Proposed Submission Core Strategy and Policies Development Plan Document Review

Policy CS1: Sustainable Development - Climate Change
This policy sets out various measures for tackling climate change over the plan period. These include a requirement for new developments to incorporate energy conservation and efficiency measures, seeking opportunities to develop renewable energy-generating capacity, supporting the implementation of a number of related plans and strategies and promoting a modal shift to reduce carbon emissions. It also proposes a requirement that all major developments should achieve a target of at least 15% of their energy requirements through decentralised renewable or low carbon energy sources where feasible and viable. Gladman would emphasise that policies such as these should comply with the provisions set out in paragraphs 173 and 174 of the Framework. These require that pursuing sustainable development requires careful attention to be paid to viability and costs in plan-making, and should

assess the likely cumulative impacts (my emphasis) on development of such policies and standards so that the viability of the plan itself is not compromised through making the proposed scale of development unviable. The Inspector needs to be satisfied that this is indeed the case.

Policy CS2: The Location and Nature of Development
The Framework sets out the Government's objective to boost significantly the supply of housing and how this should be reflected through the preparation of Local Plans. In this regard it sets out specific guidance that local planning authorities must take into account when identifying and meeting their objectively assessed housing needs. This is underpinned at paragraph 47 of the Framework which states:
To boost significantly the supply of housing, local planning authorities should:
- Use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area.
- Identify and update annually a supply of specific deliverable sites sufficient to provide five years' worth of housing against their housing requirements...
- Identify a supply of specific, developable sites or broad locations for growth, for years 6-10, and where possible for years 11- 15.
Policy CS2 takes a two-step approach. It focusses new residential development initially into the town centre, the Waterfront, Ipswich Village, and Ipswich Garden Suburb and into or within walking distance of the town's district centres and only later in the plan period does it propose to work with neighbouring authorities to address housing need within the wider Ipswich housing market area. Gladman are concerned that this approach does not comply with the requirement of the Framework outlined above to significantly boost the supply of housing, as it serves to delay the development of otherwise suitable sites that could meet housing need now.
In seeking to leave decisions around addressing the needs of the wider housing market area to an unspecified point 'later in the plan period' the policy also does not comply with paragraph 178 of the Framework, which states that "public bodies have a duty to cooperate on planning issues that cross administrative boundaries" and paragraph 179, which states that "local planning authorities should work collaboratively with other bodies to ensure that strategic priorities across local boundaries are properly coordinated". It goes on to say that "joint working should enable local planning authorities to work together to meet development requirements which cannot wholly be met within their own areas - for instance, because of a lack of physical capacity and clearly reflected in individual Local Plans".
Paragraph 181 of the Framework further sets out that "cooperation should be a continuous process of engagement from initial thinking through to implementation, resulting in a final position where plans are in place to provide the land and infrastructure necessary to support current and projected future levels of development". Leaving decisions until later hardly represents being in a 'final position'.
PPG provides further explanation of how the policies contained within the Framework should be interpreted and applied. In terms of the Duty to Cooperate, PPG sets out that "local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before they submit their Local Plans for examination1" (my emphasis). Deferring decisions around addressing housing need within the wider Ipswich housing market area to a later date is clearly not in line with the requirements of the Framework or PPG.

Policy CS8: Housing Type and Tenure
Policy CS8 sets out the mix of dwelling types to be provided through the plan in order to achieve mixed and sustainable communities. The supporting text (paragraph 8.84) for the policy establishes that it is supported by a Strategic Housing Market Assessment (SHMA) published in 2008 along with the most recent update in August 2012. However since that time, new 2012-based Sub-National Household Projections have been published, and it is these that should form the starting point for any comprehensive assessment of objectively assessed housing need, as per PPG2.
In relying on out of date population projections, Gladman are concerned that the plan does not meet the requirement set out in paragraph 158 of the Framework that LPAs "should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area". The Council's SHMA needs to be updated in line with the latest available evidence and the policy and plan amended to reflect any change as a result.

Policy DM2: Decentralised Renewable or Low Carbon Energy
Gladman reiterate the point made above when discussing policy CS1 that in seeking to ensure that all new build development of 10 or more dwellings shall provide at least 15% of their energy requirements from decentralised and renewable or low-carbon sources, this policy should comply with the requirements set out in paragraphs 173 and 174 of the Framework.

Policy DM17: Transport and Access in New Developments
This policy deals with promoting sustainable growth and sets outs measures to reduce the impact of traffic congestion from new development. As well as requiring new developments not to result in a significant impact on air quality or an Air Quality Management Area, incorporating electric vehicle charging points where appropriate and ensuring that they provide cycle storage and promote pedestrian and cycle sustainability, the policy also requires that new developments have safe and convenient access to public transport within 400m, and facilitate its use through the provision of services, infrastructure and/or tickets where required.
Gladman has concerns that the current wording of this requirement takes too narrow an approach to sustainability, one based on simple distances to services, in this case public transport. Gladman believe that this is an outdated approach to understanding sustainability and does not take into account changes in people's lifestyles, the increase in levels of homeworking and the availability of an increasing range of services online and via home delivery, which are all serving to change people's travel patterns.
Gladman believes the wording of this policy should be amended to introduce an element of flexibility to make clear that whilst the distance specified should be a consideration, it should be weighted in the planning balance against the positive benefits of a particular scheme when determining the acceptability of development proposals.
The policy also requires that new development not result in a significant impact on the highway network. Gladman would draw attention to paragraph 32 of the Framework which states that "Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe" (my emphasis) rather than 'significant'. This part of the policy should be amended to ensure it is in line with the Framework.

Policy DM34: Countryside
This policy restricts major development in areas identified on the policies map as Countryside to that which is necessary to support a sustainable rural business including tourism, or is a recreational use of land which retains its open character.
The policy appears to be based on the old PPS7 Policy, which took a restrictive stance to development in rural areas. There is nothing in the Framework which states that development in the open countryside should be restricted in the extensive manner which this proposed policy suggests. Instead, Gladman suggest the policy should take a more permissive stance. In reality, in its current form, Policy DM34 creates a 'presumption against development' in many areas between the existing built-up settlement of Ipswich and the borough boundary. The policy's supporting text (paragraph 9.214) recognises that "Ipswich has a tightly drawn Borough boundary so countryside at the periphery of the Borough is not physically remote from the urban area." Concern is raised here that "development which would be relatively isolated in terms of access to public transport and community facilities should be avoided" but this is too restrictive and ignores the possibility of sites in these locations contributing to improving public transport connectivity and providing additional community facilities. The sustainability of such sites should be judged on a case-by-case basis through the planning balance exercise.
Gladman recommend that this policy needs to be significantly revised to provide a more permissive approach to development in the open countryside. We suggest the following rewording to this element of the policy:
"Development in the Open Countryside adjacent to existing settlements will be permitted provided that the adverse impacts do not significantly and demonstrably outweigh the benefits of development."
The second part of the policy sets out that proposals in the development should, amongst other things, "maintain the separation between Ipswich and surrounding settlements"
Gladman believe that policies which seek to protect gaps between settlements are not consistent with the Framework. Gaps between settlements should be protected under Green Belt policy (it being one of the main purposes) and not through restrictive blanket countryside policies.