Object

Representation ID: 25641

Received: 08/03/2019

Respondent: Grainger Plc

The document is unsound and not legally complaint for reasons summarised:
1. Ineffective as it does not allocate an adequate number of deliverable sites over the plan period to maintain the housing need of the Borough;
2. Fails to allocate sufficient land within its early phases to ensure the Borough's five-year housing land supply is met alongside a buffer to compensate for significant under-delivery of housing;
3. It heavily relies on a single strategic allocation; and
4. Fails in its Duty to Cooperate in terms of achieving a series of deliverable sites within the early stages of the Plan

Object

Representation ID: 25642

Received: 08/03/2019

Respondent: Grainger Plc

The newly published housing projections have in fact increased the local housing need within the Borough (and majority of the Councils forming the Ipswich Strategic Housing Market Area). We therefore agree with the approach adopted within the Preferred Options document, which uses the 2016-based household projections, as it still continues to support the Government's objective of "significantly boosting the supply of homes" (NPPF Paragraph 59). However, note that these should be interpreted as a minimum housing need as outlined in paragraph 60 of the NPPF.

Object

Representation ID: 25643

Received: 08/03/2019

Respondent: Grainger Plc

(Read alongside table 2 of representation). Whilst we acknowledge that a figure of 9,214 is ambitious and commend the Council for setting such targets, the figure only represents a buffer of 6.8% above the standard methodology. We caution the conservative buffer the Borough has applied to the provision of housing over the Plan period, particularly given the Council's own margin for "slippage" was 10% (applied to Table 2 within the Core Strategy document). Therefore, logically, an uplift of at least 10% should be applied to figures H and G in Table 2 of this representation.

Object

Representation ID: 25644

Received: 08/03/2019

Respondent: Grainger Plc

We caution the Council's spatial strategy, where over 50% of new housing allocations will be delivered through a single site (Ipswich Garden Suburb). This has already limited the Council's ability to provide its five year housing land supply (discussed in detail in the other representations) but could also jeopardise the delivery of the Plan should the site be rendered undeliverable or not as fruitful for unforeseen reasons.

Object

Representation ID: 25645

Received: 08/03/2019

Respondent: Grainger Plc

In relation to the allowance of windfall sites, paragraph 70 of the NPPF states "where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply". In this case there is a lack of compelling evidence to support windfall sites as a reliable source of supply. Based on this. the plan does not comply with paragraph 70 of the NPPF and further evidence in support of the windfall sites should be provided, or housing provision over the plan period should be reviewed.

Object

Representation ID: 25646

Received: 08/03/2019

Respondent: Grainger Plc

Ipswich has experienced under-delivery against their housing targets over the last three years, ranging between 55-64% (based on the 2017 AMR) (refer to table 3 of this representation). Consequently, the Plan should be allowing a 20% buffer of land for housing to compensate for previous years of under delivery in line with paragraph 73 of the NPPF.

The Borough's draft housing trajectory demonstrates that Ipswich cannot meet its current five-year housing land supply, let along the additional 20% buffer required to compensate for its failure to meet the Housing Delivery Test.

Object

Representation ID: 25647

Received: 08/03/2019

Respondent: Grainger Plc

This policy follows a stepped approach. Whilst a stepped approach to the annual housing requirement is an acceptable approach outlined in the NPPF, we believe in the case of Ipswich this approach is not justified and does not meet the outcomes specified within the guidance (see representation for guidance extract). The Borough's housing requirement has not significantly changed between emerging and previous policies, in fact it has decreased by 10 dwellings per annum. Given the Borough's significant under-delivery of housing over previous years alongside its decrease in housing need, the proposal to step the annual housing requirement is not justified.

Object

Representation ID: 25648

Received: 08/03/2019

Respondent: Grainger Plc

In order to be considered sound and compliant with National Policy, the emerging Plan should consider allocating more deliverable sites that will contribute to meeting the Borough's five year housing land supply plus an additional 20% buffer as outlined in Paragraph 73 of the NPPF. In short, the Borough must find more deliver sites to boost delivery in the early years of the Plan. If none can be found in the Town's boundaries, then it must work with adjoining authorities to find such sites within the greater urban area.

Object

Representation ID: 25649

Received: 08/03/2019

Respondent: Grainger Plc

The Borough has clearly not exhausted reasonable alternatives within the area east of Ipswich for housing and therefore has not fulfilled its duty to cooperate with neighbouring authorities. As highlighted in Suffolk Coastal's Final Draft Local Plan, the area east of Ipswich presents opportunities to deliver housing within proximity to Ipswich Town Centre in a location that is already well served by infrastructure. Site 520 identified at Kesgrave within Appendix D (Alternative Sites) of Suffolk Coastal District Council's Sustainability Appraisal offers an opportunity to deliver housing within the early stages of the Plan period to meet Ipswich's unmet need.

Object

Representation ID: 25650

Received: 08/03/2019

Respondent: Grainger Plc

A series of Statements of Common Ground have been prepared by the Ipswich Strategic Planning Area (ISPA). It is clear that housing land supply has already fallen and that no attempts to remedy the shortfall within the early years of the plan across the ISPA have been made. Ipswich Borough and Suffolk Coastal have not worked collaboratively to resolve Ipswich's unmet housing delivery need to find more sites in the early years of the Plan Period. Both Councils have failed in their duty to cooperate and both Plans are not legally complaint and contrary to paragraph 26 of the NPPF.