ipswich.gov.uk

Policy ISPA4 Cross Boundary Working to Deliver Sites

Showing comments and forms 1 to 20 of 20

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26195

Received: 14/02/2020

Respondent: Derk Noske

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

This site (ISPA4.1) should remain as farmland to provide the Green Trail route outlined in the planning policy DM10 of the Ipswich Local Plan. Any additional housing would encroach on this pristine countryside that today provides easy access to green spaces as set out in the local plan

Change suggested by respondent:

No housing to be developed on these sites.

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26207

Received: 21/02/2020

Respondent: Ipswich & East Suffolk Clinical Commissioning Group & West Suffolk CCG

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The agreement to work with ESC supported. Development near Humber Doucy Lane is within the catchment of Two Rivers Medical Centre and primary care provision would likely be prescribed here. However, the possibility of issues arising from developments near to local authority boundaries regarding healthcare provision is prevalent. The developments of IGS, continued development of Ravenswood and Whitton are examples of possible cross-boundary developments. Communication/ cooperation will be vital in making sure that appropriate stakeholders are aware and mitigation is sought in a timely manner. Make sure that the land North of Ipswich is accounted for in mitigating health.

Change suggested by respondent:

Not specified

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26233

Received: 24/02/2020

Respondent: Rushmere St Andrew Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Rushmere St Andrew Parish Council objects to the inclusion of Policy ISPA 4.1. This allocation will significantly increase traffic on the Woodbridge to Claydon corridor via Playford Road, Rushmere Street and Humber Doucy Lane. This development should not take place until significant improvements to roads and travel has been made. The Cross Working Policy refers to upgrading of road junctions but this does not addess the concerns of the parish. More should be done to improve local roads and travel and it should be specified that improvements should be implemented prior to development.

Change suggested by respondent:

Delete Policy ISPA 4.1 and this policy.

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26246

Received: 26/02/2020

Respondent: Ipswich Rugby Football Club (Ipswich RFC)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Ipswich RFC serves the local rugby playing community and has a requirement for extra land to meet the demands for it. Land at Humber Doucy Lane adjacent to IP184b is currently leased to meet demand but more space needed. We do not wish to be omitted from any land allocation as the funds realised by land sale could greatly assist the club in better meeting demands. We are also seeking to expand our offering if larger replacement playing facilities adjacent to current pitches are made available or a new site identified. Site IP184b should be included within the ISPA4.1 allocation.

Change suggested by respondent:

Include site IP184b in the ISPA4.1 allocation.

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26329

Received: 02/03/2020

Respondent: Home Builders Federation Ltd (HBF)

Agent: Home Builders Federation Ltd (HBF)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

It would appear from the Council’s evidence that they have co-operated effectively with neighbouring authorities to plan for housing needs across the ISPA. Growth expectations are set out in ISPA1 and we agree that the minimum number of homes to be delivered in the areas is circa 35,000 between 2018-2036. However, we cannot comment on whether this has translated into effective joint working regarding the cross-border infrastructure and sites issues set out in ISPA2 and ISPA3. It will be important that the Council can show that the cross-boundary issues concerning the deliverability of those sites in ISPA4 which will meet a considerable portion of the ISPA’s housing needs will be addressed by the Council and the relevant agencies.

Change suggested by respondent:

Not specified

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26353

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

SOCS; “Adverse impacts and significant disruption will undoubtedly occur in both the short and
long term on existing residents’ Quality of Life and Well being”; point conceded by Portfolio holder (paper E/13/601); “ 2.2 The development of the Northern Fringe involves major challenges due to its largescale, multiple ownership, the need to incorporate a wide range of supporting infrastructure and the mitigation of impacts on local communities.” ISPA4 is unjustified/ unsound. Concerns regarding air quality, flood risk vulnerability and biodiversity/ habitat loss. Future households will have to bear costs of management/ maintenance of drainage. Should be levied to new houses.

