CS2: The Location and Nature of Development
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5164
Received: 04/03/2015
Respondent: clive gissing
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5204
Received: 05/03/2015
Respondent: Historic England
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We generally support the principle of concentrating development in the town centre and adjoining areas, but only where it does not compromise heritage assets and the distinctive character of Ipswich. We still have some concerns regarding the use of high densities within the town centre, Ipswich Village and Waterfront, but welcome the additional wording regarding heritage assets and the historic character of Ipswich at the end of the policy.
The supporting text offers some helpful recognition of the design and conservation issues relating to the location of development.
We generally support the principle of concentrating development in the town centre and adjoining areas, but only where it does not compromise heritage assets and the distinctive character of Ipswich. We still have some concerns regarding the use of high densities within the town centre, Ipswich Village and Waterfront, but welcome the additional wording regarding heritage assets and the historic character of Ipswich at the end of the policy.
The supporting text offers some helpful recognition of the design and conservation issues relating to the location of development, including acknowledgement of the NPPF's requirements in paragraph 8.39. We welcome the reference to the urban character study, which has been prepared as a SPD.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5316
Received: 05/03/2015
Respondent: Kesgrave Covenant Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy CS2 sets out the principal locations for growth, the plan is failing to deliver enough land for housing and needs to achieve the maximum delivery possible from existing suitable sites within the Borough boundary. Part B of the policy refers vaguely to the potential for additional growth locations later in the Plan period, this approach is unsound.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5356
Received: 05/03/2015
Respondent: Gladman Developments
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
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.
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.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5362
Received: 05/03/2015
Respondent: Mersea Homes Limited
Legally compliant? Yes
Sound? Yes
Duty to co-operate? No
The Council has failed to demonstrate how it has met the Duty to Cooperate. CS2(b) explains that housing need will be met in the wider Ipswich Policy Area. Table 3 (CS7) further reinforces the degree to which the Council depends on adjoining authorities. The Council have not yet secured agreement to meet its housing need in adjoining authorities. It must therefore focus on demonstrating and justifying as part of this plan, what need it can meet, and identifying the infrastructure necessary to support that amount of development. CS2 should provide the overall narrative of this approach. [Logged also to para4.4]
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5377
Received: 05/03/2015
Respondent: Applekirk Properties Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Applekirk Properties Ltd objects to policy CS2 as it cannot be considered to have been positively prepared and it is not justified as the strategy will not provide the future capacity for comparison and convenience retail floorspace identified in the evidence base. The NPPF requires local planning authorities to allocate a range of suitable sites to meet the scale and type of retail development needed. We consider that policy CS2 fails to do this. Sites are available in the Waterfront/Merchants Quarter which would accommodate an element of the retail capacity identified for Ipswich and support its regeneration.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5388
Received: 03/03/2015
Respondent: Northern Fringe Protection Group
Number of people: 323
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
An alternative of co-operating more closely with other authorities to find a more sustainable location than the Northern Fringe, which is remote from new employment sites and not connected by sustainable transport, could have been identified. These are reasons why housing needs are unable to be met in the Borough, under the terms of the National Planning policy Framework. Support the strategy of urban renaissance in central Ipswich but concerned that multi-site development of the Garden Suburb will have a detrimental impact on this. The removal of the 60% target for development on brownfield land is a negative step.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5409
Received: 05/03/2015
Respondent: Mr Arwel Owen
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? No
We consider that the Council has failed to demonstrate how it has met the Duty to Cooperate. CS2(b) explains that housing need will be met in the wider Ipswich Policy Area. Reference to Table 3 indicates that the 'residual need later in the plan' represents around 40% of the overall plan housing requirement. The 'duty to cooperate' topic paper published by the Council offers no substantive evidence that the Duty has been discharged. We are unconvinced that the Council can satisfactorily demonstrate that it has achieved the duty and for that reason we consider that the Plan is fatally flawed.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5536
Received: 02/03/2015
Respondent: Home Builders Federation Ltd (HBF)
Legally compliant? Yes
Sound? No
Duty to co-operate? No
We consider that the Ipswich plan is unsound on three counts
a) it has not been positively prepared - i.e. that the plan is based on a strategy which will meet the objectively assessed housing need including any unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
b) it is unjustified - it does not represent the most appropriate strategy when considered against the reasonable alternatives; and
c) it is ineffective because it is not based on effective joint working on cross-boundary strategic priorities.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5588
Received: 25/02/2015
Respondent: Mr Cyril Eden
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5617
Received: 05/03/2015
Respondent: Save Our Country Spaces
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site. [SOCS endorse Northern Fringe Protection Group points also].
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5660
Received: 05/03/2015
Respondent: Mrs Jane Catling
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5763
Received: 04/03/2015
Respondent: Tuddenham St Martin Parish Council
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The plan seems to be oblivious to risk:
1. consciously opting to develop flood plains,
2. dismissing the consequences of no clear strategy for East West traffic (particularly around the wet dock area),
3. dismissing the A14 and northern Ipswich traffic issues as out of its scope,
4. inward-looking focus regarding traffic infrastructure for Ipswich Garden Village, ignoring areas outside the Borough boundary.
The Parish Council have deep concerns about the viability and sustainability of the plan, particularly the impact of failings on Tuddenham St Martin residents and environment, and the presumption being made about areas in neighbouring authorities.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5872
Received: 05/03/2015
Respondent: Mr Roy Bush
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The vacant units in the town centre should be converted into town houses and flats
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5877
Received: 05/03/2015
Respondent: Mr Roy Bush
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5888
Received: 05/03/2015
Respondent: Mr James Collins
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5961
Received: 03/03/2015
Respondent: Mr Frank Seal
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15019
Received: 03/03/2015
Respondent: Mr Michael Keats
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15032
Received: 03/03/2015
Respondent: Mrs Anne Saggers
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15105
Received: 03/03/2015
Respondent: Mrs Roberta Seal
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15140
Received: 25/02/2015
Respondent: Mr Brown
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15147
Received: 02/03/2015
Respondent: Miss Sarah Marsden
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15151
Received: 02/03/2015
Respondent: Mr R M Coulter
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15159
Received: 03/03/2015
Respondent: Mr Richard Young
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15171
Received: 03/03/2015
Respondent: Mrs Carole Young
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15183
Received: 03/03/2015
Respondent: Mrs Glynne Whitehead
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15195
Received: 03/03/2015
Respondent: Mr Justin Keys
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15207
Received: 03/03/2015
Respondent: Mrs Pamela Keys
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15219
Received: 03/03/2015
Respondent: Mr D E Reed
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 15231
Received: 03/03/2015
Respondent: Mr Peter Galpin
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.
See attached.