Object

Representation ID: 25589

Received: 07/03/2019

Respondent: Department for Education (DfE)

The DfE notes that significant growth in housing stock is expected in the borough; draft policy CS7 confirms a housing target of at least 8,622 homes for the period 2018 - 2036, equating to an annual target of at least 479 dwellings. This will place significant additional pressure on social infrastructure such as education facilities. The Local Plan will need to be 'positively prepared' to meet the objectively assessed development needs and infrastructure requirements.

Object

Representation ID: 25643

Received: 08/03/2019

Respondent: Grainger Plc

(Read alongside table 2 of representation). Whilst we acknowledge that a figure of 9,214 is ambitious and commend the Council for setting such targets, the figure only represents a buffer of 6.8% above the standard methodology. We caution the conservative buffer the Borough has applied to the provision of housing over the Plan period, particularly given the Council's own margin for "slippage" was 10% (applied to Table 2 within the Core Strategy document). Therefore, logically, an uplift of at least 10% should be applied to figures H and G in Table 2 of this representation.

Object

Representation ID: 25644

Received: 08/03/2019

Respondent: Grainger Plc

We caution the Council's spatial strategy, where over 50% of new housing allocations will be delivered through a single site (Ipswich Garden Suburb). This has already limited the Council's ability to provide its five year housing land supply (discussed in detail in the other representations) but could also jeopardise the delivery of the Plan should the site be rendered undeliverable or not as fruitful for unforeseen reasons.

Object

Representation ID: 25645

Received: 08/03/2019

Respondent: Grainger Plc

In relation to the allowance of windfall sites, paragraph 70 of the NPPF states "where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply". In this case there is a lack of compelling evidence to support windfall sites as a reliable source of supply. Based on this. the plan does not comply with paragraph 70 of the NPPF and further evidence in support of the windfall sites should be provided, or housing provision over the plan period should be reviewed.

Object

Representation ID: 25646

Received: 08/03/2019

Respondent: Grainger Plc

Ipswich has experienced under-delivery against their housing targets over the last three years, ranging between 55-64% (based on the 2017 AMR) (refer to table 3 of this representation). Consequently, the Plan should be allowing a 20% buffer of land for housing to compensate for previous years of under delivery in line with paragraph 73 of the NPPF.

The Borough's draft housing trajectory demonstrates that Ipswich cannot meet its current five-year housing land supply, let along the additional 20% buffer required to compensate for its failure to meet the Housing Delivery Test.

Object

Representation ID: 25647

Received: 08/03/2019

Respondent: Grainger Plc

This policy follows a stepped approach. Whilst a stepped approach to the annual housing requirement is an acceptable approach outlined in the NPPF, we believe in the case of Ipswich this approach is not justified and does not meet the outcomes specified within the guidance (see representation for guidance extract). The Borough's housing requirement has not significantly changed between emerging and previous policies, in fact it has decreased by 10 dwellings per annum. Given the Borough's significant under-delivery of housing over previous years alongside its decrease in housing need, the proposal to step the annual housing requirement is not justified.

Object

Representation ID: 25648

Received: 08/03/2019

Respondent: Grainger Plc

In order to be considered sound and compliant with National Policy, the emerging Plan should consider allocating more deliverable sites that will contribute to meeting the Borough's five year housing land supply plus an additional 20% buffer as outlined in Paragraph 73 of the NPPF. In short, the Borough must find more deliver sites to boost delivery in the early years of the Plan. If none can be found in the Town's boundaries, then it must work with adjoining authorities to find such sites within the greater urban area.

Object

Representation ID: 25662

Received: 11/03/2019

Respondent: Northern Fringe Protection Group

The CS should comply with Government advice to use the Standard method annual 2014 (445) figures (Government October 2018 consultation) for housing targets.
The evidence base ignores latest population and employment figures. It fails to consider potential impacts for the Core Strategy of the drop of employed people from 67,300 to 66,500 in the latest NOMIS figures.
The CS gives misleading impressions of continued population growth, when it is currently stagnant. The evidence base needs to consider the impacts of the latest population figure of 138,500 (2017) is the same as 2016, as the fall-off in population growth has implications.

Support

Representation ID: 25712

Received: 04/03/2019

Respondent: Suffolk Chamber of Commerce

We are pleased with the Council's aim of delivering at least 8,622 dwellings and we hope the appropriate provision will be given for a mix of housing, including high-quality family housing and housing for people on lower incomes.

Support

Representation ID: 25736

Received: 12/03/2019

Respondent: Constable Homes Ltd

This policy approach is supported.

Object

Representation ID: 25787

Received: 13/03/2019

Respondent: Home Builders Federation Ltd (HBF)

We would agree with the Council's assessment of housing need of 479 dwellings per annum. However, this is the starting point for assessing needs and national policy/ guidance expect Councils to consider whether other factors will necessitate a higher requirement. Given that the level of affordable housing needs within Ipswich that will not be met the Council need to consider whether additional sites could be allocated that would make a further contribution to meeting these needs. It will also be important to raise this with neighbouring authorities to consider whether it is possible to allocate additional sites near Ipswich.

Object

Representation ID: 25789

Received: 13/03/2019

Respondent: Home Builders Federation Ltd (HBF)

The Council has adopted a stepped housing trajectory. However, the lack of a five-year housing land supply (on adoption) is not a relevant justification. Paragraph 3-034 of PPG indicates two circumstances where a stepped trajectory may be appropriate. Whilst it appears the Council can satisfy one of these tests (strategic sites and late-delivery) we suggest that the step as set out does not reflect expected delivery. We recommend that whilst a requirement in the first two years of 350 dpa is acceptable this should increase to 400 homes between 2020/21 and 2022/23. At 2023/24 this should then increase to 550.

Object

Representation ID: 25917

Received: 20/03/2019

Respondent: Pigeon Investment Management Ltd

There is no evidence of identifying housing needs across the IHMA and how IBCs neighbours are responding to the housing requirements of the Borough.

No evidence as to how IBC will deal with the 1,090 home shortfall.

The level of housing growth does not match the creation of new jobs proposed in CS13.

The lack of a five-year housing land supply cannot be considered to be relevant justification for a stepped housing trajectory and this is contrary to Planning Practice Guidance.

The level of affordable housing need and economic growth in this location means additional sites should be considered.

Object

Representation ID: 25933

Received: 12/03/2019

Respondent: Ashfield Land Limited

It would be perverse if the Local Plan was to be revised to use the lower 2014-based projects as these are below the 2016-based projections and would be inconsistent with the Government's central objective of boosting housing delivery.

The standard method should be seen as a minimum/ starting point only and a higher level of growth should be planned for to support the role of Ipswich in the wider sub-region.

Object

Representation ID: 26058

Received: 13/03/2019

Respondent: On behalf of Telereal Trillium Ltd

Welcome use of standard methodology but should be seen as a minimum as per NPPF paragraph 60. IBC is also subject to the housing delivery test 20% buffer.

Concerned that IBC will continue to note meet its target for deliverable housing in the first five years of the plan period, particularly with IGS coming in later in the plan period.

The Site (IP279) is deliverable and could accommodate 150 homes as part of IBC's five-year housing supply. This would contribute almost 30% of an entire year's supply. Paragraph 68 of NPPF states a mix of sites should be considered.