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

Part 1 - developing a spatial strategy

Part 1. 5. Strategic issues for West Suffolk

5.1. This part of the document identifies the strategic issues that will sit at the heart of the new local plan.

5.2. Paragraph 21 of the NPPF emphasises that strategic policies should be limited to those necessary to address the strategic priorities of the area. It is these policies which will set the context for the development of any local policies which may be required.

5.3. Strategic policies in the WSLP will set out the strategy establishing the pattern, scale and quality of development as well as making provision for development, infrastructure, community facilities and the conservation and enhancement of the natural and built environment where these issues relate to strategic priorities.

5.4. By analysing the strategic framework priorities, the vision and the strategic objectives for the area, we have identified the following draft strategic issues for West Suffolk:

  • Strategic issue 1: Climate change.
  • Strategic issue 2: The right homes for our communities.
  • Strategic issue 3: Economic growth and provision of strategic infrastructure.

Strategic Issue 1: Climate change

5.5. The impacts of climate change are seen and felt increasingly by us all, and the need to halt and reverse these changes is becoming ever more urgent. An increase in air temperature and severe weather events have direct and consequential effects on the local environment leading to changes in water supply, air pollution, overheating, the natural environment, biodiversity and flooding.

Claas, Saxam (2020)
Claas, Saxham (2020)

5.6. In June 2019 the government committed the UK to bring all greenhouse gas emissions to net zero by 2050. The NPPF sets out the purpose of the planning system as being to contribute to the achievement of sustainable development, and goes on to set out three overarching objectives: economic, social and environmental. The latter is a holistic and specific approach to planning in an environment that has seen rapid climate and weather changes.

5.7. West Suffolk Council declared a climate emergency in September 2019 recognising that climate change needs to be tackled as a matter of urgency. In July 2019 the council set up a task force to research and recommend actions and initiatives to address the climate emergency and propose practical solutions, investments and actions. This includes building on work already being undertaken in the district and developing and appraising options for the actions the council would have to take to be net-zero carbon by 2030, and drawing up new policies to ensure mitigation and adaptation measures are implemented to halt and where possible reverse the detrimental impacts of climate change.

Strategic Issue 2: The right homes for our communities

5.8. Nationally, the government is aiming to increase house building and delivery which is emphasised in the 2019 NPPF. The council has the responsibility of setting the district's housing requirement, which shows how many homes need to be provided over the plan period. The minimum number of homes needed is calculated using the standard method set out in national planning guidance, unless exceptional circumstances justify an alternative approach which reflects current and future demographic trends and market signals. The standard method uses a formula to identify the minimum number of homes expected to be planned for, which addresses projected household growth and historic under-supply. In addition, it should also take into account any unmet needs which cannot be met by neighbouring authorities.

  • The national standard method of assessing housing need currently gives the district a minimum figure of 800 new dwellings needing to be built each year.
  • We have calculated our current housing need using the standard methodology.
  • Simply multiplying 800 homes by the plan period of 20 years would result in a minimum need of some 16,000 new homes.

5.9. However, this figure should be treated with caution as the local housing need (LHN) figure is derived from household projections and affordability ratios which may be subject to change. Given the uncertainty over how this LHN will change in the future and the fact the figure is a minimum, the overall requirement for the plan period to 2040 is expected to be higher than 16,000 new homes. National planning practice guidance advises strategic policy making authorities to calculate a need figure at the start of the plan making process and keep this under review and revise where appropriate.

5.10. Notwithstanding the need to undertake further work to inform the assessment of a housing need figure, there are some 8,100 homes in the pipeline (sites with planning permission at 1 April 2020) and if the 5,300 homes allocated in existing local plans are taken forward into the plan review they would reduce the number of new homes that need to be planned for to a minimum of  2,600 homes.

5.11. The Government's standard methodology for calculating the district's housing need makes clear that providing fewer homes than the headline figure of 16,000 is not an option. Some other local authorities are planning for a range in setting their housing requirement in order to build in flexibility.

5.12. Where previous assessments of housing delivery or need are significantly greater than the LHN authorities are advised to consider whether to plan for a higher level of need.

