Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Object

Representation ID: 26369

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

NPPF confirms the presumption in favour of sustainable development does not trump the statutory presumption in favour of the development plan set out in s38(6) of the Planning and Compulsory Purchase Act 2004. The wording is detailed at paragraph 2.2 of the final draft of the Core strategy. As such the inclusion of the model wording in Local Plans is no longer required. It is reasonable to consider that policy CS1 is not consistent with the National Policy and should be removed, in addition no robust justification for its continued inclusion has been provided. Persimmon also endorse the statements made by the HBF.

Object

Representation ID: 26381

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

Ipswich's OAN have risen. Over the last two years house sales have fallen. There is functional need for IBC, ESDC and B&MSDC to ensure development needs are met. There seems to be little recognition of the potential of this area, or detail provided on how ESDC and IBC have cooperated. Ipswich's administrative boundary justifies significant efforts to work with neighbouring authorities as a priority on cross boundary issues. This absence of detail weighs against how positively prepared the Final Draft Local has been and the effectiveness of its approach over the plan period. Persimmon endorse the statements made by the HBF.

Object

Representation ID: 26386

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

Within policy CS8 it is stated that through regard to the Ipswich Strategic Housing Market Assessment overall provision of a diverse range of housing will be secured, noting that the policy also states where that document remains up to date. Recent experiences of developing within the water front area in Ipswich has confirmed that there is a weak market for high density flatted development in Ipswich. It is recommended that allocations for schemes are revisited with a view to allow for lower density development. Persimmon endorse the statements made by the HBF.

Object

Representation ID: 26424

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

It is also reasonable to question what time period is being used to define if the SHMA is up to date, in addition to recognition that market forces move quicker than the updating of evidence bases that support Local Plans. Defining what those time periods are would allow for clarity in future discussions on what weight can be afforded to alternative sources of evidence against the SHMA, but also provide developers with an element of certainty in discussions that appropriate sources of evidence have been referred to. Persimmon also endorse the statements made by the HBF.

Object

Representation ID: 26425

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

A prescriptive approach in the interpretation of the policy would limit opportunities to respond to market forces, and possibly result in more situations such as Griffin Wharf (site reference IP200) were the viability of development is being questioned. Persimmon also endorse the statements made by the HBF

Object

Representation ID: 26426

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? Yes

Duty to co-operate? No

A prescriptive approach in the interpretation of the policy would limit opportunities to respond to market forces, and possibly result in more situations such as Griffin Wharf (site reference IP200) were the viability of development is being questioned. Persimmon also endorse the statements made by the HBF.

Object

Representation ID: 26427

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

A prescriptive approach in the interpretation of the policy would limit opportunities to respond to market forces, and possibly result in more situations such as Griffin Wharf (site reference IP200) were the viability of development is being questioned. Persimmon also endorse the statements made by the HBF.

Object

Representation ID: 26428

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DM7 proposes minimum standard areas for private outdoor amenity space, but no evidence could be found that supports the figures detailed, including within local design guides. In addition the application of such standards varies between neighbouring authorities, which would reasonably call into question whether this policy has been adequately justified and is consistent with National Policy, whilst also being effective over the plan period. Where the policy details that lower figures may be acceptable where there is unavoidable conflict with the need to meet density requirements, additional flaws in its effectiveness arise due the questionability of how site densities are calculated given the current limited weight given to market forces and demands for different types of dwellings. Persimmon also endorse the statements made by the HBF.

Object

Representation ID: 26429

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

It is recognised that the extent of overlooking would be assessed on a case-by-case basis, which is an approach that is welcomed. However, whilst flexibility built into the adopted policy is welcomed, within the supporting text titles of recognised published technical guidance on this matter to provide continuity in the assessment of this issue would be welcomed.

Object

Representation ID: 26430

Received: 02/03/2020

Respondent: Persimmon Homes

Agent: Persimmon Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

No justification has been provided on why there is a need for 25% of all housing on major developments to be designed to Part M4(2) standards in policy DM12. Without justification it could be argued that this figure is too high, as there may be possible overlap between the provision of specialist housing and the provision market housing, on the final delivery of M4(2) housing. This policy would not therefore be effective over the plan period. Persimmon also endorse the statements made by the HBF.