Proposed Submission Core Strategy and Policies Development Plan Document Review

Object

Representation ID: 5320

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We consider the overall Local Plan housing target contained within the Proposed Submission Core Strategy to be justified and positively prepared, and accordingly consistent with National Policy. IBC concludes that it has only 3.9 years' worth of supply (4,253 dwellings) based upon its adopted Core Strategy housing requirement (AMR December 2014). However, The PPG advises that the shortfall should be rectified within the first five years, which results in 3.26 years' of supply. This therefore places increased emphasis on the deliverability of the identified locations for growth, including the Garden Suburb.

Object

Representation ID: 5322

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Yes

IBC has an agreement with neighbouring councils to undertake further policy work which addresses growth needs of the IPA, including potential unmet housing need from IBC. CSP therefore consider that IBC has demonstrated that it has engaged with neighbouring authorities and has a strategy in place to address its housing land supply. However, IBC is seeking to: "... rely on windfall sites and will work with neighbouring local authorities to address housing need later in the plan period (CS7)." IBC should ensure that it continues proactively to explore options of accommodating housing overspill through the whole plan period.

Object

Representation ID: 5324

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We fully support the continued allocation of the IGS (CS10). However, there is no evidence available to demonstrate how the triggers included within supporting Table 8B have been arrived at, and whether they represent an "appropriate stage" for delivery. CS10 and Table 8B do not have due regard to the need for a "comprehensive approach" to the development of IGS as a whole. There are currently no effective mechanisms in place to ensure the delivery of infrastructure or to ensure a collaborative approach to development, which will compromise the deliverability of IGS as a whole.

Object

Representation ID: 5327

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

CS10 is supported by Table 8B, which sets out the detailed infrastructure requirements and trigger points for their delivery. There is no evidence available to demonstrate how the triggers have been arrived [at], and whether they represent an "appropriate stage" for delivery. The policy and Table 8B do not currently have due regard to the need for a "comprehensive approach" to the development of IGS as a whole. There are no effective mechanisms in place to ensure the delivery of infrastructure, which will compromise the deliverability of IGS as a whole. See Appendix 1 of full submission for detailed comments.

Object

Representation ID: 5328

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy CS12 states that new developments at IGS will be required to provide for at least 35% on-site affordable housing. We understand that a viability appraisal has been undertaken to inform the delivery of the IGS, but question whether the Council seeking 35% affordable housing is robust and justified, especially when the affordable housing requirement is significantly lower at 15% elsewhere in the Borough. We seek further information on IBC viability assessment and reserve the right to comment further once this has been made available. As currently drafted, CS12 is not considered to be 'justified'.

Object

Representation ID: 5329

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Emerging Policy DM1 part a. seeks that all new build residential developments achieve a minimum of Level 4 for the Code for Sustainable Homes standard or equivalent. Whilst we in part support the principle of this emerging policy and welcome the removal of the onerous requirement to achieve Code Level 5 and 6 [in adopted policy DM1], we query whether seeking Code Level 4 on all development sites, we query the need for the Council to include such a policy given the Code requirements are dictated by Building Regulations.

Object

Representation ID: 5330

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Emerging Policy DM2: Decentralised Renewable or Low Carbon Energy replicates adopted Policy DM2 by requiring all new development of 10 or more dwellings to provide at least 15% of their energy requirements from decentralised and renewable or low-carbon sources. We object to the principle of this policy as there is no robust evidence base to justify the requirement and there has been no regard to potential viability issues.

Object

Representation ID: 5331

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

DM5 part i. introduces the provision of public art where this would be required to enhance the public realm and/or reinforce a sense of place. This could include new installations where this would be commensurate to the scale and type of development. We do not object to IBC seeking public art but expect any requests to be proportionate in scale and to allow for flexibility, taking into account the other contributions sought, to ensure that new developments remain viable and deliverable. The definition of 'art' should be flexible and cover the delivery of a wide range of products/installations.

Object

Representation ID: 5332

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Emerging Policy DM8: Heritage Assets and Conservation replicates adopted Policy DM8, but also combines the archaeology element of adopted Policy DM9: Buildings of Townscape Interest. Emerging Policy DM8 at part b. Conservation Areas, states that the position, height, mass and materials of a proposed building shall pay regard to the character of adjoining buildings and the area as a whole. Whilst we do not object to this policy, the weight that should be attached to the character of buildings should be proportionate to their status and this should be reflected in the policy wording to ensure that it is 'justified'.

Object

Representation ID: 5334

Received: 05/03/2015

Respondent: Crest Strategic Projects

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Emerging Policy DM17 part c. seeks to incorporate electric charging points and part f. seeks safe and convenient access to public transport within 400m. The provision of electric charging points within a development will not be necessary for development to come forward in a sustainable way. DM17f. is not necessary for all development sites, e.g. it does not take into account sites that are within reasonable walking distance of local services which would not necessarily need to be served by public transport. The policy should therefore be reworded to reflect individual site circumstances to ensure it is 'justified' and 'effective'.