5.13. Past annual delivery since 2011 shows the combined rates of the former Forest Heath and St Edmundsbury areas were lower than the LHN, averaging 637 dwellings per annum (dpa), whereas local plan annual targets when combined show a higher need than the LHN at 886dpa.

5.14. Assessing housing need is the first step in the process of deciding how many homes need to be planned for which then informs the setting of a housing requirement figure.

5.15. There is now an opportunity to consider whether we should plan for the standard methodology with an appropriate buffer to ensure a continuous supply of housing land comes forward or whether an alternative approach should be taken. The draft preferred options stage of the local plan will then consult on a preferred housing requirement figure.

(Nelson Road Bury St Edmunds)
Nelson Road, Bury St Edmunds (2019)

Strategic Issue 3: Economic growth and provision of strategic infrastructure

5.16. West Suffolk has a diverse and successful local economy, but one where wage levels are lower than the national average, yet income for residents as a whole is close to the national average. Higher residents' wages are indicative of out-commuting to higher wage economies, particularly Cambridge. As a consequence, those residents who work in the district receive lower wages but are exposed to high housing costs within West Suffolk.

5.17. However, despite the amount of out-commuting West Suffolk is a net importer of employment. This presents challenges including issues such as traffic congestion at peak times in our towns and at key junctions on the A11 and A14. A particular issue is the conflict in the use of the A14 as a major intercontinental freight route connecting Felixstowe and Harwich with the remainder of the country and its use by local traffic. More detail on transport infrastructure is provided in part two of this document.

5.18. The main employment sectors include the horseracing industry, agriculture including agricultural services, food and drink (Greene King Brewery, British Sugar, food processing, and so on.), biotech, public service (particularly West Suffolk Hospital, and the prison), civilian employment at the airbases, manufacturing (engineering, pharmaceuticals and electronics), and retail and leisure.

5.19. To maintain a balanced economy it will be important to provide the right sites to enable a wide range of business growth in the district, whether by attracting new inward investment from businesses located outside West Suffolk or allowing existing businesses within the district to expand.

5.20. It will also be important to support and enable attainment of higher education and skill levels in young people - those that will contribute to the growth and diversity of the local economy in the future. Although the percentage of 16 to 64 year olds who were economically active (September 2018), and the percentage of residents over the age of 16 with qualifications of at least NVQ level 1 or equivalent in West Suffolk are both higher than the average for England (82.90 per cent to 78.70 per cent, and 87.5 per cent and 85.5 per cent respectively) the percentage of young people achieving a 9-4 pass in both English and maths GCSE between 2016 to 2017 was lower at 62.10 per cent compared with 64.20 per cent.

5.21. West Suffolk is predominantly rural in character, covering a wide geographic area. Much of the district is located away from the primary route network and has limited access to very high-speed broadband facilities. This can limit the opportunities for rural enterprise, or limit home working and the need to travel, so we need to work with providers to enable better provision and wider coverage to sustain and grow economic activity in the rural area.

Local plan options

5.22. The following section sets out the options for consideration and comment at this early stage in the preparation of the local plan. The options for consultation include six types of place for West Suffolk, a draft settlement hierarchy and options for the distribution of growth across the district.

Types of place and settlement hierarchy

Little Wratting, Haverhill (2019)
Haverhill (2019)

5.23. A settlement hierarchy is an important tool that categorises settlements according to the range of services and facilities they offer, reflecting their level of sustainability.

5.24. Settlements at the top of the hierarchy play a key role within the district, providing services used by a wide catchment area with good transport links. At the lower end of the hierarchy are those settlements which have few services and facilities and are more isolated in respect of transport links. New development should generally be accommodated in those settlements which can meet some of the population's day-to-day needs and reduce the need to travel.

5.25. As a first stage in developing a new draft settlement hierarchy for the local plan a study has been undertaken to assess the sustainability of settlements through reviewing the provision of services and facilities. The background to this work is set out in the 2019 sustainable settlements study which is published as evidence alongside this document.

5.26. The sustainability indicators were used to rank settlements according to the number of sustainability features they possess. It is important to recognise that this exercise represents the situation at a point in time and the services and facilities could change, an issue that will be kept under review as the local plan progresses.

