Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications
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Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications
2 - CS2 The Location and Nature of Development (MOD 1)
Representation ID: 24310
Received: 21/12/2015
Respondent: Gladman Developments
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
This change introduces a rather vague reference to 'community development' with no definition provided as to what this means in this context. This contravenes §154 of the [National Planning Policy] Framework.
Clarity is important because this section of the policy outlines where new development will be focussed. It has a strong 'geographic' thrust, so it is unclear how the reference to supporting community development fits with this.
The aim of ensuring that new development promotes wellbeing and social inclusion is already embedded within national policy.
See attachment
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Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications
4 - CS4 Protecting our Assets (MOD 1)
Representation ID: 24311
Received: 21/12/2015
Respondent: Gladman Developments
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We have concerns with the proposed modification, which refers to using planning obligations to 'secure the enhancement and promotion of the significance of any heritage asset'.
Three tests for the use of planning obligations are set out in Regulation 122, Paragraph 2 of the CIL Regulations (as amended):
A planning obligation may only constitute a reason for granting planning permission for the development if the obligation is—
(a) necessary to make the development acceptable in planning terms;
(b) directly related to the development; and
(c) fairly and reasonably related in scale and kind to the development.
See attachment
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Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications
16 - DM1 Sustainable Design and Construction
Representation ID: 24312
Received: 21/12/2015
Respondent: Gladman Developments
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The Deregulation Bill 2015 specifies that Councils cannot set any additional local technical standards relating to the construction, internal layout or performance of new dwellings other than the nationally described space standard, an optional requirement for water usage and optional requirements for adaptable / accessible dwellings where these are supported by evidence of need and viability.
Furthermore, Gladman would remind the Council to pay careful attention to the requirements set out in §173 and 174 of the Framework regarding viability and not placing undue policy burdens on developers that the plan from being delivered.
See attachment
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Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications
34 - DM34 Countryside (MOD 1)
Representation ID: 24313
Received: 21/12/2015
Respondent: Gladman Developments
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Concerned that the policy creates a 'presumption against development' in many areas between the existing built-up settlement of Ipswich and the borough boundary.
The second part of the policy sets out that proposals for development in the countryside 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 can be protected under Green Belt policy (it being one of the main purposes) but not through restrictive blanket countryside policies.
See attachment