Proposed Submission Core Strategy and Policies Development Plan Document Review

Object

Representation ID: 5399

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support the efforts of the Council in using existing models and forecasts. However, the data is not up to date. ONS migration data used only goes up to 2010/11 whereas latest forecasts show no migration to Ipswich from 2012-2031. Immigration will take place in places with better jobs and wages. DCLG's household projections show a need for 10,434 homes. The baseline household figure used is too high.

Object

Representation ID: 5400

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Ipswich Viability Report showed that 'the indicative scheme average equated to 31.6% affordable housing provision by number and 28.4% by floor space, alongside the full provision of infrastructure.' It is therefore unsound to set a target of 35%. Since the Garden suburb infrastructure costs were developed other costs have arisen due to wastewater infrastructure.

Object

Representation ID: 5401

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Based on past trends, jobs are unlikely to grow by 625pa to 2031. EEFM forecasts are based on higher population projections than ONS projections and the sectors forecast to grow don't align with the Strategic Economic Plan. There is over-reliance on retail jobs. The target may not be achievable without government funding and improved transport infrastructure. Job forecasts in the Core Strategies of Ipswich and neighbouring authorities are 26% higher than EEFM and are unrealistic. Unclear whether the target relates to Ipswich or the Ipswich Policy Area. If the latter a separate jobs target must be established. Indicators are needed.

Object

Representation ID: 5402

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Viability Study challenges the deliverability of the Westgate site by stating that small comparison and convenience retail is marginally viable but large format convenience is not viable. This raises uncertainty over deliverability of jobs in the town centre. The Core Strategy does not mention the acquisition of the Sugar Beet Factory site which could take jobs away from the Borough.

Object

Representation ID: 5403

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support the vision but consider the strategy will not deliver it. The development of the Garden Suburb will result in severe congestion in north Ipswich and the town centre. Proposals to increase opportunities for buses, walking and cycling to the town centre are flawed as evidence challenges the viability of job creation in the town centre. Homes growth without jobs and sustainable transport will result in more commuting. This will harm prospects for investment. Updated traffic modelling and air quality modelling must be undertaken.

Object

Representation ID: 5404

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Core Strategy fails to take sufficient account of the waste water issues arising from proposed expansion of Ipswich. The Draft Strategic Economic Plan identified the scale and cost of new connections as inhibiting development of some strategic sites. The Water Cycle Study shows that significant upgrading is required to wastewater treatment capacity. The pipeline from north Ipswich to Cliff Quay is at capacity and no viable solutions for the Garden Suburb have been proposed. This could seriously undermine the delivery of the Core Strategy.

Object

Representation ID: 5405

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support the strategy of urban renaissance in Ipswich and note the first bullet point 'it will maximise opportunities to re-use previously developed land within central Ipswich.' The proposed removal of the 60% target for development on brownfield land is a negative step. With the multi-site development of the Garden Suburb concerned that developers will focus on greenfield development. This will have a detrimental impact on the regeneration of brownfield sites particularly in the town centre and deprived areas.

Object

Representation ID: 5406

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concern that the Country Park may not be delivered if only 499 homes are developed in Henley Gate or if only the other two parts of the Garden Suburb are developed. If the Country Park is delivered later that 2021 or not at all this will adversely impact on the integrity of a European site.

Object

Representation ID: 5407

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concern that the Country Park may not be delivered if only 499 homes are developed in Henley Gate or if only the other two parts of the Garden Suburb are developed. If the Country Park is delivered later that 2021 or not at all this will adversely impact on the integrity of a European site. The Core Strategy fails to identify and plan for key strategic wastewater infrastructure. There is the possibility that a major new pipeline will be needed from the Garden Suburb to Cliff Quay.

Object

Representation ID: 5425

Received: 03/03/2015

Respondent: Northern Fringe Protection Group

Number of people: 323

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

There is no public evidence on of any strategic policy outcomes from the IPA. There are no joint Topic Papers on housing growth, jobs growth and strategic infrastructure. Evidence base documents referred to in 8.70 have not been made available which is in breach of the Development Plan Document process. The Core Strategy should better ensure effective co-operation between Ipswich Borough Council and neighbouring authorities.