Change suggested by respondent:

Not specified

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26387

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Challenge need for future development at the northern end of Humber Doucy Lane. This is no longer required by Suffolk Coastal to meet its housing target. Settlement Sensitivity Assessment recognises the sensitivity of the open land between the edge of suburban Ipswich and villages of Westerfield and Rushmere. Concludes that the area is “sensitive to development” and “care will be needed to ensure rural countryside beyond the Ipswich administration area continues to function as a green rim to the town". Site too important/ sensitive to be built on, especially as it will need additional primary school, which has traffic implications.

Change suggested by respondent:

Not specified

Attachments:

Support

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26392

Received: 02/03/2020

Respondent: East Suffolk Council

Agent: East Suffolk Council

Representation Summary:

Supportive of general principles regarding the development of land at Humber Doucy Lane. Approach is complementary of the Suffolk Coastal Final Draft Local Plan policy for land at Humber Doucy Lane, and along with other policies and allocations in Ipswich Local Plan Final Draft, contributes towards the outcome outlined in the Statement of Common Ground of each local planning authority meeting housing need within their own area.

In particular, the Council supports the 30% affordable housing requirement for ISPA4 which complements the affordable housing policy in the Suffolk Coastal Final Draft Plan.

Change suggested by respondent:

N/A

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26393

Received: 02/03/2020

Respondent: East Suffolk Council

Agent: East Suffolk Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Suggested that policy for development at northern end of Humber Doucy Lane references maintenance of separation between Ipswich and surrounding settlements, for consistency with DM11. Noted that ISPA4 infers that SANGs will be required on both sides of Borough boundary. For clarity and to enable provision for SANGs to be considered through project level Habitats Regulations Assessment, and to be reflective of plan level HRA, policy could provide appropriate level of flexibility by not specifying that SANGs be located on both sides of boundary. Suitable Accessible Natural Greenspaces should be changed to Suitable Alternative Natural Greenspaces to reflect term SANGs.

Change suggested by respondent:

Policy should reference maintenance of separation between Ipswich and surrounding settlements. Policy could provide appropriate level of flexibility by not specifying that SANG be located on both sides of boundary. Suitable Accessible Natural Greenspaces should be changed to Suitable Alternative Natural Greenspaces.

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26396

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Traffic will increase traffic at junctions that are already over-capacity without any additional infrastructure. Breach of CS16 regarding protection/ enhancement of green corridors and the Green Rim (regardless of it being designated as countryside). Breach of policies DM8, DM10 and DM11 as no net biodiversity gains or green infrastructure though development. Acts as a rural buffer. Regardless, should be no development of this land until completion of IGS. Needs to be clarified in the CS. SA needs to fully assess implications on building on site and whether delivering more homes in town centre instead of retail is more sustainable option.

Change suggested by respondent:

Should be no development of this land until completion of IGS. SA needs to fully assess implications on building on site and whether delivering more homes in town centre instead of retail is more sustainable option.

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26440

Received: 02/03/2020

Respondent: Kesgrave Covenant Ltd

Agent: Kesgrave Covenant Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy comments on location of green infrastructure - KCL has additional land in vicinity so may be possible to locate outside of allocated site. Limiting green infrastructure to within allocation overly restrictive, therefore not effective or sound. Policy outlines affordable housing requirements - whilst provision supported in principle, Council must ensure viability. Plan identifies 15% requirement with exception of land at Humber Doucy Lane and IGS where at least 30%/31% is required. Whole Plan Viability Study calculations don't include Section 106 and CIL - query whether full infrastructure costs considered. Suggest further flexibility should be applied. Recommend policy wording change.

Change suggested by respondent:

Policy ISPA4 should be amended to read:
"Ipswich Borough Council will work with neighboring authorities to master plan and deliver appropriate residential development and associated infrastructure on identified sites within the Borough but adjacent to the boundary, where cross boundary work is needed to bring forward development in a coordinated and comprehensive manner. In order to meet housing needs within the Borough boundary as far as possible, the Council identifies cross-border allocation for development of 23.62ha of land within Ipswich Borough in 4 parcels forming ISPA4.1 for housing growth and associated infrastructure improvements at the northern end of HUmber Doucy Lane adjacent to Tuddenham Road. The allocation is shown on the accompanying site sheet for this policy. It will require land and infrastructure works and green infrastructure (including Suitable Accessible Natural Greenspace) on both sides of the Borough boundary in order to come forward, however this could include land outside the allocated site......Development will include at least 30% affordable housing, subject to viability testing at the planning application stage...."

