ipswich.gov.uk
Policy DM39 Land allocated for housing
Support
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 113
Received: 05/03/2014
Respondent: Ormiston Children and Families Trust
Agent: Evolution Town Planning
We support the allocation of Site IP257. Please see attached report.
The existing access is suitable for 27 dwellings.
The site is in a 'suitable location'.
The site is unconstrained and subject to very few site specific issues so housing development could be 'achievable' in 5 years.
The redevelopment of the site for 27 dwellings using the existing access would be 'viable'.
The site will be 'available' when the plan is adopted.
As the site is unconstrained and the existing access is suitable for c.27 dwellings then we would consider the site could be viably developed.
We support the allocation of Site IP257 for housing. The attached report has considered the constraints and opportunities for the IP257 site owned by The Ormiston Children and Families Trust.
We have shown that the existing access is suitable for the suggested allocation of 27 dwellings and is unlikely to be resisted by the County Council if/when a planning application is made on the site.
We have described how the withdrawal of the Sure Start facility from the site by the end of March 2014 will mean that the community facility element of the site will be 'genuinely redundant' in line with adopted Policy DM32.
We have confirmed that the site has been submitted for consideration by Ipswich Borough Council for allocation for housing by Evolution Town Planning on behalf of Ormiston in light of the withdrawal of County Council funding support and the Trust's wider needs as a charity.
This is not a process being undertaken by a speculative developer but a genuine attempt by a charitable trust, much valued for its work by local people, to achieve best value from an asset in order to further their charitable work.
In line with the requirements of the NPPF we have considered whether the site is 'deliverable' and 'developable'.
The NPPF states that:
To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable. Sites with planning permission should be considered deliverable until permission expires, unless there is clear evidence that schemes will not be implemented within five years, for example they will not be viable, there is no longer a demand for the type of units or sites have long term phasing plans.
It is likely that no alternative sufficient funding will be found by the Trust to continue the children's services at the Ormiston site and also that the service is provided satisfactorily elsewhere then the site will be 'available now'.
The site is in a 'suitable location' being well-located within short walking distance of a District Centre and numerous public facilities, services and public transport (buses and rail) as shown on plan SAP2 in Appendix 2.
The site is unconstrained and subject to very few site specific issues. If these were dealt with satisfactorily at planning application stage housing development could be 'achievable' in 5 years.
It is also considered at this stage that the redevelopment of the site for 27 dwellings using the existing access would be 'viable'.
The NPPF also states:
To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged.
As we have explained in the attached report, being within the settlement boundary of Ipswich, located in short walking distance of a District Centre and surrounded by residential development is in a 'suitable location'.
Because of funding issues which are outside of our clients control and the potential building repair costs, we have demonstrated that there is a more than reasonable prospect that the site will be 'available' when the plan is adopted.
As the site is relatively unconstrained and the County Council have stated they could not foresee objecting to development of c.27 dwellings on this site using the existing access then we would consider the site could be viably developed.
We therefore commend this site for ongoing consideration in the current process and for the subsequent allocation of the site.
Object
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 122
Received: 06/03/2014
Respondent: Kesgrave Covenant Ltd
Agent: Mersea Homes Limited
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Propose the allocation of land north-east of Humber Doucy Lane for housing. It could accommodate over 300 homes, to be delivered 2026-2031 to meet some of the shortfall identified through the Core Strategy. The site measures 14.6ha, however there is additional land adjacent to it which falls within Suffolk Coastal District Council's area. If this land were also developed the capacity would double.
Please see attached.
Support
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 156
Received: 10/03/2014
Respondent: Associated British Ports
Agent: Associated British Ports
ABP supports the allocation of Site IP037, but requests amendment to the wording of the policy and supporting text at paragraph 5.8 to allow more flexibility in the proportional split of acceptable uses where a master plan or the preparation of more detailed proposals show this is expedient or necessary to deliver successful regeneration of the Island Site.
