Object

Representation ID: 26298

Received: 28/02/2020

Respondent: Constable Homes Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Presume shortfall of 796 units is a result of the housing supply period being reduced to 2019-2036 (Table 4). Please clarify. Ipswich only delivered 46% of the minimum target. Previous year, the measurement for Ipswich Borough Council was 66%. This indicates that housing delivery has worsened and measures needed to recover the position. Also very close to the 45% threshold in 2019 NPPF paragraph 215b. Threshold will increase to 75% next year which reinforces the urgency of addressing the significant shortfall in housing delivery. Council should be proactively identifying opportunities to accelerate delivery to overcome the significant shortfall.

Object

Representation ID: 26300

Received: 28/02/2020

Respondent: Constable Homes Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Paragraph 73 (NPPF) states 20% buffer to the five year supply should be applied. This adds to significant challenge of meeting 75% of need. Assumed date is February 2021. No buffer applied to Policy CS7. To be effective, a buffer equivalent to one year’s supply (445 dwellings) should be added to five year housing land supply. Council is in a critical position of acute under supply and failing to quantify the need increases likelihood that unmet need won't be addressed. An immediate review of the Plan will be necessary if the Council is only targeting a capped need figure.

Object

Representation ID: 26311

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

Housing supply -
The HBF welcome the decision to include a 10% contingency within the Council's housing supply.
It is not evident which sites form the basis of supply within the first five years of the plan.
It will be necessary for the Council to provide a detailed site by site assessment of delivery across the plan period.
This is particularly important with regard to the five year supply given the amended definition of deliverable within the 2019 NPPF.
Until such evidence is provided the HBF reserve the right to comment on this issue.

Object

Representation ID: 26313

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

Stepped requirement - Policy is not sound, the stepped trajectory has not been justified. Agree with the proposed requirement for the plan period, however do not agree with the steps proposed. In too many cases the step is required on the basis of the strategy chosen by the Council. The approach is not sufficiently challenging and is more likely to lead to the whole plan under delivering. We would suggest:
2018/19 to 2019/20 - 300
2020/21 to 2023/24 - 375
2024/25 to 2035/36 - 493
This would ensure the Council can maintain a five year supply on adoption.

Object

Representation ID: 26315

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

Housing requirement - Policy not sound the housing requirement has not been justified. Paragraph 2a-024 of the PPG states that an increase in the total housing figures may be considered where it could help deliver affordable housing. The Council recognise in paragraph 8.151 affordable housing need is 239 dpa, around 48% of their requirement and as such they will not meet all of their need for affordable housing. Consideration should have been given with the other authorities in the ISPA whether more sites could be allocated elsewhere in the ISPA to meet the affordable housing needs of Ipswich.

Object

Representation ID: 26323

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

Housing requirement - Policy not sound the housing requirement has not been justified. The HBF is concerned that the desire for growth is not being matched by the Council's decision to adopt a housing requirement that is below previous assessment of need with regard to economic growth. The implicit suggestion would appear to be that any additional growth required will be covered by additional delivery elsewhere in the ISPA. However, there does not appear to be any assessment as to whether this will be sufficient and provided in appropriate locations to support the economic and jobs growth aspirations of Ipswich.

Object

Representation ID: 26406

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

The Council should plan for a higher level of housing need. The need figure generated by the standard method should only be considered as the minimum starting point. A stepped housing requirement is only appropriate where there is a significant change in the level of housing requirement between plans. Historic delivery does not suggest that the Borough’s housing need will be delivered as they are relying on historic sites with known issues as a continuation of the existing spatial strategy. The historic completions data suggests that the stepped housing requirement will continue to delay meeting identified housing needs. Continued reliance on IP-One to deliver homes in Ipswich is unfounded and unrealistic; further distribution across the HMA is required. The Council’s housing requirement will fail to meet economic and affordable housing needs. It is not evident which sites within the Council’s housing land supply will come forward within the next five years. The rate of delivery at Ipswich Garden Suburb is over estimated. The Council’s assumptions made in respect of the housing trajectory risk the deliverability of the Local Plan.

