1.CSR MM4 para 8.70 co operation between IBC and neighbouring authorities in preparation of a new joint/aligned local plan is long overdue and no development applications on the northern fringe should be entertained until this is produced in order to ensure an integrated plan on housing,main infrastructure and jobs.
2.CSR MM5 8.6 and MM6 The latest UK government housing projection for Ipswich 2011 to 2031 is 7799 which demonstrates the flawed projection of MC ie. 13550, even the reduced projection of 9777 is inaccurate and there is clearly a need to objectively assess in cooperation the other local authorities on issues of the market requirement jobs and growth (see i. above) The same comments apply to CRS MM6 table 3 needs correction.
3. CSR MM9 and 38 Removing IGS infrastructure triggers from the Local Plan reduces there importance with no certainty of local consultation leading to watered down consequences and haphazard development with fractured delivery of essential infrastructure and enforcement of cost.
4.CRS MM10 8.108. The comments in 3. above equally apply to the phasing of development.
5. CSR 18 The Travel Ipswich highways improvement scheme has clearly not delivered the reductions in target for use of private cars with the consequence that the adverse affects of the Ipswich Garden Suburb are multiplied. The soundness of traffic assessments must be subject to independent verification.
In short the main modifications do not address the major issues raised during the plan examination i.e. critical infrastructure relating to drainage and sewerage and traffic congestion and air quality in relation to the Ipswich Garden Suburb.

Response of the Suffolk Coastal District Council Cabinet Member for Planning

Ipswich Borough Council - Post-Submission Main Modifications to the Ipswich Local Plan:

Schedule of Post-Submission Main Modifications to the Core Strategy and Policies Development Plan Document (DPD) Review, October 2016

Schedule of Post-Submission Main Modifications to the Site Allocations and Policies (incorporating IP-One Area Action Plan) DPD and Opportunity Area Plans illustrating modifications, October 2016

Consultation 20 October to 1 December 2016

Introduction
Following the completion of the Examination Hearing sessions by an independent Planning Inspector in July 2016, a series of Post-Submission Main Modifications to the Ipswich Local Plan have been published for consultation.
The Inspector is inviting representations on the changes proposed to the Plan. Representations may only be made in relation to the Post-Submission Main Modifications and not on other parts of the Plan. The modifications are intended to address issues of legal compliance and/or soundness. Therefore, representations should be made in respect of the effect of the modification(s) on the Plan's soundness or legal compliance.

Comments
It is recognised that there are a number of cross-boundary issues that affect the Suffolk Coastal District Council area, with housing, and the lack of potential sites within the Borough to meet the housing needs, being the most significant. The District forms part of the Ipswich Housing Market Area and as such this Council recognises the importance of being part of the solution in addressing the needs of the area as a whole. Work on the aligned/joint Local Plan reviews for the Housing Market Area is now well progressed.

CSR MM4
In this respect, this Council supports the modifications to Policy CS6 and supporting text (CSR MM4), but with a minor change to clarify that it is work on the Issues and Options that has commenced in 2016, as considerable joint working has been taking place since mid 2014 on the evidence base for the Review.

'8.70....... Work is to commence on Issues and Options in 2016 with the aim of having the plans adopted by 2019. The preparation of joint or aligned development plan documents will ensure a coordinated approach to meeting the objectively assessed housing needs of the Ipswich housing market area and achieving economic growth.'

CSR MM5 and MM6
The Council also supports the modifications to the introductory text for Policy CS7 (CS MM5) subject to the following minor change:

'8.77 .....However, capacity constraints in the Borough mean that, currently, sufficient suitable, deliverable and available land to deliver significantly more than 9,777 dwellings cannot be met within the Council's administrative area.......'

The Council also supports Policy CS7 and the supporting text (CS MM6). In particular, the Council supports the pragmatic approach of setting an interim housing target for the Borough, pending progress on a collaborative approach to addressing the full objectively assessed housing needs across the Ipswich Housing Market Area. A minor revision to the policy is suggested to clarify the nature and status of any strategy published in Spring 2017, as indicated below:

'A) The Council has an interim housing target of at least 9,777 dwellings for the period 2011 - 2031. This equates to an interim annual target of at least 489 dwellings. The Council will, with its neighbours, prepare an updated Objectively Assessed Need for the Ipswich Housing Market Area and draft strategy options for the distribution of development to meet that need in the Ipswich Housing Market Area by spring 2017. The results of the joint working will take the form of a joint or aligned local plan review, supported by the production of a Suffolk-wide planning framework. Policy CS7 will be reviewed as part of this joint working.'

25/11/2016

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