ABP supports the allocation of Site IP037 - Island Site for housing as part of a mixed use development. However, the proportional split of uses set out in the policy can only, given the nascent proposals for the site, be aspirational. The precise split should be a matter for a future master plan and/or planning application. The Island Site presently accommodates successful high profile marine businesses (including Fairline Boats Ltd and Spirit Yachts Ltd) and the commercially successful Ipswich Haven Marina (which has contributed significantly to the regeneration of the waterfront area). Accommodating these activities in the future development of the Island Site so that they continue to contribute to an active and appealing waterfront environment for further regeneration will be critical. This should be properly reflected in Policy DM39 and in the Opportunity Area development principles and guidelines in Part C of the draft DPD.
A critical challenge to realise successful redevelopment of the Island Site, given the significant development costs on this site, will be viability. The high proportion of 'open space' use and low indicative development capacity for homes, which is at the lower end of the Policy DM30a range and is significantly lower than in previous iterations of the IP-One AAP, has not been informed by a detailed study and does not take account of any viability considerations. In this context, the requirement at paragraph 5.8 for the proportion of housing to be within + or -5% of the proportion indicated in the policy is onerous and, in our opinion, may prejudice or even preclude redevelopment. ABP would instead request that this wording is amended to acknowledge that changes may be agreed to these proportions if accepted as part of the preparation of a master plan or planning application.
Comment
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 199
Received: 10/03/2014
Respondent: Lawson Planning Partnership Ltd
Agent: Lawson Planning Partnership Ltd
An additional 1ha approximately of land is likely to be needed for health care purposes therefore leaving around 11.7ha for residential development. Amend the site area in Table 1 Policy DM39.
Please see LPP letter (attached).
Object
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 217
Received: 10/03/2014
Respondent: Mr Leslie Short
Agent: Mr Leslie Short
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
There is a need for greater flexibility either within the specific wording of DM39 to facilitate interim alternative uses until the viability/returns of residential development fit within a site owners own business needs.
RCP Parking Ltd. object to the way in which their site which they own in Handford Road East (IP 096), is referred to in this policy. Whilst they support the allocation of the land in principle for residential purposes, the decision of when to develop/dispose should be part of their commercial strategy rather than a third party. The company has not been consulted on its business plans.
RCP Parking Ltd. object to the way in which their site which they own in Handford Road East (IP 096), is referred to in this policy. Whilst they support the allocation of the land in principle for residential purposes, the decision of when to develop/dispose should be part of their commercial strategy rather than a third party. The draft allocation indicates that it has a short-term delivery timescale but the company has not been consulted on its own business plans. Had it been so consulted it would have reaffirmed the need for flexibility and the certainty of interim beneficial uses such as car parking in a difficult economic climate.
Support
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 237
Received: 10/03/2014
Respondent: Mr Leslie Short
Agent: Mr Leslie Short
Site IP256, synthetic turf pitch (STP) owned by the Ipswich Sports Club is fully available an surplus to the club's requirements and development plans. A preliminary study both of STP facilities in the wider Ipswich catchment, together with the development of its own alternative facilities and those both under construction/planned within the immediate catchment area reaffirm the position that this site is surplus. Moreover, the total opposition by the LPA and residential neighbours to floodlights which would enhance usage prospects for the facility renders the pitch useless for hockey and other sport. The site is available short-term rather than medium.
Site IP256, synthetic turf pitch (STP) owned by the Ipswich Sports Club is fully available an surplus to the club's requirements and development plans. A preliminary study both of STP facilities in the wider Ipswich catchment, together with the development of its own alternative facilities and those both under construction/planned within the immediate catchment area reaffirm the position that this site is surplus. Moreover, the total opposition by the LPA and residential neighbours to floodlights which would enhance usage prospects for the facility renders the pitch useless for hockey and other sport. The site is available short-term rather than medium.
