Proposed Submission Core Strategy and Policies Development Plan Document Review

Object

Representation ID: 5361

Received: 05/03/2015

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The obligations to secure 15% energy provisions from decentralised sources or to achieve 'significant' reductions in carbon emissions are not justified nor is it consistent with national policy. The obligations should be deleted.

Object

Representation ID: 5362

Received: 05/03/2015

Respondent: Mersea Homes Limited

Legally compliant? Yes

Sound? Yes

Duty to co-operate? No

The Council has failed to demonstrate how it has met the Duty to Cooperate. CS2(b) explains that housing need will be met in the wider Ipswich Policy Area. Table 3 (CS7) further reinforces the degree to which the Council depends on adjoining authorities. The Council have not yet secured agreement to meet its housing need in adjoining authorities. It must therefore focus on demonstrating and justifying as part of this plan, what need it can meet, and identifying the infrastructure necessary to support that amount of development. CS2 should provide the overall narrative of this approach. [Logged also to para4.4]

Object

Representation ID: 5363

Received: 05/03/2015

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

The Council has failed to demonstrate how it has met the Duty to Cooperate. CS2(b) explains that housing need will be met in the wider Ipswich Policy Area. Table 3/CS7 further reinforces the degree to which the Council depends on adjoining authorities. The Council have not yet secured agreement to meet its housing need in adjoining authorities. It must therefore focus on demonstrating and justifying as part of this plan, what need it can meet, and identifying the infrastructure necessary to support that amount of development. CS2 should provide the overall narrative of this approach. [Also logged as CS2 objection]

Object

Representation ID: 5364

Received: 05/03/2015

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

We do not consider that the Borough has adequately demonstrated that it has met the Duty to Cooperate. The requirements of the Duty, as explained by the NPPF and Planning Practice Guidance, are for key issues to be considered and addressed during plan-making, and for clear outcomes to be reflected in policy. The Council must focus on identifying its full objectively assessed need, and justifying the extent to which it can meet a proportion of that need. Policy CS6 should provide the basis for it to secure agreement with adjoining authorities in the longer term.

Object

Representation ID: 5365

Received: 05/03/2015

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy CS7 relies upon evidence which is not up to date. In order to be certain that the full objectively assessed housing need has been identified, further updates to evidence are required. Notwithstanding the issue of evidence, Policy CS7 does not provide an adequate or sound basis for meeting housing need, since it is reliant on unidentified sources of housing land, including those outside the Ipswich Borough administrative area, to meet that need. The Council should focus on identifying the proportion of its full objectively assessed need that it can meet, and plan effectively to deliver that.

Object

Representation ID: 5369

Received: 05/03/2015

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support the allocation of the Ipswich Garden Suburb as a key element of the spatial strategy. However CS10 is not effective since it establishes inflexible and overly detailed policy requirements. The land use budget, land use annotations set out on the Proposals Map, and the details set out in Table 8B should be deleted. The IGS is supported by a draft SPD which provides a more flexible means of co-ordinating long term development. However, we have concerns that viability has not been fully reflected in the guidance. Including SPD detail in policy reduces flexibility to deal with changing circumstances.

Object

Representation ID: 5370

Received: 05/03/2015

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The requirement for 'at least' 35% affordable housing provision in the IGS is not justified by the evidence, nor does it contribute to an effective policy. CS12 has reduced the affordable housing target on sites other than IGS. We don't believe there is evidence to support this policy position; rather evidence indicates that the target for the IGS should also be reduced. The NPPF makes it clear (paragraphs 173-177) that local plan policy should not place an undue burden on development. Maintaining a 35% affordable housing target for the IGS will render it unviable, and will stall its delivery.

Object

Representation ID: 5371

Received: 05/03/2015

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The provisions of DM1 are not consistent with national policy on sustainable design and construction and are contrary to the provisions of paragraphs 95 and 173 of the NPPF. The Code for Sustainable Homes is not mandatory, and is to be replaced by provisions under the Building Regulations. These critical national policy imperatives must be reflected in DM1 if it is to be a sound policy. The Council's whole-plan viability evidence (which we consider optimistic) demonstrates that the obligations set by DM1 have a detrimental effect on viability to the effect that it could determine whether sites would be deliverable.

Object

Representation ID: 5373

Received: 05/03/2015

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The provisions of Policy DM2 are not consistent with national policy on sustainable design and construction and are contrary to the provisions of paragraphs 95 and 173 of the NPPF. The evidence base which purports to assess the viability implications of the policy demonstrates that this policy has a significant impact on the viability of sites, and will therefore affect deliverability. The Borough's own evidence also failed to assess the implications of the Policy on the IGS. The policy cannot therefore be considered the most appropriate strategy.