnected from the built up area boundary of East End. It is
also at a remote and unsustainable location with limited accessibility to regular services
apart from a local pub. Development of the site will be in contrary to Policy CS2 and CS15
of the Babergh Local Plan Core Strategy and Policies and Policy EB2 of the ‘made’ East
Bergholt Neighbourhood Plan. The site is therefore unsuitable for residential or
recreational development and allocation in the Neighbourhood Plan at present.
The site is a non-designated historically significant medieval manor adjacent to the AONB.
Development of the site as a large scale solar farm may lead to a loss of tranquillity and
harm the sensitive historic and rural landscape character. The site falls within the SSSI
Impact Risk Zone where all solar schemes with a footprint larger than 0.5 Ha would need
to be consulted with Natural England on its impact on biodiversity. In line with the Planning
Practice Guidance on Renewable Energy and Low Carbon Energy and draft Policy LP27
of the draft Babergh and Mid Suffolk Joint Local Plan, the site is unsuitable for
development and allocation as large scale solar farms in the Neighbourhood Plan.

Not
suitable
Not
suitable
SS0432 Land south
of Willets
Pond, East
Bergholt
2.10 Residential
development
To be read in conjunction with Appendix B

A greenfield site located at an environmentally sensitive location in close proximity to the
Stour and Orwell Estuaries SPA and Ramsar and within the AONB. It is in the open
countryside at a remote location disconnected from the main settlement clusters of East
Bergholt. Paragraph 80 of the NPPF seeks to avoid the development of isolated homes in
the countryside unless one or more of the exceptions apply. No evidence has been
received in relation the exception criteria. The site is therefore unsuitable for housing,
recreational development or solar farm development and allocation in the Neighbourhood
Plan at present.
Not
suitable
Not
suitable East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 37

Site
Ref
Site Name Area
(Ha)
Proposed Uses
(Call for Sites)
Neighbourhood Plan Site Assessment Summary Market and/
or
affordable
Housing
Solar
Farm
The site was confirmed as available for residential development in 2020 and no
information to the contrary has been received since. Availability for other land uses is
unknown at present.
SS0829 Land south
of
Quintons
Corner,
East
Bergholt
1.34 Residential
development
To be read in conjunction with Appendix B
The site is a designated Local Green Space and Area of Visual and Amenity Value within
the built-up area of East Bergholt in close proximity to a number of designated heritage
assets. The site entirely comprises of priority habitats (Deciduous Woodland) where its
loss is unavoidable if developed. These trees are also protected under the Tree
Preservation Order. Development of the site would be in contrary to Paragraph 180 of the
National Planning Policy Framework which states that Local Planning Authorities should
refuse planning permission if significant harm to biodiversity resulting from a development
cannot be avoided (through locating on an alternative site with less harmful impacts),
adequately mitigated, or, as a last resort, compensated for. Development of the site would
have a detrimental impact on sensitive historic and natural environments, which cannot be
reasonably mitigated or compensated, and would also result in the loss of a designated
open space. The site is therefore unsuitable for development and allocation as housing,
recreational development or solar farms in the Neighbourhood Plan at present.
The site was confirmed as available for residential development in 2020 and no
information to the contrary has been received since. Availability for other land uses is
unknown at present.
Not
suitable
Not
suitable
SS1182 Land north
west of
Quintons
Road
0.47 Residential
development
To be read in conjunction with Appendix B

A greenfield site partially adjacent though not connected to the built up area boundary of
East Bergholt. The site does not front a public highway and therefore suitable access
could not be achieved at present. In addition, development of the site may also have
significant impacts on the visual and landscape character of East Bergholt. The site is
therefore unsuitable for development and allocation as housing, recreational development
or solar farms in the Neighbourhood Plan at present.
Not
suitable
Not
suitable East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 38

The site has planning permission for the erection of 10 single-storey dwellings for the over
55s. As the planning permission has been granted, the site would not need to be allocated
in the Neighbourhood Plan (although support for development at this location could be
demonstrated through an allocation).
The site does not need
to be allocated in the
Neighbourhood Plan as
planning permission
has been granted East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 39

Figure 3 Site Assessment Conclusions East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 40

Conclusions
5.1 The Parish Council intends to allocate land for market and/or affordable
housing and is exploring other uses including renewable energy (a solar farm)
on sites that accord with the strategic policies of the Local Plan and the
objectives of the Neighbourhood Plan. It also seeks to identify potential
opportunities for recreational uses.
5.2 Of the 13 sites assessed, this site assessment found that 3 sites already have
planning permission for residential or mixed use development and would not
need to be allocated in the Neighbourhood Plan Review, although support for
development at these locations could be demonstrated through an allocation.
These sites were also draft housing allocations in the emerging Babergh and
Mid Suffolk Local Plan but the relevant policies are proposed for deletion at
present. Together these sites provide a housing capacity of 229 dwellings.
These sites are:
• SS0181 Land north of west of Moores Lane – 144 dwellings;
• SS0182 Land south of Heath Road – 75 dwellings; and,
• SS0197 Land west of Hadleigh Road – 10 dwellings.
5.3 One site, EB01 White Horse Farm, is considered potentially suitable for market
or affordable housing, and therefore appropriate for allocation in the
Neighbourhood Plan with an indicative capacity of 16 dwellings. There should
be evidence that the site is a vailable and economically viable for the proposed
development if selected for allocation.
5.4 EB01 is also found to be potentially suitable for small-scale solar farm
development, if it is demonstrated to be available for this use and subject to
further investigation. Further assessment would be required to demonstrate the
site’s energy generating potential and to understand the detailed scheme’s
impacts on the qualities and function of the AONB, biodiversity, landscape,
residential amenity and the setting of designated heritage assets. The proposal
would also need to demonstrate that any potential harm resultant from
development can be effectively mitigated and that there are no alternative sites
available within the District in line with draft Policy LP27 of the draft Babergh
and Mid Suffolk Joint Local Plan.
5.5 The remaining nine sites (EB02, EB03, EB04, SS0180, SS0183, SS0239,
SS0432, SS0829 and SS182) were found to be unsuitable for residential or
solar energy development and therefore not appropriate for allocation in the
Neighbourhood Plan Review.
5.6 Three of these nine sites (EB02, EB03 and SS0180) are potentially suitable for
recreational uses subject to further consultation with the landowners, Babergh
District Council and Sports England, as well as resoluti on or mitigation of the
identified constraints. There should be evidence that the site is available and
economically viable for the proposed development if selected for allocation.
East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 41

