Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
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Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Chapter 6 - Vision and Objectives
Representation ID: 26438
Received: 02/03/2020
Respondent: Kesgrave Covenant Ltd
Agent: Kesgrave Covenant Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Whilst strongly support residential allocation for land at Humber Doucy Lane, seeking relatively minor amendments to detailed wording which is considered neither justified nor effective and therefore not sound. This will ensure no unnecessary delays to delivery of development. As currently written, the Plan identifies the land for "future" development and states that it will be "appropriately phased" with Garden Suburb and associated infrastructure. Amend to provide greater clarity regarding required infrastructure. Plan should not make generic references to "future" development or refer to requirement for phasing without appropriate evidence/details. Wording of paragraph 6.17 should be amended to reflect this.
Paragraph 6.17 should be amended to read:
"....A cross-border allocation for development (within Ipswich Borough and Suffolk Coastal Local Plan area) for housing delivery, is also identified in north-east Ipswich at the northern end of Humber Doucy Lane and Tuddenham Road..."
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Chapter 7 - Key Diagram
Representation ID: 26439
Received: 02/03/2020
Respondent: Kesgrave Covenant Ltd
Agent: Kesgrave Covenant Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Whilst strongly support allocation of land at Humber Doucy Lane, seeking relatively minor amendments to wording which is considered neither justified nor effective and therefore not sound. This will ensure no unnecessary delays to delivery of development. As currently written, the Plan identifies the land for "future" development and states that it will be "appropriately phased" with Garden Suburb and associated infrastructure. Amend to provide greater clarity regarding required infrastructure. Plan should not make generic references to "future" development or refer to requirement for phasing without appropriate evidence/details. Wording of paragraph 7.2 should be amended to reflect this.
Paragraph 7.2 should be amended to read:
"...(iv) The cross-border allocation for development proposed at the northern end of Humber Doucy Lane through policy ISPA4;..."
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy ISPA4 Cross Boundary Working to Deliver Sites
Representation ID: 26440
Received: 02/03/2020
Respondent: Kesgrave Covenant Ltd
Agent: Kesgrave Covenant Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy comments on location of green infrastructure - KCL has additional land in vicinity so may be possible to locate outside of allocated site. Limiting green infrastructure to within allocation overly restrictive, therefore not effective or sound. Policy outlines affordable housing requirements - whilst provision supported in principle, Council must ensure viability. Plan identifies 15% requirement with exception of land at Humber Doucy Lane and IGS where at least 30%/31% is required. Whole Plan Viability Study calculations don't include Section 106 and CIL - query whether full infrastructure costs considered. Suggest further flexibility should be applied. Recommend policy wording change.
Policy ISPA4 should be amended to read:
"Ipswich Borough Council will work with neighboring authorities to master plan and deliver appropriate residential development and associated infrastructure on identified sites within the Borough but adjacent to the boundary, where cross boundary work is needed to bring forward development in a coordinated and comprehensive manner. In order to meet housing needs within the Borough boundary as far as possible, the Council identifies cross-border allocation for development of 23.62ha of land within Ipswich Borough in 4 parcels forming ISPA4.1 for housing growth and associated infrastructure improvements at the northern end of HUmber Doucy Lane adjacent to Tuddenham Road. The allocation is shown on the accompanying site sheet for this policy. It will require land and infrastructure works and green infrastructure (including Suitable Accessible Natural Greenspace) on both sides of the Borough boundary in order to come forward, however this could include land outside the allocated site......Development will include at least 30% affordable housing, subject to viability testing at the planning application stage...."
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy ISPA4 Cross Boundary Working to Deliver Sites
Representation ID: 26441
Received: 02/03/2020
Respondent: Kesgrave Covenant Ltd
Agent: Kesgrave Covenant Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Paragraph 8.28 refers to transport mitigation measures required for the development of the site at Humber Doucy Lane being "challenging". This is not considered to be the case. Re-iterate earlier submissions in relation to accessibility of the site:
-Good public transport accessibility;
-Good road access;
-Good accessibility to services and facilities;
-Town centre and hospital easily accessed by public transport;
-Development of site promotes sustainable transport in accordance with NPPF;
-Transport Modelling Report concludes housing growth can be accommodated;
-Proposals will not influence northern bypass route.
