Proposed Submission Core Strategy and Policies Development Plan Document Review

Object

Representation ID: 5275

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Duty to co-operate is not met as the Plan fails to properly set out a long term strategy to meet future development needs, the Council has not adequately engaged in co-operation with neighbouring authorities in advance of the preparation of the Plan.

There is a recognition that the Council has not met the requirement under toe NPPF to identify sufficient sites, and that the Council and its neighbouring authorities so need to work together to achieve a robust strategy and there is an admission that the work that is needed hasn't been done yet.

Object

Representation ID: 5276

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraph 1.8 of the Plan states that the purpose is to set out the strategy for the future development of Ipswich to 2031. The principal concern is that the Plan fails to do this. The Plan only shows locations for 44.7% of the 10,585 additional homes over and above existing commitments needed between now and 2031.

Object

Representation ID: 5280

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The green rim designation has no clear purpose or evidence base to support it- it appear in part to be justified in relation to connecting ecological/ natural and semi-natural green space ( although without any clear explanation as to why this is necessary). In a context where the plan is failing to both meet objectively assessed housing need and failing to make use of appropriate development opportunities within the Borough boundary the designation of a green rim is premature and prejudicial to the proper long-term planning of the area.

Object

Representation ID: 5281

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraph 4.4 refers to the Duty to co-operate, it is evident from the failure of this plan to properly set out a long-term strategy to meet future development needs that he Council has not adequately engaged in co-operation with neighbouring authorities in advance of the preparation of this Plan.

Object

Representation ID: 5284

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The designation of the green rim has no clear purpose or evidence base to support it. In the context where the plan is failing to both meet objectively assessed housing need and failing to make use of appropriate development opportunities within the Borough boundary the designation of a green rim is premature and prejudicial to the proper long term planning of the area.

Object

Representation ID: 5285

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The designation of the green rim has no clear purpose or evidence base to support it, in the context of the plan failing to meet objectively assessed housing need and failing to make use of the appropriate development opportunities within the Borough boundary, the designation of a green rim is premature, and prejudicial to the proper long-term planning of the area.

Object

Representation ID: 5288

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Objective 3 states that at least 13,550 new homes are to be provided within the Ipswich Housing Market Area, but the plan do not achieve that Objective.

Object

Representation ID: 5310

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraph 1.2 of the plan states that the purpose is to set out a strategy for the future development of Ipswich to 2031, the Plan only manages to show locations for 44.7% of the 10,585 additional homes over and above existing commitments needed between now and 2031.

Object

Representation ID: 5311

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraph 6.14 seeks to justify why new housing development is necessary in Flood zone 3, and does this on the basis that there is insufficient suitable land elsewhere for meeting housing need, as presently drafted, the Core Strategy is not maximising the use of suitable housing land within the Borough outside Flood zone 3, paragraph 6.14 requires amendment to cross refer to the fact the such additional opportunities have been maximised in advance of additional housing within flood zone 3.

Object

Representation ID: 5313

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

There is a recognition that the Council has not met the requirement under the NPPF to identify sufficient specific sites for the 1-10 years or broad locations for 11-15 years therefore does not meet the objectively assessed needs for housing. There is also a recognition that the Council and neighbouring authorities need to work together and there is an admission that the work that is needed hasn't been done yet.