5.27. A matrix showing the results is included as appendix 2, with further detail set out in the 2019 sustainable settlements study. The matrix ranks the settlements in terms of highest and lowest scores awarded for each sustainability indicator.

5.28. The assessment has shown that it is the larger settlements which have the most services and facilities and are therefore the most sustainable. The smaller villages tend to have fewer services and additional growth in these locations would most likely result in increased use of the private car. However, the 2019 NPPF clearly recognises that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services (NPPF, para 78).

5.29. The current settlement hierarchies in the former St Edmundsbury and Forest Heath areas set a limit to growth in rural areas by only allowing the allocation of development sites in the top three types of place in the hierarchy. There is now an opportunity to review that approach and explore the option of identifying additional types of place where rural allocations could be made. This would allow more small sites to be identified in villages with some services and facilities that meet the day to day needs to residents.

5.30. On this basis, we have identified six potential types of place for West Suffolk in the draft hierarchy, from most to least sustainable:

  • Towns
  • Key service centres
  • Local service centres
  • Type A villages
  • Type B villages
  • Countryside

5.31. The types of place and their characteristics are discussed in further detail below:

Town

5.32. Provides a range of employment opportunities and higher order services and facilities, education, community and health facilities with good bus and/or rail access to the wider area. The opportunity for site allocations will be explored through the local plan.

Key service centre

5.33. As a minimum will have a primary school, a public house, a convenience shop and a play area. These are the largest settlements, in terms of population, outside of the towns and provide a number of key services and facilities that meet the settlements' own needs, and the needs of other nearby smaller settlements. The opportunity for site allocations will be explored through the local plan.

Local service centre

5.34. As a minimum, will have a primary school and a convenience shop. These settlements tend to have a few of the key services and facilities. The opportunity for site allocations will be explored through the local plan.

Type A village - suggested new type of place

5.35. These villages have a more limited range of services and facilities but can still meet some of the day to day needs of their residents and/or lie within two kilometres of a town with the opportunity for sustainable access. The opportunity for site allocations will be explored through the local plan.

Type B village

5.36. These settlements have a very limited range or no services and poor accessibility to public transport. It is likely that residents will rely on the private car to travel to meet their day to day needs. These settlements have a boundary, but no sites will be allocated through the local plan.

Countryside

5.37. Will contain small rural settlements with few or no services. Settlements will have no boundary and no sites will be allocated through the local plan.

Draft settlement hierarchy

5.38. On the basis of the exercise to determine the sustainability of settlements, their ranking in the matrix (Appendix 2) and the type of place, a draft settlement hierarchy for West Suffolk is set out in the table below.

Towns

Key service centres

Local service centres

Type A villages

Type B villages

Brandon

Barrow

Bardwell

Barnham

Bradfield St George

Bury St Edmunds

Clare

Barningham

Barton Mills

Chevington

Haverhill

Ixworth

Beck Row

Chedburgh

Coney Weston

Mildenhall

Kedington

Cavendish

Fornham All Saints

Cowlinge

Newmarket

Lakenheath

Exning

Fornham St Martin

Elvedon

 

Red Lodge

Great Barton

Freckenham

Eriswell

 

Stanton

Great and Little Whelnetham

Great and Little Thurlow

Gazeley

   

Hopton

Honington and Sapiston

Great Bradley

   

Hundon

Horringer

Hargrave

   

Moulton

Icklingham

Hawkedon

   

Rougham

Ingham

Hepworth

   

West Row

Kentford

Holywell Row

   

Wickhambrook

Pakenham

Lidgate

     

Risby

Lord's Walk

     

Stoke by Clare

Market Weston

     

Stradishall

Ousden

     

Troston

RAF Honington

     

Tuddenham

Rede

     

Worlington

Stanningfield

       

Stansfield

       

Thelnetham

       

Whepstead

       

Withersfield

Broad options for distribution of growth

5.39. The former Forest Heath and St Edmundsbury areas have adopted local plans which set out long term strategies for the distribution of housing growth up to 2031. The West Suffolk Local Plan will bring forward a new strategy for the distribution of growth from now until the year 2040. The table below illustrates how the current 2010 strategies distribute housing growth across West Suffolk in the currently adopted local plans.