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26441

Received: 02/03/2020

Respondent: Kesgrave Covenant Ltd

Agent: Kesgrave Covenant Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Paragraph 8.28 refers to transport mitigation measures required for the development of the site at Humber Doucy Lane being "challenging". This is not considered to be the case. Re-iterate earlier submissions in relation to accessibility of the site:
-Good public transport accessibility;
-Good road access;
-Good accessibility to services and facilities;
-Town centre and hospital easily accessed by public transport;
-Development of site promotes sustainable transport in accordance with NPPF;
-Transport Modelling Report concludes housing growth can be accommodated;
-Proposals will not influence northern bypass route.

Current reference to "challenging" transport mitigation measures not justified. Recommend amendment to paragraph 8.28.

Change suggested by respondent:

Paragraph 8.28 should be amended to read:
"The site allocation at the northern end of Humber Doucy Lane is located at the edge of Ipswich approximately 3.5km from the town centre. Sustainable transport connections will be key to providing linkage to employment and other opportunities. In addition, it is acknowledged that transport mitigation measures are required for the development of the site and it is essential that significant modal shift is delivered through strong travel plans and other sustainable measures"

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26442

Received: 02/03/2020

Respondent: Kesgrave Covenant Ltd

Agent: Kesgrave Covenant Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Plan identifies requirement for sites to provide 15% affordable housing, with the exception of Humber Doucy Lane and IGS where 30/31% required respectively. Calculations for Humber Doucy Lane from assessment of affordable housing provision in The Whole Plan Viability Study, don't include section 106/CIL - query whether full infrastructure costs considered. After testing, first IGS neighbourhoods have been agreed with 4/5% provision instead. Therefore, suggest further flexibility applied to this policy. Whilst support provision of affordable housing, more detailed viability testing may be required to ensure site is viable with regard to all infrastructure costs. Recommend amendment to paragraph 8.29.

Change suggested by respondent:

Paragraph 8.29 should be amended to read:
"The Council will outline expected infrastructure provision of both green infrastructure and built infrastructure required as part of the joint agreed master-planning process to the cross-border Humber Doucy Lane sites. the Whole Plan Viability Assessment of the Local Plan identifies that this area of land falls wihtin a high value zone and indicates that approximately 30% affordable housing could be achieved on a greenfield development, however this will be subject to further testing at the planning application stage. The level of affordable housing also broadly aligns with the Suffolk Coastal Local Plan affordable housing requirement of 33%"

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26443

Received: 02/03/2020

Respondent: Pigeon Investment Management Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy ISPA4 – Cross Boundary Working to Deliver Sites
3.1 Pigeon support the Council’s inclusion of a policy that relates to the delivery of sites outside of the Borough. However, this policy remains almost the same as its version in the previous document, only including a little more detail. Furthermore, this policy relates solely to site ISPA4.1. It does not therefore provide any general policy support or guidance for delivering Ipswich Borough Council’s housing need for 8,010 homes (Policy CS7), outside of the authority area, particularly given the stepped housing trajectory with less homes delivered at the start of the plan period.
3.2 The Site Sheet for ISPA4.1 sets out that the development would need to be ‘delivered in coordination with the delivery of the Ipswich Garden Suburb to ensure that there is sufficient infrastructure capacity to meet demand’. The Ipswich Garden is assessed with further commentary within this representation, and in line with the conclusions of this, it is considered that reliance on the Ipswich Garden Suburb puts site ISPA4.1 at risk of delay.

