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

Object

Representation ID: 26431

Received: 02/03/2020

Respondent: AquiGen

Agent: AquiGen

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy continues to only specifically allow for consideration of no reasonable prospect of re-use for employment purposes for sites outside the Employment Areas. Ambiguity in the supporting paragraphs as 9.32.2 and 9.32.4 suggest that the no reasonable prospect test could be applied to Employment Area land.

NPPF paragraph 120 relates to allocated land and recommends the use of the no reasonable prospect test. Recommend DM33 is amended to allow the test to be applied to all defined Employment Area land. Will ensure plan is consistent with national guidance and flexible to deal with changing market needs. Important given surplus allocation.

Object

Representation ID: 26434

Received: 02/03/2020

Respondent: AquiGen

Agent: AquiGen

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Welcome introduction of marketing requirements - offers basis for early agreement with Council. However, aspects are onerous and should be removed. Paragraph 2.1: discussions with Council before marketing unnecessary if marketing requirements in Appendix 6 are followed. Adds hurdle to process/could delay marketing. Paragraph 2.5: welcome amendment to require simple schedule noting origin of enquiry and reason for interest is sufficient. Paragraph 2.6: commercial site not generally marketed at set market value as this is determined by the offer that a purchaser is willing to make. "All Enquiries" exercise is appropriate as it generates enquiries on all potential purchase options.

Object

Representation ID: 26435

Received: 02/03/2020

Respondent: AquiGen

Agent: AquiGen

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to criterion (a) which requires consideration of the appropriateness of scale when assessing out-of-centre retail proposals. Use of 'scale' no longer recommended by national guidance and is therefore inconsistent with the NPPF which only requires an applicant to demonstrate compliance with the Sequential Approach and Impact. As identified in paragraph 89 b), scale forms part of the consideration of Impact. Therefore, no requirement to demonstrate appropriateness of scale separate from Impact. In addition, requirement to demonstrate scale not identified by Evidence Base as a retail policy requirement based on the characteristic of the area. Recommend criterion (a) removed.

Object

Representation ID: 26436

Received: 02/03/2020

Respondent: AquiGen

Agent: AquiGen

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Land allocation should be consistent with needs identified in Evidence Base. 23.2ha requirement represents most up-to-date figure to base allocation on. When compared with total land allocated for employment use (28.34ha) under Policy SP5, there is a significant amount of land allocated in excess of requirement. Even allowing for flexibility, the excess is not justified. Entirely appropriate to consider reducing land allocation to reflect actual need. Allocations require further review to ensure consistency with Evidence Base and to achieve soundness. Recommend land identified in Plan is reduced under Policy CS13 to circa 23ha.