Towns Rural area (outside the towns)
16,244 homes 6,658 homes
71% 29%






(Information taken from former FHDC Single Issue Review Policy CS7 and former SEBC Core Strategy Policy CS1)

Draft settlement hierarchy

5.40. There are a number of factors that need to be taken into account when considering options for distribution, including the proposed settlement hierarchy, environmental and infrastructure capacity constraints, and available sites in the strategic housing and economic land availability assessment (SHELAA) which is prepared in order to give a clear understanding of housing and economic land available in the district, taking into account the sites availability, suitability and achievability.

5.41. At this early stage in the plan making process, a number of broad sustainable options for growth need to be tested before progressing to a preferred sustainable development strategy for the district. In order to plan for additional homes needed we have considered a range of draft broad distribution options. It is important to note that as the plan progresses and consultation responses are analysed, the final distribution option is likely to be a combination of the options outlined below.

5.42. It is important that the options are realistic and deliverable and based on the following:

  • The high number of environmental constraints across the district.
  • The need for the distribution of growth to accord with national planning policy.
  • That each option should deliver the necessary infrastructure required as a result of the growth.
  • The availability of suitable land to meet the distribution options, including new sites; the existing site allocations in the currently adopted local plans for the former Forest Heath and St Edmundsbury areas that are carried forward to the West Suffolk Local Plan; and existing commitments (sites with planning permission).

5.43. The draft distribution options, along with the opportunities and challenges of each option are set out below:

Option 1: Focus growth on new settlement(s) which would be of a sufficient scale to support new community infrastructure and employment

5.44. The NPPF, at paragraph 72 indicates that "The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities."

5.45. New settlements are being explored and proposed as options for growth in many local authority areas, and one or more new settlement could be an option for future growth in West Suffolk.

5.46. A stand-alone new settlement would need to comprise a minimum of 3000 homes and be located on a primary road or rail network with good accessibility to one of the towns. Consequently, with this option, comparatively low levels of growth would need to be planned for in the remainder of the district.

West Suffolk Growth Option 1
Distribution of growth - option 1

Opportunities

Challenges

Opportunities for creating walkable neighbourhoods, and integrated active travel and sustainable transport networks.

Suitable land in a suitable location needs to be available.

Minimises growth in existing towns and villages.

Delivery of the first phase of the new settlement isn't likely to be achieved until the latter years of the local plan period, so would need to be combined with growth in other location to ensure a consistent supply of housing.

Greater potential for cost effective low carbon energy networks.

Lack of strategic infrastructure - viability, cost and delivery issues?

A sustainable new settlement can provide a positive impact on health and wellbeing through planned provision of green spaces and services and facilities.

Impact on road network, greater congestion and potential for higher carbon emissions.

Opportunity for more organic growth and delivering town scale facilities with village identities.

Potential loss of large area of agricultural land and landscape impacts.

Opportunity to closely locate homes and jobs.

Planning for lower housing growth elsewhere may reduce the amount of affordable housing that can be delivered and compound existing affordability issues.

Opportunity for net environmental gains.

 

Opportunity to deliver homes beyond the plan period (after 2040) and will also meet needs of the next local plan.

 

Option 2: Focus development in the towns and key service centres where infrastructure and environmental constraints allow

5.47. This option would result in the majority of growth being directed to the towns and the larger villages, with low growth across the remainder rural parts of the district.

Distribution of growth (Option 2)
Distribution of growth - option 2

Opportunities

Challenges

The towns and larger villages are the most sustainable locations for new growth with optimum access to facilities/healthcare/leisure and cultural facilities.

The options for further growth in Brandon, Newmarket and Mildenhall may be limited due to lack of available sites/environmental and other constraints which means that town growth may need to be concentrated in the central south area of the district in Bury St Edmunds and Haverhill.

Infrastructure provision is already in place/planned in these locations which can be maximised through additional growth.

Intensifies the need for additional infrastructure and services and facilities - what are the cost and delivery issues?

Population and workforce are closely linked.

