Proposed Submission Core Strategy and Policies Development Plan Document Review
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Proposed Submission Core Strategy and Policies Development Plan Document Review
10: Table 8B
Representation ID: 5279
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Table 8B refers to three 420-place primary schools. The County Council requires three 315-place primary schools as the minimum necessary resulting from the development. Experience of other large greenfield developments suggests that they generate greater demand for education places than existing housing. It is intended that land is provided such that the schools can be constructed with a larger (420-place) capacity, if monitoring of the number of children emanating from the development necessitates it. In the initial phases, the primary schools will not be constructed for more than 315 pupils each; this enables flexibility whilst meeting statutory requirements for proportionality.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
DM8 - Heritage Assets and Conservation
Representation ID: 5282
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The County Council understands the role of the Area of Archaeological Importance (AAI) to be descriptive; i.e. alerting developers to areas where the high potential for significant archaeological assets may necessitate detailed archaeological investigation as part of the development process. At present, DM8 applies differing investigation procedures for inside and outside the AAI. Whilst the County Council supports a more stringent pre-determination investigation requirement within the AAI, the reference to applying archaeological monitoring conditions as standard is not appropriate given the significance of the Historic Environment Record in this part of Ipswich.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
8.42
Representation ID: 5283
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Paragraph 8.42 [CS4] could better describe the significance of the AAI. 'An Area of Archaeological Importance for remains of all periods in the historic core, particularly Anglo Saxon deposits.'
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
9.73
Representation ID: 5286
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The following words should be inserted in the supporting text for DM8 to help define the reasoning behind the AAI:
'The settlement of Ipswich has developed through Saxon, Medieval and later periods, leaving a legacy of history below ground which tells the complex story of the town's evolution. To ensure that this invaluable and irreplaceable historical, cultural and educational resource is not lost or damages, the planning process must ensure that development proposals respect archaeologically important sites.'
The Borough Council should also consider amending the Core Strategy to reflect the emerging proposal for an Archaeological Supplementary Planning Document.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
DM25 - Protection of Employment Land
Representation ID: 5287
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The County Council as Minerals and Waste Planning Authority considers the Ipswich Local Plan to be generally consistent with the Suffolk Minerals and Waste Plans. In order to support the provision of sustainable waste management facilities, e.g. Household Waste and Recycling Centres, amend DM25 to make it clear that, where compatible with adjacent uses, waste facilities can come forward on land allocated for employment. This amendment would better enable the delivery of employment-generating civic amenity sites, whilst still protecting other employment uses. Other policies, such as DM26, would ensure that sufficient weight is given to the protection of amenity
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
CS16: Green Infrastructure, Sport and Recreation
Representation ID: 5289
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
In order to meet the requirements of the Habitats Regulations, the Borough Council should liaise with Natural England to ensure that any recommended measures to avoid likely significant effects on the features of designated sites should be put in place. A further amendment is suggested to ensure Objective 6 is realised in relation to Rights of Way. Wording is suggested to add to the supporting text to CS16, to emphasise the role of the Public Rights of Way network as a major recreational resource, economic asset and means of promoting mental and physical health.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
DM10 - Protection of Trees and Hedgerows
Representation ID: 5290
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The Borough Council may consider a minor amendment to the supporting text of Policy DM10 to make reference to the Hedgerow Regulations.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
DM31 - The Natural Environment
Representation ID: 5291
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Policy DM31 appears to be a useful tool for applying the Framework's requirement to protect and enhance the natural environment. However, in order to be sound, the policy needs to refer to protected species in addition to Priority species, and 'priority species' rather than 'biodiversity action plan species' because there is no longer a national list of BAP species. An amendment is proposed to ensure that the plan is compliant with the legal duty set out by the Natural Environment and Rural Communities Act 2006. Reference should also be added to 'Biodiversity: Code of Practice for Planning and Development' (BS42020).
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
DM28 - Protection of Open Spaces, Sport and Recreation Facilities
Representation ID: 5292
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policies CS5, CS16, CS20, DM5, DM17 and DM34 promote the development of the Rights of Way Network. Useful supporting text exists at paragraphs 8.63 and 9.99. However an amendment is required to protect the Public Rights of Way Network. Suggest amending DM28 by adding 'Rights of Way' to the title and add text at the end: 'Development which may affect Rights of Way will not be permitted unless it can demonstrate how it protects or enhances the network. Where development cannot avoid detriment to the Rights of Way Network, it should demonstrate how suitable alternative provision will be made.'
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
DM34 - Countryside
Representation ID: 5293
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy DM34 refers to the Area of Outstanding Natural Beauty, in line with the requirements in the Framework. However, the policy does not explicitly deal with the impacts of development outside the AONB on the character and qualities of the AONB. Other locally protected landscapes, which exist outside the Borough boundaries but potentially within sight of new development are not referred to, which is not consistent with paragraph 109 of the Framework.
See attached.