Comment
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 241
Received: 10/03/2014
Respondent: Lawson Planning Partnership Ltd
With reference to proposed site allocation IP005, NHS Property Services Ltd, on behalf of NHS England, wishes to make the following comment:
Whilst the healthcare impact arising from this allocated site in isolation would not necessitate the provision of a new GP surgery, a site for a new health centre to accommodate planned growth may be warranted, subject to the securing of pooled funding from other major housing sites as necessary, and subject to NHS Business case approval procedures.
With reference to proposed site allocation IP005, NHS Property Services Ltd, on behalf of NHS England, wishes to make the following comment:
Whilst the healthcare impact arising from this allocated site in isolation would not necessitate the provision of a new GP surgery, a site for a new health centre to accommodate planned growth may be warranted, subject to the securing of pooled funding from other major housing sites as necessary, and subject to NHS Business case approval procedures.
Object
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 245
Received: 18/02/2014
Respondent: Mr Martin Catchpole
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
TBC
See attached
Object
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 377
Received: 10/03/2014
Respondent: Environment Agency
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Allocation of a site does not prevent the Environment Agency lodging an objection to a subsequent application e.g. if the proposal would contravene environmental legislation. Given the number of brownfield site allocations and the absence of a specifically worded condition covering land contamination, we recommend that the following policy wording be added to the policies: 'Applicants who wish to develop suspected contaminated land will be required to undertake a thorough investigation of the site and determine any risks. Relevant remediation and mitigation measures will need to be built into development proposals to ensure safe, sustainable development of the site.'
See attached.
Object
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 378
Received: 10/03/2014
Respondent: Environment Agency
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Some of the proposed sites are situated within Flood Zones 2 and 3. The Council will need to provide evidence that demonstrates the sequential test has been carried out in relation to the proposed proposed site allocations: IP004; IP011b; IP015; IP031; IP037; IP039a; IP043; IP096; IP098; and IP136. A standalone Sequential Test report should be presented in support of the plan to ensure compliance with the NPPF. Planning applications in Flood Zones 2 & 3 will also need to be supported with a Flood Risk Assessment. Developments on river frontage sites should enhance the appearance of the site.
See attached.
Object
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 672
Received: 10/03/2014
Respondent: Suffolk County Council
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The allocated sites will yield pupils as follows:
Early years 205; Primary 512; Secondary 369; Sixth Form 82.
Early education facilities across the town are at capacity. Full contributions will be sought from all the sites listed. 205 additional places creates a theoretical need for 5-10 new settings, which are normally sought within developments of >200 dwellings. Thus sites IP037 (Island Site) and IP116 (St Clements) are candidates. Development will create pressure at primary schools across Ipswich, therefore allocations within some catchments need urgent discussion. There is some secondary school capacity in Ipswich, but it needs to be carefully managed.
See attached.
Object
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 677
Received: 10/03/2014
Respondent: Suffolk County Council
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Housing is a key issue for older people. The County Council as social care authority is aware of the need to ensure a suitable mix of housing for older people; from market housing, through various types of supported housing. The Council supports local planning authorities to encourage new housing to be built to the Lifetime Homes standard, which makes it easier for people to remain in their own homes as their mobility needs change. Both authorities should also consider whether allocations of land for supported housing (for older people and other Adult and Community Services user groups) would be justified.
See attached.
Comment
Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 738
Received: 10/03/2014
Respondent: Crest Strategic Projects
Crest has no comment on the range of sites and their detailed capacity in Policy DM39, but notes that they will deliver 2,409 dwellings, leaving a substantial number of dwellings still to deliver. This underscores the position that policy needs to allow the Northern Fringe to come forward and deliver the balance, to meet targets. Without the Northern Fringe, there is a large land deficit for housing development and the targets would be unachievable. The importance of the Northern Fringe will increase if any of the sites listed under DM39 experience delivery problems or their capacity has been overstated.
See attached.