B&MS Joint Local Plan: East Bergholt PC’s response to Reg 19 Consultation

East Bergholt Parish Council welcomes the opportunity to make its representation on Babergh’s
Joint Local Plan (the Plan) and wish to make the following points.

Strategic Considerations
1. The Plan has surprisingly changed little from the Reg18 consultation draft despite the
many thousands of consultee comments received on that version of the Plan.
2. We are concerned that the results of the extensive Sustainability Appraisal (SA)
conducted over summer 2020 by LUC are also not reflected in this Plan, resulting in the
adoption of a strategy which is not justified by the evidence base. The NPPF (2019)
requires that the Plan should provide a sustainable route map for the future, but in this
case the assessment of 9 different spatial strategies to direct Babergh’s growth over the
plan period, showed that the spatial strategy adopted ( Sustainable Transport Corridors)
is that only in name and, scores particularly poorly relative to two other options tested.
The SA also highlighted that the strategy will lead to increased car journeys and carbon
emissions, which conflicts directly with the LA’s Climate Change objectives and policy
stance. The SA also showed clearly that many of the site allocations in the Plan do not
score well on sustainability criteria but have nevertheless been retained.
3. The Plan’s strategy to guide growth and development along the A12 and A14 transport
corridors requires significant infrastructure improvements. Whilst this is acknowledged in
SP08, the strategy is flawed without the LA having the decision making power to allocate
strategic transport funding, and hence the ability to deliver the infrastructure investment
required. Capacity issues and safety issues at poorly specified junctions on this network
have lacked the necessary investment for many years and to base the Plan’s strategy on
the hope that the required funding will be granted by Highways England, particularly
when the public purse is empty, cannot surely be considered a robust approach.
4. The Plan’s evidence base and underlying assumptions have also, unfortunately,
effectively been rendered out of date by Brexit and Covid, neither of which are
referenced in the Plan. Both have potential to significantly impact the growth
assumptions in the Plan and alter the way we live and work. This comment was made in
respect of Brexit at the Regulation 18 consultation. The effects of both will likely endure
for many years and without an appraisal of these impacts the Plan is unlikely to be able
to offer an adequate policy response for the future.

East Bergholt Local Considerations
1. East Bergholt’s Neighbourhood Plan was approved in 2016 and has a minimum housing
requirement of 86 homes based on local need. The JLP SP04 Table 4 allocates 241
homes which will be more than enough for East Bergholt’s local need. The Plan adopted
a capacity led approach when allocating the District wide housing requirement. In East
Bergholt “the capacity” includes 3 sites (229 homes) which were the subject of
speculative applications in 2016/17 and which received planning consent as a departure
from the Development Plan at a time when Babergh lacked a 5YHLS, and the “tilted
balance” was invoked. However the NPPF (2019) recommends that local housing

allocations should be based on objectively assessed need. In this respect the Plan
appears to ignore NPPF guidelines by choosing an alternative capacity led approach,
which we wish to question as we did in our Reg 18 submission.
2. The Parish Council is working with Babergh in reviewing its Neighbourhood Plan. In this
regard it would be helpful if the Local Plan could make clear whether the three sites
allocated for housing represent strategic or non-strategic allocations. The designation
will be materially important in understanding the influence that our Neighbourhood Plan
revision might have over each of these sites.
3. The 4 Sisters Junction on the A12 is East Bergholt’s main access to the A road network.
However this junction fails to meet Highways England’s own safety standards. This
remains a well-documented issue and area of concern. However the Plan makes no
provision for improvements despite the planned growth of housing in East Bergholt and
surrounding villages and the significant increase in traffic volumes that will use this
junction, as East Bergholt’s Core village services provide for a rapidly growing
catchment.

Specific Policy Considerations
1. Tourism is an important component of the District’s economy, and the Plan’s policies are
clearly designed to manage the competing pressures that inevitably result from growing
tourist numbers. In some parts of the country an increasing number of second homes
and holiday homes have resulted in a surge in absentee landlords and second home
owners to the detriment of the local community and local economy. The Plan has no
explicit policy to limit or control this phenomena nor guidance on its position on second/
holiday homes as distinct from properties which are intended for short term holiday lets.
Whilst this phenomenon might not be seen as a big issue today, the area is recognised
as one which is highly attractive to visitors and there is evidence of a growing trend in
the provision of holiday accommodation, so a policy statement which can help guide and
manage second and holiday home development and use would be beneficial.
2. East Bergholt PC fully supports Babergh in its recognition of the Climate Emergency and
its target to become carbon neutral by 2030. The built environment is a major source of
greenhouse gases, but can equally help to offer a means of delivering a solution through
planning. Through encouraging alternative transport solutions and ensuring all
development is “green development” the Plan provides Babergh with a unique
opportunity. However, the Plan’s policies could push much harder by being more specific
and by mandating the change required of all development activity. For example SP10
requires “a proactive approach to mitigate and adapt….” and uses the word
“encouragement” of sustainable design and holistic water management systems, rather
than stating necessary and specific requirements. The same also partly applies in LP25.
It also appears that policies LP1-12 are not consistently requiring new development to
deliver energy savings in construction techniques and renewable energy systems. The
Parish Council believes that the Plan’s Climate Change Policies and alternative transport
solutions should ensure that the energy savings that result will be sufficient, and that in
framing each policy the requirements are explicit and unambiguous for all new

development, including the retrofitting of the existing stock, so as to enable Babergh to
meet its ambitious objectives.

East Bergholt Parish Council has considered the Plan’s policies in some detail and recommend
that these representations to Babergh DC on its Regulation 19 Draft, as set out above, can
accompany the Plan’s submission to the Secretary of State so that they might be considered
when the Plan is subject to its Examination in Public.