Market signals - can the towns absorb this level of growth?

Opportunities for transport connectivity/growth of sustainable transport options. Greater usage improves viability.

Focussing on the towns and larger villages could undermine the economy and vibrancy of the rural areas and cause increased use of the car as people look to the towns to meet their day to day needs.

Minimises the impacts on environment and landscape on many parts of the rural area.

Long lead in times for development of large sites would mean that housing may not be delivered until later in the plan period.

Greater potential for cost effective low carbon energy networks.

Impact on health and wellbeing through air quality from increased car use, loss of green space on the urban edge.

Opportunity for net environmental gains.

Challenges of integrating new and existing communities.

environments constraints and agricultural land are safeguarded.

Impact on road network, greater congestion and increased travel times.

 

Planning for lower growth in the smaller villages will limit the  amount of affordable housing that can be delivered and compound existing affordability issues.

 

Impact on landscape character on the urban fringe and ability to preserve important landscape gaps.

 

Provides less opportunity for smaller sites to come forward, which are important in ensuring a continuous supply of housing land.

Option 3: Focus growth on the towns, key service centres and local service centres through urban extensions and infilling where infrastructure and environmental constraints allow

5.48. This option would mean that growth would be concentrated in the towns, the key service centres, local service centres and larger villages where constraints allow. Consequently, there would be comparatively low levels of growth in the remainder of the rural area.

Distribution of growth (Option 3)
Distribution of growth - option 3

Opportunities

Challenges

The towns are the most sustainable locations for new growth with optimum access to facilities/healthcare/leisure and cultural facilities. After the towns, the key service centres and local service centres are the next most sustainable settlements providing opportunity for sustainable growth.

The opportunities for further growth in Brandon, Newmarket and Mildenhall and some of the key service centres may be limited due to lack of available sites, environmental and other constraints which means that growth may need to be concentrated in the central south area of the district in Bury St Edmunds and Haverhill and in those key service centres which are suitable to take more growth.

Infrastructure provision is already in place/planned which can be maximised through additional growth.

Bury St Edmunds and Haverhill have relatively high levels of growth already planned and committed which means that the market may not be able to absorb the proportion of further growth necessary under this option.

Population and workforce are closely linked.

Focussing on the towns and larger villages could undermine the economy and vibrancy of settlements in the rural area and lead to possible loss of services and facilities.

Opportunities for transport connectivity/growth of sustainable transport options. Greater usage improves viability.

Impact on health and wellbeing through air quality from increased car use, loss of green space on the urban edge.

Minimises the impacts on environment and landscape on many parts of the rural area.

Challenges of integrating new and existing communities.

 

Impact on road network, greater congestion and increased travel times.

 

Planning for lower growth in smaller villages will limit the amount of local needs housing that can be delivered and compound existing affordability issues.

Option 4: Disperse development around the district allocating sites across the towns, service centres and villages to allow them to grow where infrastructure and environmental constraints allow

5.49. This option would result in less growth in towns but some of the lower order villages such as local service centres and Type A villages will need to take higher levels of growth to ensure our housing need can be met.

22 - Distribution of growth (Option 4)
Distribution of growth - option 4

Opportunities

Challenges

Provides a level of development to support the growth of services and facilities in all sustainable settlements.

Challenges of providing appropriate infrastructure to support a dispersed pattern of growth.

Provides the opportunity to meet affordable housing needs across many settlements in the district.

Impact on road network, greater congestion and increased travel times.

Enables the creation of a rural network of clustered developments that are able to share services.

Impact on health and wellbeing through air quality from increased car use, loss of green space on the urban edge.

Enable smaller communities to grow and support existing services.

Some villages have a limited range of services and facilities which could mean a high level of car dependency and limited opportunities for and access to sustainable means of transport.

Maximise opportunity for smaller sites to come forward across the district, this supports housing delivery from small to medium size house builders which in turn supports local employment.

Some settlements may be unable to take their share of the growth due to environmental and infrastructure constraints and lack of available sites.

Smaller scale development can be more sensitively integrated into urban fabric of villages and delivered relatively quickly.

Potential loss of agricultural land.