Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications

Object

Representation ID: 24267

Received: 20/11/2015

Respondent: Home Builders Federation Ltd (HBF)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Requiring residential development to achieve a 19% improvement in energy efficiency over Part L of the Building Regulations is contrary to national policy in the Written Ministerial Statement March 2015, the Deregulation Act 2015 (S.43), and Fixing the Foundations July 2015. The Government is not proceeding with zero carbon Allowable Solutions or the proposed 2016 increase in on-site energy efficiency standards. It does not wish LPAs to set targets higher than the Building Regulations. The Council cannot require that applicants go further than Part L 2013. The Council should also consider the viability implications of the water efficiency standard.

Object

Representation ID: 24268

Received: 20/11/2015

Respondent: Home Builders Federation Ltd (HBF)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy in relation to the Part M optional technical standards is unsound because the adoption of these optional technical standards has not been justified. Before these can be adopted in the local plan the Council will need to demonstrate need and the effect on viability. The Viability Testing for the Ipswich Development Plan report, December 2014, has not assessed the cost of applying these standards. The DCLG report: Housing Standards Review: Cost Impacts, September 2014 summarises the costs (p.38). The Council will also need to justify the 35% figure for Part M(2) and the percentage figure for Part M4(3).

Object

Representation ID: 24269

Received: 20/11/2015

Respondent: Home Builders Federation Ltd (HBF)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The part of the policy in relation to residential development is unjustified. The policy requires that developments of 15 dwellings or more provide at least 10% of the area, or 15% in higher density schemes, as public green space. In view of the Council's inability to meet its OAN in full, and because there is no plan to provide for these unmet needs elsewhere, we consider that this policy requirement is unjustified.

Object

Representation ID: 24270

Received: 20/11/2015

Respondent: Home Builders Federation Ltd (HBF)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The requirement that new residential development complies with the Nationally Described Space Standard is unjustified. The Council has not demonstrated that the relevant tests set out in the NPPG have been satisfied (need, viability and timing). The Council should provide a justification for requiring the Nationally Described Space Standard. Given the scale of the unmet need in Ipswich, we would question the efficacy of adopting the standard. The plan should also specify a reasonable transition period to provide for legacy projects or land transactions currently underway. The Council should have regard to the effect the standard will have on affordability.