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

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Support

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

2 - CS2 The Location and Nature of Development (MOD 1)

Representation ID: 24230

Received: 23/11/2015

Respondent: Crest Strategic Projects

Representation Summary:

Emerging Policy CS2: The Location and Nature of Development - We support the amendment to the wording of Policy CS2 which removes the requirement to provide suitable infrastructure 'prior' to the delivery of the IGS. This reflects Table 8B in Chapter 10 of the Proposed Submission Core Strategy, which sets out trigger points for the delivery of items of infrastructure (this table is not proposed to be modified).

Full text:

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Support

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

10 - CS10 Ipswich Garden Suburb / Paragraph 8.108

Representation ID: 24231

Received: 23/11/2015

Respondent: Crest Strategic Projects

Representation Summary:

Support additional text within Policy CS10 and the supporting text, which reinforces the need for a comprehensive approach to the development of the IGS and reflects the need for proposals to positively facilitate and not prejudice the development of other phases. This aligns with current work being undertaken on the Infrastructure Delivery Plan and Collaboration Agreement. Crest is a key delivery partner of the IGS. The commitment within the Core Strategy to a comprehensive and coordinated approach to the development of IGS is essential to ensure the delivery of infrastructure at an appropriate time by the relevant parties.

Full text:

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Object

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

13 - CS17 Infrastructure

Representation ID: 24232

Received: 23/11/2015

Respondent: Crest Strategic Projects

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Emerging Policy CS17: Delivering Infrastructure - We support the addition of text to clarify that the direct provision of infrastructure by developers is allowed as mitigation for impacts, as an alternative to a commuted sum or CIL payment. This provides sufficient flexibility for developers. We suggest that similar text is also included within Policy CS10.

Full text:

See attached.

Object

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

16 - DM1 Sustainable Design and Construction

Representation ID: 24233

Received: 23/11/2015

Respondent: Crest Strategic Projects

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

We support the amendment to Policy DM1 which reflects the withdrawal of the Code for Sustainable Homes. However, we object to Part a. of Policy DM1 and this should be removed. The Written Ministerial Statement March 2015 and 'Fixing the Foundations' July 2015 indicate that LPAs should not set additional local technical standards for new dwellings and that the Government does not intend to proceed with 'Allowable Solutions' or the proposed increased energy efficiency requirement. Therefore, LPAs cannot require developments to meet standards higher than those set in the Building Regulations Part L.

Full text:

See attached.

Object

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

17 - DM5 Design and Character (MOD 1)

Representation ID: 24234

Received: 23/11/2015

Respondent: Crest Strategic Projects

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

This policy now requires that 35% of new dwellings, built on developments of 10 or more dwellings, are built to Building Regulations standard M4(2) and where affordable housing is provided a proportion of dwellings should be built to Building Regulations standard M4(3). There is no robust evidence to justify this requirement and without this we object to the Policy. However, we welcome the flexibility provided within the Policy which will ensure that the requirements do not hinder development in circumstances where it is not possible to accommodate the requirement and/or in case were the requirement would render the development unviable.

Full text:

See attached.

Object

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

20 - DM8 Heritage Assets and Conservation

Representation ID: 24235

Received: 23/11/2015

Respondent: Crest Strategic Projects

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Modifications to this Policy are not proposed, however our previous representations (Barton Willmore, March 2015) highlighted concerns regarding Part b. "Conservation Areas" which states that the position, height, mass and materials of a proposed building shall pay regard to the character of adjoining buildings. This is not objected to however, 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'. [Note - DM8 Part b Conservation Areas has been modified.]

Full text:

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Support

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

25 - DM24 Affordable Housing

Representation ID: 24236

Received: 23/11/2015

Respondent: Crest Strategic Projects

Representation Summary:

The amendment to this Policy to reflect the withdrawal of the Code for Sustainable Homes is supported.

Full text:

See attached.

Object

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

29 - DM30 9.181 / 9.192

Representation ID: 24237

Received: 23/11/2015

Respondent: Crest Strategic Projects

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Emerging Policy DM30: The Density of Residential Development - The Written Ministerial Statement - March 2015 introduces new Nationally Described Space Standards for housing. These regulations are optional and the Planning Practice Guidance (PPG) (ID: 56-002-20150327) requires LPAs to gather evidence to determine whether there is a need for additional standards and the viability implications. The Council has not demonstrated there is a need or provided evidence regarding viability and therefore we object to this policy.

Full text:

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