Change suggested by respondent:

Not specified

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26512

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Challenge need for future development at the northern end of Humber Doucy Lane. This is no longer required by Suffolk Coastal to meet its housing target. Settlement Sensitivity Assessment recognises the sensitivity of the open land between the edge of suburban Ipswich and villages of Westerfield and Rushmere. Concludes that the area is “sensitive to development” and “care will be needed to ensure rural countryside beyond the Ipswich administration area continues to function as a green rim to the town". Site too important/ sensitive to be built on, especially as it will need additional primary school, which has traffic implications.

Change suggested by respondent:

Not specified

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26516

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Traffic will increase traffic at junctions that are already over-capacity without any additional infrastructure. Breach of CS16 regarding protection/ enhancement of green corridors and the Green Rim (regardless of it being designated as countryside). Breach of policies DM8, DM10 and DM11 as no net biodiversity gains or green infrastructure though development. Acts as a rural buffer. Regardless, should be no development of this land until completion of IGS. Needs to be clarified in the CS. SA needs to fully assess implications on building on site and whether delivering more homes in town centre instead of retail is more sustainable option.

Change suggested by respondent:

Should be no development of this land until completion of IGS. SA needs to fully assess implications on building on site and whether delivering more homes in town centre instead of retail is more sustainable option.

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26579

Received: 02/03/2020

Respondent: Suffolk County Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The County Council welcomes the commitment to coordinate development across boundaries. This area is outside district or local centres buffers defined on Plan 1. NPPF p.92 states that planning policies should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services. P.103 states that the planning system should limit the need to travel, through an appropriate mix of uses. To enable access to services and make future communities in the area defined by ISPA4 sustainable, the policy should state the masterplanning of the site should also consider the inclusion of a local centre.

Change suggested by respondent:

In order to enable access to services and make future communities in the area defined by ISPA4 sustainable, the policy should state the masterplanning of the site should also consider the inclusion of a local centre. This will also help to keep the plan more internally consistent e.g. with paragraph 6.17.

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26590

Received: 02/03/2020

Respondent: Bloor Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

There is a lack of a coordinated approach, with allocations proposed within Ipswich. Concerned that spatial strategy has been unduly influenced by the administrative boundary, e.g. SHELAA only looking at sites within IBC. The Site has the potential to help meet housing needs within a location (East of Ipswich) which has already been tested through the Suffolk Coastal Local Plan plan-making process and found to be a sustainable location for growth. Do not consider the Site has been robustly assessed, subsequently a sustainable option for growth being rejected without justification. 200 homes (shorter term) and 1,200 homes (medium term)

Change suggested by respondent:

Allocate site identified at Humber Doucy Lane.

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26629

Received: 02/03/2020

Respondent: Ipswich School

Agent: Mr Matt Clarke

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to allocation of land at the northern end of Humber Doucy Lane (ISPA4.1), with suggested alternative reference to allocation of land west of Tuddenham Road, north of Millenium Cemetery (21.81ha, with capacity for 500 dwellings), albeit not necessarily involving cross boundary working given containment within Ipswich Borough.
Land west of Tuddenham Road, north of Ipswich Millennium Cemetery would be more appropriate, better related to the Ipswich Garden Suburb development, and therefore more sustainable, by virtue of reducing the need for travel by private car, improving pedestrian and cycle access and enabling a more consolidated and comprehensive form of development. See accompanying letter for details.

Change suggested by respondent:

Allocate land west of Tuddenham Road, north of Millenium Cemetery (21.81ha, with capacity for 500 dwellings) instead of Humber Doucy Lane (ISPA4.1).

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26658

Received: 02/03/2020

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Site includes Grade II Listed Everton School Westerfield House, and adjacent to/within the setting of other Grade II Listed buildings (Allens House, and Laceys Farmhouse). Development must preserve and where possible enhance these assets and their settings where this setting contributes to significance. Heritage Impact Assessment required, which must assess the contribution this land makes to those elements which contribute towards the significance of the heritage assets (designated and non-designated), and determine what impact its development might have upon their significance. Any specific measures required to remove/ mitigate any harm should be included in a site specific policy for ISPA4.1.

Change suggested by respondent:

Heritage Impact Assessment of ISPA4.1 required. Any specific measures required from the assessment then integrated into a site specific policy.

Attachments: