ipswich.gov.uk

Policy CS2: The Location and Nature of Development
The Framework sets out the Government's objective to boost significantly the supply of housing and how this should be reflected through the preparation of Local Plans. In this regard it sets out specific guidance that local planning authorities must take into account when identifying and meeting their objectively assessed housing needs. This is underpinned at paragraph 47 of the Framework which states:
To boost significantly the supply of housing, local planning authorities should:
- Use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area.
- Identify and update annually a supply of specific deliverable sites sufficient to provide five years' worth of housing against their housing requirements...
- Identify a supply of specific, developable sites or broad locations for growth, for years 6-10, and where possible for years 11- 15.
Policy CS2 takes a two-step approach. It focusses new residential development initially into the town centre, the Waterfront, Ipswich Village, and Ipswich Garden Suburb and into or within walking distance of the town's district centres and only later in the plan period does it propose to work with neighbouring authorities to address housing need within the wider Ipswich housing market area. Gladman are concerned that this approach does not comply with the requirement of the Framework outlined above to significantly boost the supply of housing, as it serves to delay the development of otherwise suitable sites that could meet housing need now.
In seeking to leave decisions around addressing the needs of the wider housing market area to an unspecified point 'later in the plan period' the policy also does not comply with paragraph 178 of the Framework, which states that "public bodies have a duty to cooperate on planning issues that cross administrative boundaries" and paragraph 179, which states that "local planning authorities should work collaboratively with other bodies to ensure that strategic priorities across local boundaries are properly coordinated". It goes on to say that "joint working should enable local planning authorities to work together to meet development requirements which cannot wholly be met within their own areas - for instance, because of a lack of physical capacity and clearly reflected in individual Local Plans".
Paragraph 181 of the Framework further sets out that "cooperation should be a continuous process of engagement from initial thinking through to implementation, resulting in a final position where plans are in place to provide the land and infrastructure necessary to support current and projected future levels of development". Leaving decisions until later hardly represents being in a 'final position'.
PPG provides further explanation of how the policies contained within the Framework should be interpreted and applied. In terms of the Duty to Cooperate, PPG sets out that "local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before they submit their Local Plans for examination1" (my emphasis). Deferring decisions around addressing housing need within the wider Ipswich housing market area to a later date is clearly not in line with the requirements of the Framework or PPG.