ipswich.gov.uk
CS1: Sustainable Development - Climate Change
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5355
Received: 05/03/2015
Respondent: Gladman Developments
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Pursuing sustainable development requires careful attention to be paid to viability and costs in plan-making, and should assess the likely cumulative impacts (my emphasis) on development of such policies and standards so that the viability of the plan itself is not compromised through making the proposed scale of development unviable. The Inspector needs to be satisfied that this is indeed the case.
Policy CS1: Sustainable Development - Climate Change
This policy sets out various measures for tackling climate change over the plan period. These include a requirement for new developments to incorporate energy conservation and efficiency measures, seeking opportunities to develop renewable energy-generating capacity, supporting the implementation of a number of related plans and strategies and promoting a modal shift to reduce carbon emissions. It also proposes a requirement that all major developments should achieve a target of at least 15% of their energy requirements through decentralised renewable or low carbon energy sources where feasible and viable. Gladman would emphasise that policies such as these should comply with the provisions set out in paragraphs 173 and 174 of the Framework. These require that pursuing sustainable development requires careful attention to be paid to viability and costs in plan-making, and should
assess the likely cumulative impacts (my emphasis) on development of such policies and standards so that the viability of the plan itself is not compromised through making the proposed scale of development unviable. The Inspector needs to be satisfied that this is indeed the case.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5361
Received: 05/03/2015
Respondent: Mersea Homes Limited
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The obligations to secure 15% energy provisions from decentralised sources or to achieve 'significant' reductions in carbon emissions are not justified nor is it consistent with national policy. The obligations should be deleted.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5408
Received: 05/03/2015
Respondent: Mr Arwel Owen
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The model policy setting out the NPPF presumption in favour of development should not be conflated to the reminder of Policy CS1 and should instead be a separate policy. The obligation to secure 'significantly reduced carbon emissions' is not costed, is not justified nor is it consistent with national policy. The obligation should be deleted. The obligation to secure 15% energy provisions from decentralised sources is not justified nor is it consistent with national policy. The obligation should be deleted.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5487
Received: 05/03/2015
Respondent: Mr Andrew Fisk
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Transport policy, (CS5, CS17 and CS20) There doesn't seem to be any realistic attempt to deal with the additional traffic that will result from the Northern fringe development. There are some changes which will increase the area of road for traffic to queue on, but they do not fundamentally address the problem of traffic movement.
Transport policy, (CS5, CS17 and CS20) There doesn't seem to be any realistic attempt to deal with the additional traffic that will result from the Northern fringe development. There are some changes which will increase the area of road for traffic to queue on, but they do not fundamentally address the problem of traffic movement. The roads to and from the development are already extremely busy and there does not seem a suitable way of expanding the capacity of the existing roads (Valley Road, Henley Road etc.) to accommodate this traffic. I believe that increased congestion is likely, which in turn is liable to cause more pollution both in terms of air quality and noise
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5539
Received: 02/03/2015
Respondent: Home Builders Federation Ltd (HBF)
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Parts of the policy are unsound as they are contrary to national policy.
Policy CS1: Sustainable Development - Climate Change
Parts of the policy are unsound as they are contrary to national policy.
Part B of the policy requires all major developments to achieve a target of at least 15% of their energy requirements to be provided through decentralised renewable or low carbon energy were feasible and viable.
The approach is contrary to national policy. We refer to the published DCLG consultation document Next steps to zero carbon homes - Allowable Solutions published in August 2013. This set out the Government's thinking on how the energy efficiency targets in the Building Regulations will be met by developers. How developers achieve the carbon reduction targets under Part L of the Building Regulations is a matter for them to decide. The Council cannot specify how this is achieved. It cannot require developers to provide or connect to decentralised energy systems and it cannot require developers to provide decentralised or low carbon energy systems. Applicants will be free to decide the most appropriate course themselves. There are also legal considerations relating to connection to district heating that means that the role of the Council is prescribing in detail how energy reduction targets will be achieved and so is unlawful. Customers (home purchasers or tenants) are required under law to have the freedom of choice from whom they purchase their energy. This part of the policy is therefore contrary to paragraph 95 of the NPPF. The policy should be deleted.
It is unclear what is being proposed by parts C and D of the policy. The Government proposes that house builders will have a choice of four routes to deliver the remaining carbon abatement above the onsite minimum level required by the Building Regulations from 2016 (see chapter 6). One option includes contracting with a private sector party or local authority for them to deliver carbon abatement measures, but developers cannot be compelled down this route. Developers may be allowed to deliver Allowable Solutions through a combination of the four options but how Allowable Solutions are delivered is a matter for the developer to decide, not the council. The policy therefore, is not compliant with the direction of Government thinking and should be deleted. This is not a planning matter.