Current reference to "challenging" transport mitigation measures not justified. Recommend amendment to paragraph 8.28.
Paragraph 8.28 should be amended to read:
"The site allocation at the northern end of Humber Doucy Lane is located at the edge of Ipswich approximately 3.5km from the town centre. Sustainable transport connections will be key to providing linkage to employment and other opportunities. In addition, it is acknowledged that transport mitigation measures are required for the development of the site and it is essential that significant modal shift is delivered through strong travel plans and other sustainable measures"
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy ISPA4 Cross Boundary Working to Deliver Sites
Representation ID: 26442
Received: 02/03/2020
Respondent: Kesgrave Covenant Ltd
Agent: Kesgrave Covenant Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Plan identifies requirement for sites to provide 15% affordable housing, with the exception of Humber Doucy Lane and IGS where 30/31% required respectively. Calculations for Humber Doucy Lane from assessment of affordable housing provision in The Whole Plan Viability Study, don't include section 106/CIL - query whether full infrastructure costs considered. After testing, first IGS neighbourhoods have been agreed with 4/5% provision instead. Therefore, suggest further flexibility applied to this policy. Whilst support provision of affordable housing, more detailed viability testing may be required to ensure site is viable with regard to all infrastructure costs. Recommend amendment to paragraph 8.29.
Paragraph 8.29 should be amended to read:
"The Council will outline expected infrastructure provision of both green infrastructure and built infrastructure required as part of the joint agreed master-planning process to the cross-border Humber Doucy Lane sites. the Whole Plan Viability Assessment of the Local Plan identifies that this area of land falls wihtin a high value zone and indicates that approximately 30% affordable housing could be achieved on a greenfield development, however this will be subject to further testing at the planning application stage. The level of affordable housing also broadly aligns with the Suffolk Coastal Local Plan affordable housing requirement of 33%"
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS2 The Location and Nature of Development
Representation ID: 26448
Received: 02/03/2020
Respondent: Kesgrave Covenant Ltd
Agent: Kesgrave Covenant Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy comments on the location of green infrastructure. It should be noted that KCL has additional land in the vicinity of the Humber Doucy Lane site allocation so it may be possible to locate these uses outside the site. Therefore, seek flexibility to policy wording to ensure the most appropriate option can be pursued. Limiting green infrastructure to the application site is overly restrictive at this stage and does not enable options to be fully explored. This approach is not effective and therefore does not comply with the tests of soundness. Recommend amendment to policy wording.
Policy CS2 should be amended to read:
"b. Allocating sites for development at the northern end of Humber Doucy Lane for housing and associated infrastructure and working with East Suffolk Council to master plan development and ensure a comprehensive approach to its planning and delivery (see policy ISPA4)..."
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS2 The Location and Nature of Development
Representation ID: 26451
Received: 02/03/2020
Respondent: Kesgrave Covenant Ltd
Agent: Kesgrave Covenant Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Although we generally support the Plan, it's policies and supporting text relating to the proposed allocation at Humber Doucy Lane, as currently drafted, it is neither justified nor effective as it should be specific about any infrastructure requirements that will influence timescales of delivery and should not make generic references to the site coming forward "as development draws to a conclusion at Ipswich Garden Suburb" without providing appropriate evidence and details. Recommend amendment to paragraph 8.55 wording.
The final bullet point of paragraph 8.55 should be amended to read:
"Lower density housing development is to be master planned jointly with East Suffolk Council at the northern end of Humber Doucy Lane, which will maintain and ensure separation between Ipswich and surrounding settlements"
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS7 The Amount of Housing Required
Representation ID: 26452
Received: 02/03/2020
Respondent: Kesgrave Covenant Ltd
Agent: Kesgrave Covenant Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Although we generally support the Plan, it's policies and supporting text relating to the proposed allocation at Humber Doucy Lane, as currently drafted, it is neither justified nor effective as it should be specific about any infrastructure requirements that will influence timescales of delivery and should not make generic references to the site coming forward "as development draws to a conclusion at Ipswich Garden Suburb" without providing appropriate evidence and details. Recommend amendment to policy wording.
Policy CS7 should be amended to read:
"....c. ...Delivery will also take place at the northern end of Humber Doucy Lane."
