Support

Representation ID: 26214

Received: 21/02/2020

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

S106 is very important when providing health infrastructure and up until recent this has just been accessible to primary care providers through the CCG. NHS England has now provided instructions that all health providers should be looking to request mitigation through S106 or CIL as part of the planning application response process. As part of this process, developments over 250 dwellings will automatically go to the Alliance partners in health for them to make representation and request mitigation. The inclusion of GP surgeries and health centres as key strategic infrastructure is to be commended as this will allow the CCG to strategically plan ahead with the understanding that providing the business case is sustainable it will more likely get approval.

Object

Representation ID: 26265

Received: 26/02/2020

Respondent: East Suffolk and North Essex NHS Foundation Trust (ESNEFT)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

It is noted that health and emergency services are again referred to, although there is no specific reference to acute hospital facilities. Therefore point 3 and bullet point 7 of the policy wording require amendment.

Object

Representation ID: 26405

Received: 02/03/2020

Respondent: East Suffolk Council

Agent: East Suffolk Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Categories detailed in CS17 broadly in line with infrastructure commitments in SCLP2.2 of the Suffolk Coastal Final Draft Local Plan. Requirement for cross-boundary cooperation identified in Statement of Common Ground. Noted that CS17 refers to infrastructure to be secured from new development including early years provision. However, not clear in Table 8A of the plan whether early years provision in north east Ipswich is identified as an infrastructure priority, consistent with the Statement of Common Ground. Council has included criterion within SCLP12.24 for provision of early years setting on site, if needed. Recommend that this is replicated in ISPA4.

Object

Representation ID: 26410

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Not clear what RAMS S106 payments agreed with CBRE and Crest sites as S106 are not publicly available. If no RAMS tariffs included in the S106 agreements this could be in breach of this SPD and policies CS4, CS17 and Policy DM31 of the adopted CS. New CS would be unsound in relation to CS4 CS17 and DM 8 as no means of funding the required.

Object

Representation ID: 26459

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

Para. 8.218 - Support the collaborative working on the Recreational disturbance Avoidance and Mitigation Strategy (RAMS), although need to ensure that any RAMS contributions collected are spent to mitigate the impact from the development that has generated the need for the RAMS contribution.

Object

Representation ID: 26528

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Not clear what RAMS S106 payments agreed with CBRE and Crest sites as S106 are not publicly available. If no RAMS tariffs included in the S106 agreements this could be in breach of this SPD and policies CS4, CS17 and Policy DM31 of the adopted CS. New CS would be unsound in relation to CS4 CS17 and DM 8 as no means of funding the required.

Object

Representation ID: 26535

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No firm proposals for new sewage infrastructure required for the IGS and the wider Ipswich area, which need to be consulted upon and included in the Infrastructure Tables. The 13 transport projects need to be included in the Infrastructure Tables. If any of projects aren't delivered by the required dates (which need to be identified) then the traffic modelling will be flawed as traffic flows will not have been properly assessed and the CS unsound. Evidence needed showing funding is in place for these schemes compatible with required delivery dates. Bramford Road/ Sproughton Road link road must be included.

Object

Representation ID: 26536

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No firm proposals for new sewage infrastructure required for the IGS and the wider Ipswich area, which need to be consulted upon and included in the Infrastructure Tables. The 13 transport projects need to be included in the Infrastructure Tables. If any of projects aren't delivered by the required dates (which need to be identified) then the traffic modelling will be flawed as traffic flows will not have been properly assessed and the CS unsound. Evidence needed showing funding is in place for these schemes compatible with required delivery dates. Bramford Road/ Sproughton Road link road must be included.

Object

Representation ID: 26541

Received: 02/03/2020

Respondent: Department for Education (DfE)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

While DfE supports Policy CS17, we request a minor amendment either to the policy or its supporting text, to clarify that developer contributions may be secured retrospectively, when it has been necessary to forward fund infrastructure projects in advance of anticipated housing growth. An example of this would be the local authority’s expansion of a secondary school to ensure that places are available in time to support development coming forward. This minor amendment would help to demonstrate that the plan is positively prepared and deliverable over its period.

Object

Representation ID: 26625

Received: 02/03/2020

Respondent: Councillor Oliver Holmes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Financing infrastructure through developer contributions is difficult in Ipswich as net profit margins are low and contributions are challenged by developers on viability grounds. For example, Ipswich Garden Suburb required a grant of £9.8 million from the Housing Infrastructure Fund in order to proceed. The Draft needs to reflect this difficulty otherwise it is unsound.