Object

Representation ID: 26071

Received: 13/03/2019

Respondent: CBRE

Agent: Mr Arwel Owen

The draft policy recognises the need for cross-boundary working to address potential effects on protected habitats and species. We fully support such an approach but advocate that this be accompanied by a holistic approach to mitigation which recognises that RAMS should provide a suite of mitigation measures including the Ipswich Garden Suburb ('IGS') Country Park which allows for a responsive approach to development proposals. The separation of the IGS Country Park from RAMS risks a piecemeal approach to mitigation and an adverse impact on delivery of sites.

Object

Representation ID: 26072

Received: 13/03/2019

Respondent: CBRE

Agent: Mr Arwel Owen

Despite clear evidence submitted through the development management process, unrealistic policy expectations remain under CS10. In particular, the Council's stance on affordable housing provision is untenable given the evidence available to it by virtue of the applications before it. Recognising the provisions of paragraph 64 of the NPPF (2019)), consideration should be given to a 10% threshold with additional provision secured where viability provides. We remain concerned that Policy CS10 remains prescriptive in terms of the use budget set out, and that such detail is unnecessary in Local Plan policy.

Object

Representation ID: 26073

Received: 13/03/2019

Respondent: CBRE

Agent: Mr Arwel Owen

Policy CS16 includes proposed amendments recognising the relationship of green infrastructure and RAMS. The Policy should further recognise the role of the IGS Country Park as an element of an overall mitigation strategy, and the cross-boundary relationships which exist under ISPA3. A comprehensive, rather than compartmentalised approach to mitigation is required and should be reflected in Policy.

Object

Representation ID: 26074

Received: 13/03/2019

Respondent: CBRE

Agent: Mr Arwel Owen

Policy DM1 remains onerous and fails to adhere to the requirements of paragraph 16(b) of the NPPF (2019) - it is demonstrably not deliverable in a viability sense. The expectation of green and/or blue roofs is not justified and does not appear to have been subject to viability testing.

Object

Representation ID: 26075

Received: 13/03/2019

Respondent: CBRE

Agent: Mr Arwel Owen

Policy DM1 remains onerous and fails to adhere to the requirements of paragraph 16(b) of the NPPF (2019) and is made less so by the amendments proposed which establishes a compound test rather than an either/or test. The Council's justification and evidence to support the change is awaited.