Object

Representation ID: 236

Received: 10/03/2014

Respondent: Lawson Planning Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

NHS Property Services Ltd, on behalf of NHS England objects to the limitations imposed by the proposed changes to Policy CS17 on securing direct provision of infrastructure by developers, as well as the payment of financial contributions towards mitigating the impacts arising from proposed developments.
The policy, as currently worded, would preclude the direct provision of infrastructure as mitigation would only be able to take the form of a "Section 106 Agreement commuted sum or CIL charge".

Comment

Representation ID: 239

Received: 10/03/2014

Respondent: Lawson Planning Partnership Ltd

In light of the revised requirement across the Borough over the period 2013-2031, NHS England has updated its Evidence Base in respect of the healthcare charge to be included in the Borough Council's CIL Charging Schedule. This updated Evidence Base is attached to this consultation form.

Support

Representation ID: 267

Received: 06/03/2014

Respondent: Theatres Trust

Support addition to policy CS17 of the term 'community and cultural facilities' and its being repeated in Appendix 5.

Support

Representation ID: 372

Received: 10/03/2014

Respondent: Suffolk Wildlife Trust

The use of this policy to support delivery of green infrastructure is supported.

Object

Representation ID: 386

Received: 10/03/2014

Respondent: Merchant Projects (Ipswich)

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The relationship of CIL and Core Strategy policies will be adversely affected by unrealistic aspirational policies that affect the cost of development; government guidance is that development should not be fettered by unreasonable financial burdens. In development terms it is premature to establish arbitrary target thresholds in the absence of full viability assessments which can only be considered once an application is submitted for determination.

Object

Representation ID: 464

Received: 27/03/2014

Respondent: Suffolk County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Unclear whether archaeology comes under 'community and cultural facilities'. It may be appropriate to add reference to heritage facilities here also.

Comment

Representation ID: 484

Received: 10/03/2014

Respondent: EDF Energy Plc

Agent: EDF Energy Plc

It is requested that any financial contributions towards the provision of social, environmental and physical infrastructure is 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 Circular 05/05 which states that Section 106 contributions from development sites must be fair, reasonable and proportionate.

Object

Representation ID: 590

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Development should not be fettered by unreasonable financial burdens. We are concerned that the Borough's failure to review and consult upon key policies which affect viability and thus have a CIL relationship will undermine its approach and risk the adoption of the Core Strategy and CIL. Unrealistic and aspirational policy goals will undermine policy objectives through viability issues. Particular policies which raise viability concerns are: CS12 (unproven affordable housing target) and DM1, DM2, DM7, DM24, DM29 and DM30 (unproven requirements). E.g. Colchester recently reduced its affordable housing requirement to 20%.

Object

Representation ID: 623

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is essential that supporting infrastructure is available to provide for the level of growth proposed. BDC/MSDC are gravely concerned about the impacts of housing on transport infrastructure. Bringing forward the Northern Fringe proposal earlier in the plan period (before 2021) could mean that infrastructure is required earlier, or require different mitigation. The Borough need to make clear the consequential impacts on congestion and deal with the long-term problems caused by intermittent closure of the Orwell Bridge. Appropriate traffic modelling needs to be available to inform such decisions, based on the latest scale, distribution, and phasing of development.

Object

Representation ID: 643

Received: 07/03/2014

Respondent: Lafarge Tarmac

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

In developing detailed policies for the future of S106 contributions and CIL, the Council should be mindful to ensure that they do not overburden industrial uses as this could have unplanned for consequences on the delivery of jobs and the regeneration of employment land. The proposals for contributions from new employment developments (para 8.196) need to be carefully considered and clarification should be provided on the forms of employment development to be appropriately included. Care must be taken to ensure that the future of existing industrial sites e.g. Ipswich Port, Cliff Quay are not prejudiced.

Object

Representation ID: 684

Received: 10/03/2014

Respondent: Suffolk County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Libraries: the County Council will seek contributions from development to expand and improve the service provided by existing libraries in Ipswich. Developer contributions will be spent by and in collaboration with Suffolk Libraries, on behalf of the County Council.
Waste: the County Council would welcome the assistance of the Borough Council in implementing Waste Policy WDM17 (provision of recycling facilities at major sites).
Fire: standard conditions in relation to access and water supply will be sought and hard standing for fire appliances may be required. Suffolk Fire and Rescue Service encourages a risk-based approach to provision of automated sprinkler systems.

Object

Representation ID: 821

Received: 10/03/2014

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Save our Country Spaces has major concerns about the changes to policy CS17 and supports the Northern Fringe Protection Group's detailed analysis and comments.

Object

Representation ID: 866

Received: 10/03/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Fresh water and sewerage infrastructure should be included in the "Key strategic infrastructure requirements" since both have previously been identified by the Haven Gateway Water Cycle Study as key issues for Ipswich and mentioned in the NALEP 2014 Strategic Economic Plan. The latter also identifies rail and road infrastructure improvements key to growth and prosperity which should be mentioned: A14/J57 Nacton £20M, A14/A12 J58 Ipswich Seven Hills Roundabout £10M and A14/A12 J55 Copdock major project £100M; better rolling stock and faster journey times on the Great Eastern Main Line; Felixstowe-Nuneaton electrification, Felixstowe branch line and the Ipswich Northern Fringe Bridge.