West Suffolk Local Plan (Regulation 18) Issues and Options October 2020

Part 1 - developing a spatial strategy

Part 1. 1. Introduction

What is a local plan and why do we need one for West Suffolk

1.1. A local plan provides a vision for the growth and development of an area and policies which set out the way that the plan aims to meet the housing, employment, social and community needs of an area while at the same time protecting and enhancing the natural, built and historic environment. Balancing growth and development with protecting and enhancing our environment is often referred to as sustainable development.

1.2. It is a statutory requirement that local authorities produce a local plan for their area and keep it up to date.

1.3. West Suffolk Council was formed from the former Forest Heath area and the former St Edmundsbury area, and came into being on 1 April 2019. The new council needs to start afresh and plan positively for the new, larger area.

1.4. National guidance is provided in the National Planning Policy Framework (NPPF, or sometimes referred to as the Framework). The NPPF requires local plans to be reviewed every five years to establish if a new plan is necessary, so our timeline starts with the creation of the new authority in 2019. The West Suffolk Local Plan (WSLP) will provide strategic and local policies that will enable and guide the delivery of sustainable growth to 2040.

Does the council already have a plan?

1.5. West Suffolk Council has 'inherited' the local plans that were prepared for and adopted by the former St Edmundsbury and Forest Heath councils. These existing documents include both strategic policies and policies specific to our local area. Preparing the WSLP will include reviewing existing planning policies, updating, deleting and adding where appropriate to our current context and future needs.

1.6. Much has changed since the two former authorities' local plans were prepared and adopted. The NPPF was substantially revised and republished in July 2018, and further revised (guidance on calculating local housing need) in February 2019. Neighbouring authorities in Suffolk, Essex and Cambridgeshire have published plans for growth that may impact shared infrastructure and have positive effects on the local economy, and the formation of West Suffolk Council will change the planning context as we go forward. Hargrave and Newmarket have made neighbourhood plans and a number of others are under preparation.

The local plan process

1.7. The local development scheme (LDS) sets out all the steps in the process of preparing a local plan with a timeline and milestones. The timeline is a live document and will be kept up to date during the preparation of the plan. In brief the process can be described in three stages:

  • This issues and options stage is the very beginning of the process of producing a plan for West Suffolk. Its scope is to identify the key strategic issues. The plan should address and set out options and initial ideas for the strategic policies in areas such as housing and economic growth and where the growth might take place (distribution), and the provision of strategic infrastructure.
  • Further research and studies need to be carried out to give us the evidence we need to develop strategic and local policies. This work and responses to this issues and options stage will contribute to the next stage, the preferred options draft of the plan. We anticipate that consultation on this next stage of preparing the plan will take place in 2021.
  • Responses to consultation on the second document will inform the submission draft of the local plan (anticipated publication date January 2022 and it is this draft, together with the responses to it that will be examined by an independent inspector appointed by the Secretary of State.

1.8. You will be able to have a say at each stage of plan preparation - this issues and options stage is just the beginning.

National Planning Policy Framework

1.9. The Government's planning policies for England are set out in the revised NPPF, February 2019. Guidance is provided in Planning Practice Guidance (referred to as the PPG), an online resource that sets out how development plans (a local plan is part of the development plan for the area) should be prepared and what must be taken into account and included in them.

1.10. The new plan must contribute towards achieving sustainable development and be supported by appropriate sustainability appraisal and habitats regulations assessment (see below), and must:

  • Include strategic policies that provide a strategy for the scale, pattern and quality of development.
  • Collaborate and cooperate with neighbouring local authorities and other bodies set out in legislation (such as the Local Enterprise Partnership, Natural England, and the Environment Agency) - this is known as the Duty to Cooperate.
  • Make provision for housing and economic growth, and adequate levels of infrastructure (including community infrastructure).
  • Use the standard method set out in national planning guidance to undertake a local housing need assessment to determine the minimum number of new homes needed.
  • Plan for the housing needs of different groups in the community, including affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to build their own homes.
  • Include policies that recognise the qualities of and protect, conserve and enhance the natural, built and historic environment.
  • Include planning measures to address climate change mitigation and adaptation.

Strategic planning and the duty to cooperate - working with others

1.11. As a Suffolk authority we have worked and will continue to work with all authorities in the county to address the future public service and development needs of residents and businesses. The Suffolk Growth Framework is a document has been produced collaboratively to bring together work being taken forward across the county into a single cohesive programme.

