ipswich.gov.uk
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Representation ID: 26406
Received: 02/03/2020
Respondent: Gladman Developments
Legally compliant? No
Sound? No
Duty to co-operate? No
The Council should plan for a higher level of housing need. The need figure generated by the standard method should only be considered as the minimum starting point. A stepped housing requirement is only appropriate where there is a significant change in the level of housing requirement between plans. Historic delivery does not suggest that the Borough’s housing need will be delivered as they are relying on historic sites with known issues as a continuation of the existing spatial strategy. The historic completions data suggests that the stepped housing requirement will continue to delay meeting identified housing needs. Continued reliance on IP-One to deliver homes in Ipswich is unfounded and unrealistic; further distribution across the HMA is required. The Council’s housing requirement will fail to meet economic and affordable housing needs. It is not evident which sites within the Council’s housing land supply will come forward within the next five years. The rate of delivery at Ipswich Garden Suburb is over estimated. The Council’s assumptions made in respect of the housing trajectory risk the deliverability of the Local Plan.
The Council could plan for a higher level of housing need than the standard method suggests. The stepped trajectory should be deleted as it delays housing delivery. neither the SHLAA nor the Housing Topic Paper provide the necessary detail on the housing land supply as required by the NPPF. Refer to Lichfields 2016 report and Babergh Mid Suffolk 2019 for evidence of delivery rates at larger sites.