5.7 Residential development in excess of 1 hectare will be required to provide open
space provision to meet identified needs or deficits in accordance with the open
space standards referenced in the draft Local Plan. The Leisure, Sport and
Physical Activity Strategy (2020)
20
for Babergh and Mid Suffolk District Councils
identifies East Bergholt as a priority area for additional and improved sports and
physical activity provision due to the likely pressure from large scale committed
development. The Strategy also sets out a number of potential projects to
address the expected needs, such as improving East Bergholt Sports Centre.
5.8 The assessment of sites for renewable energy use in this report has been
limited to solar energy and has not considered other uses (e.g. wind turbines).
Sites assessed as unsuitable for solar farms may be suitable for other forms of
renewable energy generation, such as active solar technology (photovoltaic
and solar water heating) on or related to buildings.
Affordable Housing
5.9 Excluding the three committed sites with planning permissions for residential
development, one site considered in this assessment is potentially suitable for
allocation for affordable housing including Discounted Market Housing (e.g.
First Homes
21
), affordable housing for rent, or other affordable housing types
(see NPPF Annex 2). The requirement for Affordable Housing provision on sites
proposed for allocation in the Neighbourhood Plan should be discussed with
the Local Planning Authority (usually your neighbourhood planning officer) to
understand the specific requirements for the sites proposed for allocation. D raft
Policy LP08 of the draft Babergh and Mid Suffolk Joint Local Plan supports up
to 35% of market housing on sites where the financial appraisal demonstrates a
need for open market housing to cross-subsidise affordable housing.
5.10 There is also an option to bring forward affordable housing on ‘rural exception
sites’ in the Neighbourhood Area, which would be expected to meet national
and local rural exception policies and could be supported through a rural
exception policy in the Neighbourhood Plan.
Next Steps
5.11 Based on the findings of this report, East Bergholt Parish Council should
engage with Babergh District Council and the community to select sites for
allocation in the Neighbourhood Plan which best meet community needs and
plan objectives from the shortlist of suitable and potentially suitable sites.

5.12 The site selection process should be based on the following:
• The findings of this site assessment;
• Discussions with the planning authority;
• The extent to which the sites support the vision and objectives for the NP;
20
Available at
https://baberghmidsuffolk.moderngov.co.uk/documents/s23553/Appendic%20A%20LSPA%20Strategy%20Update%20Report%
20-%20Final%20Ver%202.0.pdf
21
The Government recently consulted on the First Homes Policy and a minimum of 25% of all affordable housing units secured
through developer contributions will need to be first homes. You can find out more here: https://www.gov.uk/guidance/first-
homes East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 42

• The potential for the sites to meet the identified infrastructure needs of the
community;
• Engagement with key stakeholders; and
• General conformity with strategic Local Plan policy
5.13 The Qualifying Body should be able to demonstrate that the sites are viable for
development, i.e. that they provide an adequate financial return for the
developer. It is recommended that the Qualifying Body discusses site viability
with Babergh District Council. It is further suggested that any landowner or
developer promoting a site for development should be contacted to request
evidence of viability, e.g. a site financial viability appraisal. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 43

Appendix A Site Assessment Proforma East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 44

Appendix B SHELAA Review
SS0180
SS0180 Land north east of Hadleigh Road, East Bergholt
Site Reference
SS
0180
Site Address
Land north east of Hadleigh Road, East Bergholt
Site Source
BMSJLP SHELAA October 2020
Gross Site Area (Hectares) 11.7 (AECOM estimate)
Proposed Development Residential development (approximately 170 dwellings)
BMSJLP SHELAA October 2020 Assessment Summary
Conclusion
Discounted – Site is disproportionate and is not consistent with existing
settlement pattern. Site has poor connectivity to the existing settlement.

A subsequent addendum published in September 2021
22
during the
examination period provides the full suitability assessment work for the
discounted sites. It shows that the site is unsuitable as development of the
site would not fit in well with the existing pattern of residential development
in townscape terms and is disproportionate. It is also not well related to the
functional settlement of East Bergholt.