1.12. Many of the key strategic issues, such the need to build more houses, plan for economic growth and the improvement or provision of new infrastructure, cover much wider areas than West Suffolk. Some of these issues will be shared with different neighbours and bodies, and we will work towards preparing and maintaining statements of common ground as evidence of the duty to co-operate (as set out in the NPPF).

1.13. The map below shows West Suffolk and its neighbouring local authorities, and the main towns and transport links in the area. The main trunk roads and railway lines clearly show the importance of considering the economic, social and environmental issues that link neighbours, the cumulative impact of growth, and the benefits of joint and collaborative working to achieve better outcomes for the people that live and work in this area.

1.14. In terms of the geographical context of West Suffolk the main features are:

  • To the west - Cambridge including the Biomedical Campus and A1 to the West Midlands; East Cambridgeshire part of the Cambridge and Peterborough Combined Authority area and growing.
  • To the north - growth planned at Thetford, the A11 link to and from Norwich (and the extended link to Cambridge), the Brecks protected habitats and unique character.
  • To the east - considerable levels of growth proposed in the Babergh and Mid Suffolk Joint Local Plan along the A14 corridor from and including Stowmarket.
  • To the south - growth in and around the south of Cambridge; growth planned as part of the Braintree Local Plan (but connections poorer to the south), and Sudbury in Babergh to the south-east; and the issues and opportunities presented by the location of Felixstowe in terms of traffic and transport movements, and for added value businesses, warehousing and distribution.

1.15. The government is currently consulting on a reform to the planning system, which could affect the way Local Plans are prepared. The consultation proposals do not alter the requirement to maintain an up to date Local Plan which remains a fundamental part of the existing and the consultation proposals.  It is important for West Suffolk to continue with the Local Plan and your feedback to this consultation will inform the next stages of either the current system of plan making requirements or help prepare to deliver a ‘new system’ Local Plan.

1.16. The impacts of growth in the wider sub-region are shared across administrative boundaries, these include transport, energy supply, and water supply in an area of water stress, health services and education provision. It is important that we understand how these vital services can be delivered to enable sustainable growth without competing with our neighbours.

West Suffolk context plan
(West Suffolk District map)

Evidence base

1.17. We have started preparing the evidence that will provide the foundation for the policies in the West Suffolk Local Plan. Some of the studies will take time to research and prepare, and will be reviewed at later stages of the plan. The evidence will support specific policy areas but will also need to be considered as a whole as the plan is refined and advanced. Evidence studies will be published on the consultation system as they become available. The evidence base that has been prepared to support the issues and options local plan includes:

  • Sustainable settlements study - a study to identify those settlements in the district which would be the most appropriate to deliver sustainable growth and inform a new settlement hierarchy for the district.
  • Strategic housing and economic land availability assessment (SHELAA) - It is part of the evidence base which underpins the local plan and is required by the NPPF (paragraph 67). The SHELAA provides a clear understanding of the availability, suitability and achievability of sites in the plan area, but does not allocate land for development nor does it indicate that planning permission would be granted for development of a site.
  • Environmental constraints study - identifies the environmental and land use constraints in the district.

Scoping and sustainability appraisal

1.18. A sustainability appraisal (SA) is a [1] legal requirement and accompanies each stage of the local plan. This continuous appraisal process helps ensure the plan is in line with the aims of sustainable development. This is summarised in the NPPF as 'meeting the needs of the present without compromising the ability of future generations to meet their own needs'. The NPPF sets out three overarching objectives that the planning system needs to balance. It describes them as interdependent and needing to be pursued in mutually supportive ways. The three objectives can be summarised:

  • Social - supporting strong, vibrant and healthy communities, including ensuring sufficient numbers of homes are provided.
  • Economic - ensuring sufficient land is available to support growth.
  • Environmental - protecting and enhancing the natural, built and historic environment.

1.19. A SA scoping report has been prepared that provides baseline evidence on current and future characteristics and issues in West Suffolk. This provides the context and specific issues that help to identify the key issues when considering growth and development, and helps to establish the main sustainability objectives which will be used to appraise policy options as the plan progresses through the plan preparation process. The SA process will identify, describe and evaluate the likely significant economic, social and environmental effects of implementing both the plan and reasonable alternatives.

