Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review

Object

Representation ID: 25817

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

The Company supports the general vision as is set out at paragraph 6.7. It is also in general agreement with the Objectives (paragraph 6.8), but considers that there should be explicit recognition that, unless development is financially viable (or subsidised from the public purse) it will not take place and the Vision will not, therefore, be achieved.

Support

Representation ID: 25818

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

The Company offers its general support for the spatial strategy, as set out at paragraphs 6.10 to 6.22 and, in particular, the objective of focusing development in central Ipswich to tackle issues of deprivation and social exclusion.

Object

Representation ID: 25819

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

Policy's main principles are supported. In particular, the Company again notes the focus that is being placed upon the IP-One Area, where high density development will be the norm.

There is a potential conflict between criterion h of the policy and the 'objectives' (as set out at paragraph 6.8) and Policy DM12. The former (criterion h) requires that new development demonstrates 'very high quality architectural and urban design', whilst the latter (the 'objectives' and Policy DM12) both require a 'high standard' of design. The latter is considered to be more consistent with the guidance set out in the NPPF.

Object

Representation ID: 25820

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

The company generally welcomes, and supports, initiatives that are designed to minimise the need to travel and promote foot, bicycle and public transport travel modes.

It also welcomes the recognition that some journeys will need to be made by car, although it is disappointed that only the Town Centre is specifically mentioned as being a location, the vitality and viable of which, depends upon access by a variety of transport modes. the Company is of the view that this needs to be expanded to include the whole of the IP-One Area.

Support

Representation ID: 25821

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

The Company welcomes the acknowledge that, in some cases, due to high cost of development and 'abnormals' relating to a site, it may not always be viable to provide full provision (as set out in the policy), or any, affordable housing.

It is understood that the Council will shortly be progressing with its proposed Community Infrastructure Levy. This will place additional financial burdens upon development and, in some circumstances, reduce the amount of affordable housing that can be provided (on viability grounds).

Object

Representation ID: 25822

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

Whilst the Company generally support the objectives of this policy, it considers that there should be explicit recognition that, on high density sites within the IP-One Area, and particularly along the Waterfront, it will not be possible to make full provision for private, and public, open space, in accordance with the Council's standards. Open space is a very 'land hungry' use and, if developments have to meet full standards, densities will be greatly reduced. This could threaten the achievement of the Council's spatial strategy and result in new development not making the best, and most effective, use of previously-developed sites.

Object

Representation ID: 25823

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

The Company's comments, in respect of this policy, follow on from those set out above in relation to Policy CS16. The Company again offers its general support to the objectives of the policy but considers that it needs to be more explicit in recognising that, on higher density, previously developed, sites in the IP-One Area, and particularly on the Waterfront, it will not be possible to make full provision for open space in accordance with the Council's standards.

Object

Representation ID: 25824

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

As with the comments relating to Policies CS16 and DM6, there should be explicit recognition that, in respect of high density, previously developed, sites, it may not always be possible to make full provision for private amenity space to accord with the Council's standards.

Object

Representation ID: 25825

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

Whilst the Company generally supports the policy, it is noted that Site IP035 is excluded from the 'arc of land', where tall buildings may be appropriate.

This may not be significant/ material, as a 'tall' building is defined as one which is substantially taller than its neighbours or which significantly changes the skyline. In, this respect, there are buildings of between 7 and 15 storeys adjacent to the southern boundary of the site.

If the development of IP035 would be subject to this policy however, then an objection is raised to the exclusion of the site from the arc.

Object

Representation ID: 25826

Received: 13/03/2019

Respondent: Cardinal Lofts (Mill) Ltd

The Company supports the general objectives set out in this policy, but considers that it should be re-worded, particularly in respect of the tests relating to harm caused to heritage assets, to better accord with the wording set out in the NPPF. In particular, the three criteria relating to listed buildings do not include a balancing exercise, whereby harm caused is weighed against any public benefits arising from a scheme.