Other identified constraints of the site include limited access to local
facilities, potential impacts on the Dedham Vale AONB immediate south,
location within the HRA RAMS 13km Zone of Influence, potential impact on
listed buildings located to the southwest of the building, as well as potential
impacts on the highways network.
How can these conclusions be applied to the Neighbourhood Planning Site Assessment?
Has the site been excluded or
assessed as unsuitable due to
size?
No
Does more recent or additional
information now exist which could
change the HELAA findings?
• The site falls within the SSSI Impact Risk Zone. Residential
development of 50 or more dwellings would need to be consulted with
Natural England.
• The site is of low to medium landscape capacity (Parcel N) to accommodate built development as identified in the 2015 East Bergholt
Landscape Capacity Appraisal. The assessment suggests that while
development on the parcel would relate well to the settlement edge, it
would have the potential to have a significant influence on visual
amenity as a result of the open nature of the surrounding landscape.
The assessment states that it is likely that a case for development
could only be made for the portion of land between the settlement edge
and the plantation.
• Development of the site is likely to significantly impact one of the most
significant and valued views identified (View 3 View north from
Hadleigh Road) through the made East Bergholt Neighbourhood Plan.
• The Historic Landscape Study of East Bergholt and the Cultural Legacy
of John Constable (November 2020) provides an update to the 2015 East Bergholt Landscape Capacity Appraisal which considers the
cultural heritage associations and archaeological interest of East
22
Available at https://www.midsuffolk.gov.uk/assets/Strategic -Pl anning/Current-Evidence- Base/SHELAA2020/BMSDC -Joint-
SHELAA- Report-Oct-2020.pdf East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 75

Bergholt and extend the appraisal to the Parish Boundary. The northern
part of the site falls within one of the Areas of Potential Archaeological
and Historical Sensitivity identified (Area A). Area A is described as the
most sensitive area archaeologically within the parish , with a very high
potential of encountering undiscovered archaeological remains based
on existing evidence. The discovery of high or medium sensitivity
significance from the Roman times within Area A is considered to be of
medium probability. The site falls within Land Parcel 23 which is
considered to be of medium-high landscape and heritage sensitivity.
This means that all development (except for very localised and small-
scale development) is likely to have significant adverse effects on the
landscape / village character and/or visual amenity, even with mitigation
measures in place. The Parcel is described to have a rectilinear from
typical of enclosed heathland and remain largely intact dating to pre
18
th
century enclosure. The assessment particularly notes the open and
far ranging views across the large scale landscape from the B1070
towards the north settlement edge and eastwards from Hughes Road.
• The site is in close proximity to a Grade II* listed building (The Lodge) and a Grade II listed building (The Lodge Cottage). The site has high intervisibility with the designated heritage assets and development is
likely is impact the setting of these designated heritage within the
AONB as well as the landscape and scenic quality of the AONB.
• The site is adjacent though not connected to the East Bergholt Built Up
Area. It falls outside of the 800 metres of the village Focal Points under
Policy EB2 of the ‘made’ Neighbourhood Plan, although it is in close
proximity to committed development west of Moores Lane.
• The site is located within the Minerals Consultation Area and is in
excess of 5Ha, where Suffolk County Council will in principle object to
development unless it can be shown that the sand and gravel present
is not of economic value, or not practically or environmentally feasible
to extract, or that the mineral will be worked before the development in
accordance with Policy MP10 of the Suffolk Minerals and Waste Local
Plan.
• The site consists of Grade 2 Very Good Agricultural Land. Paragraph
171 of the National Planning Policy Framework states that plans should
allocate land with the least environmental or amenity value. Footnote
53 suggests that where significant development of agricultural land is
demonstrated to be necessary, areas of poorer quality land should be
preferred to those of higher quality.
Are there any concerns that the
HELAA conclusion is reasonable
and defensible?
No
Are the HELAA conclusions
reasonable to be carried
forward to the Neighbourhood
Plan Site Assessment?

Yes
In the Neighbourhood Plan
context, is the site suitable
(Y/N); is the site available (Y/N);
is the site achievable (Y/N)
A large greenfield site adjacent though not connected to the built up area
boundary of East Bergholt. The site was promoted and confirmed as
available for residential development in 2020 and no information to the
contrary has been received since. The site is not indicated to be available
for other proposed uses at present.

Development of the site would represent significant encroachment into the
open countryside beyond the existing settlement pattern taking into
account the committed development at SS0181. Development of the site is
likely to have significant adverse impacts on the landscape and scenic
quality of the AONB, the setting of the designated heritage assets within
the AONB and an identified view, contrary to Paragraphs 176 and 177 of
the NPPF, Policy CR02 of the ‘saved’ policies of the Babergh Local Plan,
Policy CS11 of the adopted Babergh Local Plan Core Strategy and
Policies, Policy EB6 of the ‘made’ East Bergholt Neighbourhood Plan and
draft Policy LP20 of the draft Babergh and Mid Suffolk Local Plan. The site
is unsuitable for housing and therefore not appropriate for allocation or as a
rural exception site in the Neighbourhood Plan.

Similarly, development of the site as a large scale solar farm is also likely
to have significant adverse impacts on the landscape and scenic quality of East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 76

the AONB (including the identified view and the setting of the designated
heritage assets) and on the residential amenity of nearby homes due to its
proximity and likely prominence. The significant adverse impacts are
unlikely to be effectively mitigated through screening and may be
exacerbated by the potential glint and glare, movements of solar arrays
and impacts from any security measures required.