1. The Environmental Assessment of Plans and Programmes Regulations 2004 which transposes into national law the EU Strategic Environmental Assessment (SEA) Directive (sometimes referred to as SA/SEA). [back]

Habitats regulations assessment

1.20. The purpose of habitats regulations assessment (HRA) is to ensure that the policies and proposals in the plan are fully assessed and do not have a significant effect on any wildlife sites of international importance, often called Natura 2000 sites. In West Suffolk there are five such sites, however consideration is also given to Natura 2000 sites outside the district that could also be affected. While the Natura 2000 sites have been included as a constraint in the SA scoping report a HRA is not required at this initial issues and options stage of preparing the local plan. However, a HRA Report, setting out an initial evaluation of the plan's likely effects and confirming the range of issues which need to be considered, will be produced at the preferred options stage of plan making.

Impact of coronavirus (COVID-19)

1.21. The evidence base which supports the local plan will consider the land use impacts of coronavirus. For example in the assessment of transport and how we travel around the district, its impact on housing building and construction industry as well as how we can plan effectively for the future of our high streets and employment, health and leisure uses.

1.22. The true effects are not known and will evolve and change over time. Gathering this information will help us to prepare a local plan that is both flexible and adaptable to meet changing circumstances and ensure we have a strong basis for economic recovery.

About this consultation and how to respond

1.23. The statement of community involvement (SCI) (December 2018) sets out the variety of ways the community can be involved in the planning process. This consultation conforms to the standards set out in the SCI.

This is the beginning of the process of drawing up a local plan for West Suffolk. It is important to identify the key issues that have an impact on our area and the options that are available to us in planning for growth. No decisions have been made, and we don't have all the answers, so it is important for us to hear your views and comments so they can be taken into account and influence the next stages of the plan.

Look out for the questions throughout this document to have your say.

1.24. We have produced the following documents which are also available for comment during the consultation period:

  • West Suffolk Local Plan Issues and Options document (this document)
  • Sustainability Appraisal of Issues and Options document
  • Habitat Regulations Assessment (Screening) of Issues and Options document
  • Sustainable Settlements Study

1.25. When you are responding, please make it very clear which document you are commenting on. Please explain your answer and where appropriate provide evidence, alternative options or reasoned justification for your response. This will help us when we analyse the comments.

1.26. A glossary is included at Appendix 1 to provide definitions of technical terms.

1.27. The issues and options consultation period will run for 10 weeks from Tuesday 13 October to Tuesday 22 December 2020. You can respond in the following ways:

1.28. Due to the Coronavirus pandemic the issues and options consultation documents can only be viewed online. If you do not have access to a computer or the internet, please telephone Strategic Planning on 01284 757368 to speak with a planning officer who can advise on alternative ways of viewing the documents.

1.29. The planning strategy team will host a number of online events during the consultation period where you can come along and speak to us about this issues and options document and how the new local plan might affect you. Details of these sessions can be found on our website.

Next steps

1.30. All representations received in response to this consultation will be considered by the council when preparing the next stage of the plan which is called the preferred options draft. Further information and updates about the West Suffolk Local Plan will be published on the West Suffolk Local Plan page of the council's website as well as on the home page of the council's online public consultation system.

1.31. If you have any queries regarding any aspect of this consultation, please contact a member of the strategic planning team on 01284 757368 or email planning.policy@westsuffolk.gov.uk 

1.32. The next section sets out the background and context for a new local plan for West Suffolk and identifies some of the issues and challenges we face.

Data protection

1.33. We are collecting your personal information in order to process your comments under the Town and Country Planning (Local Planning) (England) Regulations 2012 and the Neighbourhood Planning Regulations 2012. Your name, address, (and all unredacted personal details as submitted by yourself), organisation, and comments may be passed to an independent planning inspector or examiner to consider the soundness legal compliance of the planning policy documents being produced. Apart from that your data will not be shared with third parties unless used for council purposes, in order to enquire and receive information relating to your comments, the prevention or detection of crime, to protect public funds or where we are required or permitted to share data under other legislation.

1.34. Your data will be kept until the document is superseded in line with our retention policy.

1.35. You have the right to access your data and to rectify mistakes, erase, restrict, object or move your data in certain circumstances. Your data will not be subject to automated decision making and processing. For further information on our data protection policies please go to our website: How we use your information or email: data.protection@westsuffolk.gov.uk 

1.36. Please note that all images in this document were taken prior to the coronavirus pandemic and therefore may not show compliance with current social distancing requirements.