Part I of the policy may need amending in the light of the Government's Housing Standards Review. If the Council expects developers to incorporate water conservation measures that exceed the current Building Regulations then it will need to have regard to the Government's tests set out in the Housing Standards Review with regard to adopting the optional standard for water conservation. It will also need to have regard for paragraph 173 of the NPPF.
These parts of the policy should be revised to make clearer the Council's intentions.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5556
Received: 05/03/2015
Respondent: Save Our Country Spaces
Legally compliant? No
Sound? No
Duty to co-operate? No
SOCS major concern relates to non compliance of CS1 with the NPPF. Traffic problems, congestion & gridlock fail NPPF requirements for no "serious adverse effects". Air Pollution, increased human mortality and Public Health risks from traffic are identified in 2000 as a serious and growing problem in Ipswich which mitigation measures appear not to have alleviated. IBC hasn't the capacity to control likely serious adverse impacts via DM Policies on Transport, Traffic congestion, Air Pollution, Flood Risk, Potable Water and Sewage Requirements. There is insufficient work on likely Climatic Change impacts and Cumulative Impacts with Suffolk Coastal District growth plans.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5603
Received: 25/02/2015
Respondent: Mrs Mavis Hammond
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The plan will not protect our health or deal with air pollution. National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5622
Received: 19/02/2015
Respondent: Mr & Mrs David and Eileen Warren
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Will your plans protect our health and deal with pollution?
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5633
Received: 16/02/2015
Respondent: Mr Tony Moran
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We already have significant and chronic issues relating to infrastructure and surface drainage, flooding and sewerage. The proposals will only add to these and not improve matters. Heavy rainfall and flash flooding are an increasing feature of our weather patterns and this will not improve matters. CS1 CS17 & CS20
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5670
Received: 03/03/2015
Respondent: Mr Bridges
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The plan will not protect our health or deal with air pollution. National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5681
Received: 03/03/2015
Respondent: Mrs Bridges
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The plan will not protect our health or deal with air pollution. National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5743
Received: 03/03/2015
Respondent: D C Norman
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The plan will not protect our health or deal with air pollution. National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5753
Received: 02/03/2015
Respondent: Mr Brian Pinner
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The plan will not protect our health or deal with air pollution. National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Support
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5771
Received: 25/02/2015
Respondent: Mr Brian Pachent
The plan will protect our health or deal with air pollution. National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5776
Received: 03/03/2015
Respondent: Mr & Mrs David and Pamela McCartney
Number of people: 2
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The plan will not protect our health or deal with air pollution. National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development. Local residents feel that there will be adverse effects and that their views are not being listened to.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5801
Received: 05/03/2015
Respondent: Yvonne Maynard
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Air pollution, Infrastructure issues, the plans for the Country Park are not acceptable, sustainable development will not be achieved through CS1.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5807
Received: 05/03/2015
Respondent: Mr Philip Maynard
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Air pollution, Infrastructure issues. The Country Park Plans are unacceptable, CS1 is does not achieve sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5816
Received: 05/03/2015
Respondent: Mr Creasey
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Question whether the plan will protect our health or deal with air pollution.
See atttached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5823
Received: 05/03/2015
Respondent: Mrs Creasey
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The plan will not protect our health or deal with air pollution.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5829
Received: 05/03/2015
Respondent: Mr John Summers
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The plan will not protect our health or deal with air pollution.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5830
Received: 05/03/2015
Respondent: Mr John Summers
Legally compliant? Yes
Sound? No
Duty to co-operate? No
National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5841
Received: 05/03/2015
Respondent: Mrs Jennifer Summers
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The plan will not protect our health or deal with air pollution. National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5852
Received: 05/03/2015
Respondent: Mr Neil Summers
Legally compliant? Yes
Sound? No
Duty to co-operate? No
Where will 12,500 jobs come from? National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5863
Received: 05/03/2015
Respondent: Miss Charlotte Miller
Legally compliant? Yes
Sound? No
Duty to co-operate? No
Where will 12,500 jobs come from? National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5897
Received: 05/03/2015
Respondent: F A Leeder
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5900
Received: 05/03/2015
Respondent: F A Leeder
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5909
Received: 05/03/2015
Respondent: A W Parkin
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5913
Received: 05/03/2015
Respondent: Mr R Snook
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
National Planning Policy Framework (NPPF) says sustainable developments means no adverse impacts should be caused elsewhere. The Core Strategy Review will not deliver sustainable development.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5922
Received: 05/03/2015
Respondent: Mrs A Snook
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The plan will not protect our health or deal with air pollution.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5932
Received: 05/03/2015
Respondent: D Roberts
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The plan will not protect our health or deal with air pollution
See attached