Development of the site as a large scale solar farm would also represent
an ineffective use of the best and most versatile agricultural land. The site
falls within the SSSI Impact Risk Zone where all solar schemes with a
footprint larger than 0.5 Ha would need to be consulted with Natural
England on its impact on biodiversity. In line with the Planning Practice
Guidance on Renewable Energy and Low Carbon Energy and draft Policy
LP27 of the draft Babergh and Mid Suffolk Joint Local Plan, the site is
unsuitable for development and allocation as large scale solar farms in the
Neighbourhood Plan.

The site is within walking distance of the one of the committed large scale
residential development in East Bergholt and the East Bergholt VC Primary
School. The site could be accessed via public and active mode of travel. It
is therefore a potentially appropriate location for recreational use subject to
consultation with Babergh District Council and Sports England and
mitigation or resolution of the identified constraints. The site has not been
promoted for recreational uses at present, and would need to be
demonstrated as available and viable if allocated in the forthcoming
Neighbourhood Plan Review.
SS0181
SS0181 Land north of west of Moores Lane, East Bergholt
Site Reference
SS
0181
Site Address
Land north of west of Moores Lane, East Bergholt
Site Source
BMSJLP SHELAA October 2020
Gross Site Area (Hectares) 8.80
Proposed Development Residential development (SHELAA identified site capacity: 144 dwellings)
BMSJLP SHELAA October 2020 Assessment Summary
Suitability
Site is potentially suitable, but the following constraints have been
identified which would require further investigation: Highways – regarding
access, footpaths and infrastructure required. Scale of site- consider
reducing size of site to be more in keeping with the existing settlement
townscape and landscape. Utilities – water mains crossing site.
Availability
Site has a willing single landowner, with a planning application which is
awaiting a decision issued. The site is available in the short term.
Achievability
Now planning permission has been granted, a development scheme is
expected to be implemented.
Conclusion
The site is potentially considered suitable for residential development
(144 dwellings), taking identified constraints into consideration. However,
only part development (south- western aspect of site) is recommended in
order to avoid disproportionate development to the existing settlement.
How can these conclusions be applied to the Neighbourhood Planning Site Assessment? East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 77

Has the site been excluded or
assessed as unsuitable due to
size?
No
Does more recent or additional
information now exist which could
change the HELAA findings?
The site has been allocated for 144 dwellings (LA060) in the draft Babergh
and Mid Suffolk Joint Local Plan currently under examination. However,
correspondence between the Babergh and Mid Suffolk District Councils
and the Inspectors in December 2021 has agreed that the proposed
housing allocation policies will be deleted from the emerging Local Plan
moving forward as it is found unsound at present.
The site has a granted planning permission (B/15/00673) for the erection of
144 dwellings including 360sqm of single storey courtyard development to contain 4 B1 (business) units, public open space, associated landscaping and infrastructure since November 2017. In February 2022, it has been
demonstrated that the layout and construction of a part of a roadway of the
site constitutes commencement of development prior to expiry and therefore the planning permission B/15/00673 is extant and phase 0 of the development is decided as lawfully implemented.
As the planning permission has been granted, the site would not need to be all
ocated in the Neighbourhood Plan (although support for development
at this location could be demonstrated through an allocation). Further assessment in this SOA is not required.
Are there any concerns that the
HELAA conclusion is reasonable
and defensible?
No
Are the HELAA conclusions
reasonable to be carried
forward to the Neighbourhood
Plan Site Assessment?

Assessment not required as planning permission has been granted
In the Neighbourhood Plan
context, is the site suitable (Y/N); is the site available (Y/N);
is the site achievable (Y/N)
The site has planning permission for the erection of 144 dwellings. As the
planning permission has been granted, the site would not need to be
allocated in the Neighbourhood Plan (although support for development at
this location could be demonstrated through an allocation).
SS0182
SS0182 Land south of Heath Road, East Bergholt
Site Reference
SS
0182
Site Address
Land south of Heath Road, East Bergholt
Site Source
BMSJLP SHELAA October 2020
Gross Site Area (Hectares) 9.00
Proposed Development Residential development (75 dwellings)
BMSJLP SHELAA October 2020 Assessment Summary
Suitability
Site is potentially suitable, but the following constraints have been
identified which would require further investigation: Highways – regarding
access, footpaths and infrastructure required. Landscape/Townscape
impact Biodiversity impact. Minerals – site lies within Mineral Safeguarding
Zone.
Availability
Land available within 0-5 years. Site has been subject to a planning
application.
Achievability
The submission confirms that there are no legal restrictions on the land
and no known abnormal costs which would affect viability
Conclusion
Site is potentially suitable for residential development (75 dwellings)
taking into account identified constraints. East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 78

How can these conclusions be applied to the Neighbourhood Planning Site Assessment?
Has the site been excluded or
assessed as unsuitable due to
size?
No
Does more recent or additional
information now exist which could
change the HELAA findings?
The site has been allocated for 10 dwellings (LA059) in the draft Babergh
and Mid Suffolk Joint Local Plan currently under examination. However,
correspondence between the Babergh and Mid Suffolk District Councils
and the Inspectors in December 2021 has agreed that the proposed
housing allocation policies will be deleted from the emerging Local Plan
moving forward as it is found unsound at present.
The site has a granted outline planning permission (B/16/01092) for mixed-
use development including up to 75 dwellings, a pre- school and a
neighbourhood hub (comprising a swimming pool, office space and a local
shop), and associated infrastructure and landscaping since February 2018.
Subsequently, the reserved matters application (DC/20/04663) has also
been approved in December 2021.
As the planning permission has been granted, the site would not need to
be all
ocated in the Neighbourhood Plan (although support for development
at this location could be demonstrated through an allocation). Further
assessment in this SOA is not required.
Are there any concerns that the
HELAA conclusion is reasonable
and defensible?
No
Are the HELAA conclusions
reasonable to be carried
forward to the Neighbourhood
Plan Site Assessment?

A subsequent addendum published in September 2021 during the
examination period provides the full suitability assessment work for the
discounted sites. It shows that the site is unsuitable due to unsatisfactory
access to local services and facilities (no continuous footpath to the site)
and that the site would be an unnatural and isolated extension to the
locality.
East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 79

Other identified constraints of the site include the need for HRA screening
assessment for potential biodiversity impact, potential impact on listed
buildings located approximately 100m away to the north of the site, as well
as potential impacts on the highways network.
How can these conclusions be applied to the Neighbourhood Planning Site Assessment?
Has the site been excluded or
assessed as unsuitable due to
size?
No
Does more recent or additional
information now exist which could
change the HELAA findings?
• The site is of low to medium landscape capacity (Parcel B) to
accommodate built development as identified in the East Bergholt Landscape Capacity Appraisal. Although abutting the settlement edge,
Parcel B is considered to have a rural character relating to the open
countryside more than the village.

• The Historic Landscape Study of East Bergholt and the Cultural Legacy
of John Constable (November 2020) provides an update to the 2015
East Bergholt Landscape Capacity Appraisal which considers the
cultural heritage associations and archaeological interest of East
Bergholt and extend the appraisal to the Parish Boundary. The
assessment identifies the site in the Landscape Character Area of Land
Parcel 12, which of medium to high landscape and heritage sensitivity
to development. This means that all development (except for very
localised and small- scale development) is likely to have significant
adverse effects on the landscape / village character and/or visual
amenity, even with mitigation measures in place. In particular, the
assessment notes the open character of the landscape which affords
far reaching views including from higher ground in the vicinity of the
A12 and the intact rectilinear fields’ form dating to pre 18
th
century
enclosure.

• The site is adjacent though not connected to the East Bergholt Built Up
Area. It is within the 800 metres zone of the village Focal Points under
Policy EB2 of the ‘made’ Neighbourhood Plan.
• The site consists of Grade 2 Very Good Agricultural Land. Paragraph
171 of the National Planning Policy Framework states that plans should
allocate land with the least environmental or amenity value. Footnote
53 suggests that where significant development of agricultural land is
demonstrated to be necessary, areas of poorer quality land should be
preferred to those of higher quality.
Are there any concerns that the
HELAA conclusion is reasonable
and defensible?
No
Are the HELAA conclusions
reasonable to be carried
forward to the Neighbourhood
Plan Site Assessment?

Yes
In the Neighbourhood Plan context, is the site suitable (Y/N); is the site available (Y/N); is the site achievable (Y/N)
A greenfield site with a strong rural character adjacent though not
connected to the East Bergholt Built Up Area Boundary. The site was
confirmed as available for residential development in 2020 and no
information to the contrary has been received since. Availability for other
land uses is unknown at present and there is no indication the site is
available for solar energy generation.
Development of the site would represent an unnatural and isolated
extension of East Bergholt, encroaching into the open countryside with
significant adverse impacts on the landscape and settlement character of
East Bergholt. The site is not connected to a continuous pedestrian
network. The site is therefore unsuitable for housing and therefore not
appropriate for allocation or as a rural exception site in the Neighbourhood
Plan at present.
Similarly, development of the site as a large scale solar farm is also likely to have significant adverse impacts on the landscape and settlement
character of East Bergholt, the rural setting of the Grade II Listed
Woodgates Farmhouse and the residential amenity of adjacent properties.
Development of the site as a large scale solar farm would also represent
an ineffective use of the best and most versatile agricultural land. The site
falls within the SSSI Impact Risk Zone where all solar schemes with a
footprint larger than 0.5 Ha would need to be consulted with Natural East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 80

England on its impact on biodiversity. In line with the Planning Practice
Guidance on Renewable Energy and Low Carbon Energy and draft Policy
LP27 of the draft Babergh and Mid Suffolk Joint Local Plan, the site is
unsuitable for development and allocation as large scale solar farms in the
Neighbourhood Plan.
The site is not connected to a continuous pedestrian network and could not
be safely accessed via public and active modes of travel. Combined with
significant landscape, heritage and potential biodiversity impacts, the site is
unsuitable for recreational development and allocation in the
Neighbourhood Plan.
SS0239
SS0239 Land south of Bentley Road, East Bergholt
Site Reference
SS
0239
Site Address
Land south of Bentley Road, East Bergholt
Site Source
BMSJLP SHELAA October 2020
Gross Site Area (Hectares) 1.11 (AECOM estimate)
Proposed Development Residential development
BMSJLP SHELAA October 2020 Assessment Summary
Conclusion
Discounted – Site has poor access to core services and facilities and has
poor connectivity to the existing settlement.

A subsequent addendum published in September 2021 during the
examination period provides the full suitability assessment work for the
discounted sites. It shows that the site is unsuitable as it is in the open
countryside and not well related to the existing settlement or facilities in
townscape and accessibility terms (no continuous footpath to the site).

Other identified constraints of the site include the need for HRA screening
assessment for potential biodiversity impact, potential impact on listed buildings located approximately 100m away to the southwest , as well as
potential impacts on the highways network.
How can these conclusions be applied to the Neighbourhood Planning Site Assessment?
Has the site been excluded or
assessed as unsuitable due to
size?
No
Does more recent or additional
information now exist which could
change the HELAA findings?
• The site is removed and disconnected from the built up area boundary
of East End (East Bergholt).
• The site has been recently considered for a full planning application (DC/18/00235) in which the application was refused and appeal
dismissed in May 2018 for the erection of 9 no. dwellings, construction
of new vehicular access and improvements to existing agricultural
access; and demolition of outbuilding at Manor Farm House and
erection of cartlodge and demolition of modern agricultural building.

The main reason for refusal is that residential development for 9
dwellings would not be appropriate in this location due to its poor
accessibility to regularly-required services and facilities and relatively
high degree of private car use dependency. The site is located on the
opposite side of East End separated by a stretch of highway that runs
through an intervening gap of mainly undeveloped countryside, far
removed from the Built Up Area Boundary. While the site is adjacent to
a public house, there are no other services within the housing cluster East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 81

next to the site. Further facilities in East Bergholt and surrounding
villages are not connected via a safe pavement network, with the
nearest bus stop to the site in a significant distance away that is not
conveniently accessible by foot.

• The site falls within 800m of the Focal Point under Policy EB2 of the
‘made’ East Bergholt Neighbourhood Plan.

• The site is wrapped by the AONB to the north and east although it is
relatively enclosed by existing boundary vegetation.
• The site consists of Grade 3 Good to Moderate Quality Agricultural
Land
• The Historic Landscape Study of East Bergholt and the Cultural Legacy
of John Constable (November 2020) identifies the site as one of the
Areas of Potential Archaeological and Historical Sensitivity (Area C). A
rea C is described to have played a significant in the development of
the settlement pattern within the parish, with the openness of the
landscape and the lack of built form within this part of the Parish
reflecting its medieval origins. The assessed site, in particular, is
identified to be historically significant as the site of medieval manorial
site (Manor Farm). The site is within Parcel 20 which is identified to be
of medium landscape and heritage sensitivity to development. This
means that Parcel 20 may be a potential location for development (the
scale of development would be subject to further detailed assessment
but may range between the maximum of 15 to 25 units) in landscape
and heritage terms if accompanied by significant mitigation measures.
Are there any concerns that the
HELAA conclusion is reasonable
and defensible?
No
Are the HELAA conclusions
reasonable to be carried
forward to the Neighbourhood
Plan Site Assessment?

Yes
In the Neighbourhood Plan context, is the site suitable (Y/N); is the site available (Y/N); is the site achievable (Y/N)
The site is outside of and disconnected from the built up area boundary of
East End. It is also at a remote and unsustainable location with limited
accessibility to regular services apart from a local pub. Development of the
site will be in contrary to Policy CS2 and CS15 of the Babergh Local Plan
Core Strategy and Policies and Policy EB2 of the ‘made’ East Bergholt
Neighbourhood Plan. The site is therefore unsuitable for residential or
recreational development and allocation in the Neighbourhood Plan at
present.
The site is a non-designated historically significant medieval manor adjacent to the AONB. Development of the site as a large scale solar farm
may lead to a loss of tranquillity and harm the sensitive historic and rural landscape character. The site falls within the SSSI Impact Risk Zone where all solar schemes with a footprint larger than 0.5 Ha would need to be
consulted with Natural England on its impact on biodiversity. In line with the
Planning Practice Guidance on Renewable Energy and Low Carbon
Energy and draft Policy LP27 of the draft Babergh and Mid Suffolk Joint
Local Plan, the site is unsuitable for development and allocation as large
scale solar farms in the Neighbourhood Plan.
SS0432
SS0432 Land south of Willets Pond, East Bergholt
Site Reference
SS
0432
Site Address
Land south of Willets Pond, East Bergholt
Site Source
BMSJLP SHELAA October 2020
Gross Site Area (Hectares) 2.10 (AECOM Estimate) East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 82

Proposed Development Residential development
BMSJLP SHELAA Assessment Summary
Conclusion
Discounted – Site has poor access to core services and facilities.
Largescale development of the site is likely to have a detrimental impact on
the AONB.
A subsequent addendum published in September 2021 during the examination period provides the full suitability assessment work for the discounted sites. It shows that the site is unsuitable as it relates poorly to
local services (with no safe continuous footpath to other services) and is located within the AONB.

Other identified constraints of the site include unclear access, potential
impact townscape as development would represent an unnatural and isolated extension into the open countryside, the need for HRA screening
assessment for potential biodiversity impact, potential impact on listed
buildings to the west, as well as potential impacts on the highways
network.
How can these conclusions be applied to the Neighbourhood Planning Site Assessment?
Has the site been excluded or
assessed as unsuitable due to
size?
No
Does more recent or additional
information now exist which could
change the HELAA findings?
• The site is in the open countryside removed from the built up area
boundary of East Bergholt. The site falls outside of the 800m zone of
Focal Point under Policy EB2 of the ‘made’ East Bergholt Neighbourhood Plan.
• The site falls within the SSSI Impact Risk Zone. Any development that
would result in a net gain in residential units would need to be
consulted with Natural England. Part of the site (south) consists of
priority habitats (deciduous woodland).
• The Historic Landscape Study of East Bergholt and the Cultural Legacy
of John Constable (November 2020) identifies the site to be of high
landscape and heritage sensitivity, meaning that it is unlikely for any
development to be appropriate except for individual plots in very
specific locations.
Are there any concerns that the
HELAA conclusion is reasonable
and defensible?
No
Are the HELAA conclusions
reasonable to be carried
forward to the Neighbourhood
Plan Site Assessment?

Yes
In the Neighbourhood Plan
context, is the site suitable
(Y/N); is the site available (Y/N);
is the site achievable (Y/N)
A greenfield site located at an environmentally sensitive location in close
proximity to the Stour and Orwell Estuaries SPA and Ramsar and within
the AONB. It is in the open countryside at a remote location disconnected
from the main settlement clusters of East Bergholt. Paragraph 80 of the
NPPF seeks to avoid the development of isolated homes in the countryside
unless one or more of the exceptions apply. No evidence has been
received in relation the exception criteria. The site is therefore unsuitable
for housing, recreational development or solar farm development and
allocation in the Neighbourhood Plan at present.
The site was confirmed as available for residential development in 2020 and no information to the contrary has been received since. Availability for
other land uses is unknown at present.
SS0829
SS0829 Land south of Quintons Corner, East Bergholt East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 83

Site Reference
SS0829
Site Address
Land south of Quintons Corner, East Bergholt
Site Source
BMSJLP SHELAA October 2020
Gross Site Area (Hectares) 1.34 (AECOM Estimate)
Proposed Development Residential development
BMSJLP SHELAA Assessment Summary
Conclusion
Discounted – The site would have a detrimental impact on sensitive
historic and natural environments, which cannot be reasonably mitigated or
compensated. Development of the site would result in a loss of designated
open space, which is either not surplus to requirement.

A subsequent addendum published in September 2021 during the
examination period provides the full suitability assessment work for the
discounted sites, which confirms the site as unsuitable. Other identified
constraints of the site include impacts on the site as an important visual
setting for the village (identified in the Local Plan and Neighbourhood Plan
as an area of visual importance), impact to the townscape setting of local
area along Quintons Road, the entire site is covered by Tree Preservation
Order, negative impact upon adjacent listed buildings, poor accessibility to
local shops and potential impacts on the highway network.
How can these conclusions be applied to the Neighbourhood Planning Site Assessment?
Has the site been excluded or
assessed as unsuitable due to
size?
No
Does more recent or additional
information now exist which could
change the HELAA findings?
• The site entirely comprises of priority habitats (Deciduous Woodland)
where its loss is unavoidable if developed. Development of the site
would be in contrary to Paragraph 180 of the National Planning Policy
Framework which states that Local Planning Authorities should refuse
planning permission if significant harm to biodiversity resulting from a
development cannot be avoided (through locating on an alternative site
with less harmful impacts), adequately mitigated, or, as a last resort,
compensated for.
• The site is located within the built up area of East Bergholt and the 800m zone of Focal Points identified under Policy EB2 of the ‘made’
East Bergholt Neighbourhood Plan
• The site is designated as a Local Green Space under Policy EB7 of the ‘made’ East Bergholt Neighbourhood Plan (LGS 1 Box Iron off Quintons
Road). It is also identified as an area of visual and amenity value under
saved Policy CN03 of the Babergh Local Plan although this allocation has not been taken forward in the emerging Babergh and Mid Suffolk Joint Local Plan. Development of the site would result in the total loss
of the Local Green Space.

• The Historic Landscape Study of East Bergholt and the Cultural Legacy of John Constable (November 2020) identifies the site to be of medium
to high landscape and heritage sensitivity. In particular, the assessment states that the historic settlement of the triangular green at Gaston’s
End, known as the ‘Box Iron’ and interrelationship with surrounding
historic buildings should be better recognised with origins as a
medieval hamlet. The green, which is the site in concern, should be
protected from further encroachment and landscape management to
strengthen the visual connection into the green and if possible be made
publicly available. Gastons End is also identified as one of the Areas of
Potential Archaeological and Historical Sensitivity.
East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 84

Are there any concerns that the
HELAA conclusion is reasonable
and defensible?
No
Are the HELAA conclusions
reasonable to be carried
forward to the Neighbourhood
Plan Site Assessment?

Yes
In the Neighbourhood Plan context, is the site suitable (Y/N); is the site available (Y/N); is the site achievable (Y/N)
The site is a designated Local Green Space and Area of Visual and
Amenity Value within the built-up area of East Bergholt in close proximity to
a number of designated heritage assets. The site entirely comprises of
priority habitats (Deciduous Woodland) where its loss is unavoidable if
developed. These trees are also protected under the Tree Preservation
Order. Development of the site would be in contrary to Paragraph 180 of
the National Planning Policy Framework which states that Local Planning
Authorities should refuse planning permission if significant harm to
biodiversity resulting from a development cannot be avoided (through
locating on an alternative site with less harmful impacts), adequately
mitigated, or, as a last resort, compensated for. Development of the site
would have a detrimental impact on sensitive historic and natural
environments, which cannot be reasonably mitigated or compensated, and
would also result in the loss of a designated open space. The site is
therefore unsuitable for development and allocation as housing,
recreational development or solar farms in the Neighbourhood Plan at
present.
The site was confirmed as available for residential development in 2020 and no information to the contrary has been received since. Availability for
other land uses is unknown at present.
SS1182
SS1182 Land north west of Quintons Road
Site Reference
SS11
82
Site Address
Land north west of Quintons Road
Site Source
BMSJLP SHELAA October 2020
Gross Site Area (Hectares) 0.47 (AECOM Estimate)
Proposed Development Residential development
BMSJLP SHELAA Assessment Summary
Conclusion
Discounted – Site does not front a public highway.