Object

Representation ID: 26426

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? Yes

Duty to co-operate? No

A prescriptive approach in the interpretation of the policy would limit opportunities to respond to market forces, and possibly result in more situations such as Griffin Wharf (site reference IP200) were the viability of development is being questioned. Persimmon also endorse the statements made by the HBF.

Object

Representation ID: 26445

Received: 02/03/2020

Respondent: Pigeon Investment Management Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy CS7 sets out a policy with the minimum housing number that Ipswich Borough Council proposes to deliver in its area. The Housing Land Supply only amounts to a total of 7,214 dwellings, including an allowance for windfall development. Therefore, the Council already acknowledge that they have an unmet housing need of 1,597 dwellings over the Plan period, taking into account the 10% contingency that is allowed for in the final paragraph of the policy. Steps should therefore be taken with the ISPAB to now identify locations outside the boundary of Ipswich Borough Council where this unmet need can be accommodated.

Object

Representation ID: 26452

Received: 02/03/2020

Respondent: Kesgrave Covenant Ltd

Agent: Kesgrave Covenant Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Although we generally support the Plan, it's policies and supporting text relating to the proposed allocation at Humber Doucy Lane, as currently drafted, it is neither justified nor effective as it should be specific about any infrastructure requirements that will influence timescales of delivery and should not make generic references to the site coming forward "as development draws to a conclusion at Ipswich Garden Suburb" without providing appropriate evidence and details. Recommend amendment to policy wording.

Object

Representation ID: 26456

Received: 02/03/2020

Respondent: Grainger Plc

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

There is a lack of evidence to support the proposed windfall rate which may mean unmet need will increase over the plan period;

Object

Representation ID: 26464

Received: 02/03/2020

Respondent: Babergh District Council & Midsuffolk District Council

Agent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy CS7 contradicts the text in paragraph 8.58. Whilst it is correct the Ipswich Housing Market Area authorities discuss the housing requirement for each local planning authority in the IHMA through the ISPA Board, before considering any implications for not being able to meet need, the text in paragraph C3 of the ISPA Statement of Common Ground Version 5 (October 2019 – signed January 2020) needs to be adhered to.

Object

Representation ID: 26582

Received: 02/03/2020

Respondent: Bloor Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No housing trajectory and the rate of delivery unknown. This is a significant failure. The Site can deliver a smaller scale housing development of around 200 homes within the early Plan period. Without full consideration of this and joint working to increase delivery, the stepped trajectory has not been justified and is unsound. Plan is also overly-reliant on delivery of IGS for stepped delivery. Question the overall housing requirement and whether the Council have adequately considered uplifting to support economic growth as this contradicts paragraph 8.168. Contrary to NPPF 35 and not positively prepared or effective.

Object

Representation ID: 26626

Received: 02/03/2020

Respondent: Ipswich School

Agent: Mr Matt Clarke

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to omission of reference to the need for inclusion of a 20% buffer to the 5 Year Housing Supply, given latest HDT; to the need to address the emerging delivery shortfall in this regard (77 dwellings within year 1); and need for increased focus on identification of sites that are deliverable in the initial 5 years.
The allocated sites component of housing supply should be increased on the basis that not all of the sites will be delivered within the Plan Period, a proportion have been allocated since 1997, others are reliant on relocation of existing uses. See accompanying letter for details.

Object

Representation ID: 26649

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

HDT identifies IBC only able to deliver 46% of identified need. Now requires a 20% buffer. Concerning paragraph 8.108 doesn't reference 20% buffer. Greater number of short/ medium-scale developments required to ensure consistent delivery. The Draft HDAP supports enhancement of small and medium-sized housebuilders, this is agreed. Our client willing to explore this developer consortium opportunities, exemplified though the current purchase of the neighbouring site. CS7 expects that 700 dwellings (50 annum) will be delivered on small windfall sites. Concerning AMR (2017-18) shows only 47 delivered. The Site would contribute to delivery of windfall. Support 100% PDL development in IP-One.