Proposed Submission Core Strategy and Policies Development Plan Document Review

Object

Representation ID: 20196

Received: 03/03/2015

Respondent: Ipswich Rugby Football Club (Ipswich RFC)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is unsound to allocate the entire Northern Fringe when its delivery may not be viable over the plan timescales. To lower this risk the CS should include a plan based on co-operating more closely with neighbouring LAs to deliver homes growth. The CS cannot guarantee delivery of the Country Park in a timely manner and so demonstrate it will not adversely affect the integrity of a European designated habitat. For soundness, policy CS10 and Infrastructure Table 8B need to be revised. Allocating the entire Northern Fringe for immediate development through multi-site starts is a high risk strategy that will result in severe traffic congestion for both North Ipswich and the town centre and will damage the future attractiveness and prosperity of town. With so few new jobs being created in the town centre, residents will have to commute by car to jobs growth sites. The effectiveness of the Core Strategy to deliver the Ipswich Garden Suburb is doubtful without additional road improvements. In response to a planning application by Mersea Homes /CBRE Global Investors for the first phase of the Ipswich Garden Suburb, Suffolk County Council stated with regard to traffic '... the development has a severe impact on network performance and travel time.' IBC has been pinning their hopes on getting people out of their cars and onto public transport but with so few new jobs being created in the town centre, residents will mainly have to commute by car to jobs growth sites. The effectiveness of the Core Strategy to deliver the Ipswich Garden Suburb is doubtful without additional road improvements and capacity such as a northern bypass or link road. New measures will also be required to ensure air quality does not deteriorate.

Object

Representation ID: 20197

Received: 03/03/2015

Respondent: Ipswich Rugby Football Club (Ipswich RFC)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

A recent report by Peter Brett Associates (listed on the IBC website) calls into question the viability of developing new offices, industrial units, warehousing and large retail offerings with Ipswich. This challenges the ability of the CS to deliver the massive jobs growth target. For soundness the CS needs to address the severe obstacle to growth identified and produce a specific and realistic jobs target for the Borough of Ipswich.

Object

Representation ID: 20198

Received: 03/03/2015

Respondent: Ipswich Rugby Football Club (Ipswich RFC)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Traffic congestion has always been a key concern for residents. The CS fails to properly assess development and infrastructure requirements including the cumulative effects on traffic, air pollution, fresh water and wastewater. As such the plan will not be effective and is unsound. Updated traffic and air quality modelling should be undertaken and development not be permitted unless effective mitigation methods can be implemented. Freshwater and waste water infrastructure needs to be objectively assessed and key infrastructure listed in the CS. The risks to delivery should be identified.

Object

Representation ID: 20199

Received: 03/03/2015

Respondent: Ipswich Rugby Football Club (Ipswich RFC)

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

IBC has not demonstrated that it has effectively worked with neighbouring Authorities on cross boundary issues affecting jobs, housing and infrastructure since there are no published results nor results incorporated into the CS. This does not accord with the 2011 Localism Bill and consequently the CS should not be adopted. IBC needs to demonstrate that the strategic purchase of the old sugar beet factory was with the prior agreement of Babergh Council.
IBC needs to explain in the CS how this strategic purchase aligns with employment and housing growth strategies and targets [to focus new employment within the town centre].

Object

Representation ID: 20200

Received: 03/03/2015

Respondent: Ipswich Rugby Football Club (Ipswich RFC)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Without properly defined specific and measurable jobs growth objectives the CS is unsound. Two jobs targets are required: one for the Borough and one for outside the Borough. Measurement indicators are needed.
The housing target is so poorly defined as to be ineffective. To improve soundness a specific, realistic and measurable housing growth target is required for the Borough of Ipswich, based on the best available data and forecasts. IBC plans to help grow housing in neighbouring LAs. This needs to be explained and agreed with neighbouring LAs, together with a plan of how it will be achieved and measured.

Object

Representation ID: 20201

Received: 03/03/2015

Respondent: Ipswich Rugby Football Club (Ipswich RFC)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Council's population forecast should not be based on a high immigration scenario, which is inconsistent with the policies of all the main political parties.

Object

Representation ID: 20202

Received: 03/03/2015

Respondent: Ipswich Rugby Football Club (Ipswich RFC)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Traffic congestion is a key concern for residents. The CS fails to properly assess development and infrastructure requirements including the cumulative effects on traffic, air pollution, fresh water and wastewater. The plan will not be effective and is unsound. Updated traffic and air quality modelling should be undertaken and development not be permitted unless effective mitigation can be implemented. Fresh/waste water infrastructure needs to be objectively assessed and key infrastructure listed in the CS. The risks to delivery should be identified. There is a lack of sewage pipeline capacity between the Garden Suburb and Cliff Quay treatment works.

Object

Representation ID: 20203

Received: 03/03/2015

Respondent: Ipswich Rugby Football Club (Ipswich RFC)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

For improved effectiveness and soundness it is recommended a target be reinstated for the use of brownfield land with priority given to regenerating these sites in preference to developing the Northern Fringe greenfield site.