Other identified constraints of the site include poor accessibility to primary
school, loss of Grade 2 agricultural land, potential landscape sensitivity,
potential impacts on the Natura 2000 sites, as well as potential impacts on
the historic environment (including archaeological site and Grade II listed
buildings to the south).
How can these conclusions be applied to the Neighbourhood Planning Site Assessment?
Has the site been excluded or
assessed as unsuitable due to
size?
No East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 85

Does more recent or additional
information now exist which could
change the HELAA findings?
• The site is of low to medium landscape capacity (Parcel A) to
accommodate built development as identified in the East Bergholt
Landscape Capacity Appraisal. The assessment suggests that while
development on the parcel would relate well to the settlement edge, it
would have the potential to have a significant influence on visual
amenity as a result of the open nature of the surrounding landscape.
• The Historic Landscape Study of East Bergholt and the Cultural Legacy
of John Constable (November 2020) identifies the site to be of medium
to high landscape and heritage sensitivity. Gastons End is also
identified as one of the Areas of Potential Archaeological and Historical
Sensitivity.
• The site is partially adjacent though not connected the built up area
boundary of East Bergholt. It is within the 800m Focus Area Zone
identified under EB2 of the ‘made’ East Bergholt Neighbourhood Plan.
• The site is in close proximity to the committed residential development
at SS0181 but there are no significant highways improvements
proposed for the private lane north of SS1182.
Are there any concerns that the
HELAA conclusion is reasonable
and defensible?
No
Are the HELAA conclusions
reasonable to be carried
forward to the Neighbourhood
Plan Site Assessment?

Yes
In the Neighbourhood Plan
context, is the site suitable
(Y/N); is the site available (Y/N);
is the site achievable (Y/N)
A greenfield site partially adjacent though not connected to the built up
area boundary of East Bergholt. The site does not front a public highway
and therefore suitable access could not be achieved at present. In addition,
development of the site may also have significant impacts on the visual
and landscape character of East Bergholt. The site is therefore unsuitable
for development and allocation as housing, recreational development or
solar farms in the Neighbourhood Plan at present.
The site was confirmed as available for residential development in 2020
and no information to the contrary has been received since. The site is not
indicated to be available for other proposed uses at present.

SS1197
SS1197 Land west of Hadleigh Road, East Bergholt
Site Reference
SS11
97
Site Address
Land west of Hadleigh Road, East Bergholt
Site Source
BMSJLP SHELAA October 2020
Gross Site Area (Hectares) 0.85
Proposed Development Residential development (10 dwellings)
BMSJLP SHELAA October 2020 Assessment Summary
Suitability
Site is potentially suitable, but the following considerations would require
further investigation: Highways – regarding access, footpaths and
infrastructure required. Heritage – potential impact upon Conservation Area
and heritage assets. Biodiversity – potential impact on ecological sensitive
areas.
Availability
Site in single family ownership with a developer option on the land and a
planning application submitted (currently undetermined at the time of
assessment). Site is available for development in the short term, as
evidenced by a planning application East Bergholt Neighbourhood Plan Site Options and Assessment Prepared for: East Bergholt Parish Council (the Qualifying Body) 86

Achievability
Now planning permission has been granted, a development scheme is
expected to be implemented.
Conclusion
The site is potentially considered suitable for residential development
(10 dwellings), taking identified constraints into consideration. At the time
of assessment the site is subject to a planning application, which has not
been determined.
How can these conclusions be applied to the Neighbourhood Planning Site Assessment?
Has the site been excluded or
assessed as unsuitable due to
size?
No
Does more recent or additional
information now exist which could
change the HELAA findings?
The site has been allocated for 10 dwellings (LA061) in the draft Babergh
and Mid Suffolk Joint Local Plan currently under examination. However,
correspondence between the Babergh and Mid Suffolk District Councils
and the Inspectors in December 2021 has agreed that the proposed
housing allocation policies will be deleted from the emerging Local Plan
moving forward as it is found unsound at present.

The site has a granted planning permission (B/15/01678) for the erection of
10 single-storey dwellings for the over 55s, along with refuse,
bicycle/gardeners store buildings and associated landscaping work since
November 2017.
As the planning permission has been granted, the site would not need to
be all
ocated in the Neighbourhood Plan (although support for development
at this location could be demonstrated through an allocation). Further
assessment in this SOA is not required.
Are there any concerns that the
HELAA conclusion is reasonable
and defensible?
No
Are the HELAA conclusions
reasonable to be carried
forward to the Neighbourhood
Plan Site Assessment?

aecom.com

East Bergholt Parish Council

East Bergholt Parish Council

Aecom 230109 East Bergholt Site Options and Assessment Final Report.pdf

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East Bergholt
Parish Council