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

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.