ipswich.gov.uk

Comment

Representation ID: 25070

Received: 30/10/2017

Respondent: On behalf of EDF Energy

Regarding policy CS2, we propose that new development should also be encouraged within sustainable areas and there should be a preference for development on brownfield land. With regard to density, there should also be some flexibility with the application of density standards, depending on the character of the area and accessibility levels. In certain situations, outside of the town centre, it may be possible to achieve higher densities and each site should be assessed on a site specific basis. This approach is consistent the NPPF (paragraph 17), which encourages effective use of land.
Policy CS12 - We support the Council's approach in that the Council recognises that where it is difficult to meet the target for affordable housing provision, a lower amount of affordable housing or different tenure mix could be provided on a site, subject to viability testing in accordance with the NPPF. However, the policy does not provide for off -site affordable housing or commuted payments in lieu of on-site provision. It would be helpful to provide these alternative arrangements within the policy, especially where viability assessments support this approach as a preferred option.
Policy CS9 seeks to focus on brownfield land first whilst recognizing that greenfield land will need to be developed to meet the Boroughs housing need and forecasted job growth. This policy has been deleted. We therefore request that this policy be included as part of the emerging Local Plan as there is a priority to build on previously developed land, in line with paragraph 17 of the NPPF.
Policy CS17 - We request that any infrastructure to be secured or financed from new developments towards the provision of highways and transport; childcare, early years and education; health and emergency services; environment and conservation; community and cultural facilities including heritage and
archaeology; sport and recreation; economic development; and utilities are sought in areas where there is an identified deficiency and at a level that ensures that overall delivery of appropriate development is not compromised. This request accords with paragraph 204 of the NPPF which states that planning obligations from development sites must be fair, reasonable and proportionate.
Policy DM25 does not provide for or set out clear guidance around the grounds upon which the Council will permit the conversion, change of use/redevelopment of sites and premises allocated for employment uses to non B1, B2 and B8 uses.
We suggest the Council sets out clear guidance within the policy to permit this only
where:
- 'there is no reasonable prospect of the site being re-used for employment purposes over the plan period;
- The proposed use is compatible with the surroundings; and
- 6 months marketing evidence is provided to demonstrate the lack of demand for the land'