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

Object

Representation ID: 25838

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The Local Plan Documentation does not deliver upon the stated Objectives and does not comply with significant swathes of national planning policy contained in the NPPF (February 2019) and elsewhere. Notably the Local Plan Policies and their associated justification conflict with chapters 3, 5, 8, 9, 12, 14, 15 and 16 of the NPPF. It is alarming that the plan already fails to meet basic requirements of plan making as initially set out in paragraph 16 of the NPPF.

Object

Representation ID: 25841

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The Statement of Common Ground in relation to Strategic Cross Boundary Planning Matters is weak. Given that Ipswich cannot meet its own development needs it is of some concern that a closer working arrangement has not been created. Ipswich is an important sub regional centre. The other two similar centres in the region are Norwich and Cambridge. Norwich City is planned as part of the Greater Norwich Local Plan. Cambridge is planned with South Cambridgeshire as Greater Cambridgeshire but Ipswich is not coordinating its growth on the same statutory basis. Consideration must be given to a joint Local Plan.

Object

Representation ID: 25844

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The NPPF states that at least 10% of the affordable housing percentage should be discounted market housing. That means that where a Council is proposing 15% affordable housing then the 10% falls entirely within that. Policy CS12 is contrary to paragraph 64 and footnote 29 of the NPPF.
The Council is asking that "at least 15%" affordable housing should be provided on major development sites. No justification as to why "at least" is used. This is a huge "developer cost" so why is there no mandatory level of affordable housing in the Local Plan as per other Local Plans?

Object

Representation ID: 25845

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

Where the Council wants to ... it is asking to deliver 100% affordable housing on its sites but it is not providing any clarity as to where these sites are. This approach is contrary to the government's objectives to provide mixed and balanced communities. Large scale affordable housing schemes are generally regarded as problematic in social and economic terms which is why development is normally promoted to have a mix of tenures and types of homes to meet the requirements of the whole community.

Object

Representation ID: 25857

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The air quality policy would prevent development at Ravenswood because existing peak hour traffic is so great that this would be an Air Quality Management Area had the Borough Council conducted appropriate monitoring at the Nacton Road roundabout. The development at Ravenswood on all of the 6 development sites adds intolerably to air quality concerns without a solution in the Local Plan.

Object

Representation ID: 25858

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The policy causes a conflict with the allocations policies because the allocations will have an adverse impact on European Protected sites. The huge housing and industrial development at Ravenswood could be located on an alternative site that would cause less harm to the SPA so Policy DM8 mandates that the Ravenswood development should be refused. The plan therefore unreasonably allocates land for development whilst including policies which would see that development rejected.