Proposed Submission Core Strategy and Policies Development Plan Document Review

Object

Representation ID: 5314

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraph 8.31 notes that beyond 2024, opportunities for development in the Borough boundary become more limited, and there will be a need to consider ways of meeting housing need outside the Borough boundary, it is incumbent on the Council to make best use of land within its own boundary before it relies this has not been done.

Object

Representation ID: 5316

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy CS2 sets out the principal locations for growth, the plan is failing to deliver enough land for housing and needs to achieve the maximum delivery possible from existing suitable sites within the Borough boundary. Part B of the policy refers vaguely to the potential for additional growth locations later in the Plan period, this approach is unsound.

Object

Representation ID: 5318

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan is failing to deliver enough land for housing, and needs to achieve the maximum delivery possible from existing suitable sites within the Borough boundary.

Object

Representation ID: 5333

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Our concerns in regard to the green rim are that the designation has no clear purpose or evidence base to support it, the plan is failing to 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: 5337

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The objection is that there is recognition that the Council has not met the requirement under the NPPF to identify wither specific sites in years 1-10 or broad locations for years 11-15. There is recognition from the Council that the Plan does not meet the objectively assessed housing need. There is recognition the the Council and neighbouring authorities need to work together to achieve a robust strategy, there is recognition that this work has not been done yet.

Object

Representation ID: 5341

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan is failing to deliver enough land for housing, and in that context, needs to achieve the maximum delivery possible from existing suitable sites within the borough boundary. The Key Diagram should identify additional suitable sites (including my client's land at north-east Ipswich). In addition, it is inappropriate for the Key Diagram to show a green rim around the edge of Ipswich, in advance of the formulation of long-term strategy for accommodating the number of new homes needed in the Plan period.

Object

Representation ID: 5343

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Objective 4 sets out the principal locations for growth. Whilst we do not object to the proposed locations, the Plan is failing to deliver enough land for housing, and in that context, needs to achieve the maximum delivery possible from existing suitable sites within the borough boundary. Objective 4 should therefore recognise the potential for additional growth locations.

Object

Representation ID: 5345

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraph 5.25 refers to the key challenges for Ipswich over the Plan period, but absent from the list of points raised is recognition of the fact the Plan is failing to deliver enough housing, because of constrained boundaries, an in this context needs to achieve the maximum delivery possible from existing suitable sites, before relying on assistance from neighbouring authorities.

Object

Representation ID: 5346

Received: 05/03/2015

Respondent: Kesgrave Covenant Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Based upon the sources of supply set out in Table 3, policy CS7 states that 5,434 new homes will be allocated for development through the Site Allocations Plan, the Plan is failing to deliver enough land for housing, and needs to achieve the maximum delivery possible from the existing suitable sites within the Borough boundary.