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

Object

Representation ID: 26443

Received: 02/03/2020

Respondent: Pigeon Investment Management Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy ISPA4 – Cross Boundary Working to Deliver Sites
3.1 Pigeon support the Council’s inclusion of a policy that relates to the delivery of sites outside of the Borough. However, this policy remains almost the same as its version in the previous document, only including a little more detail. Furthermore, this policy relates solely to site ISPA4.1. It does not therefore provide any general policy support or guidance for delivering Ipswich Borough Council’s housing need for 8,010 homes (Policy CS7), outside of the authority area, particularly given the stepped housing trajectory with less homes delivered at the start of the plan period.
3.2 The Site Sheet for ISPA4.1 sets out that the development would need to be ‘delivered in coordination with the delivery of the Ipswich Garden Suburb to ensure that there is sufficient infrastructure capacity to meet demand’. The Ipswich Garden is assessed with further commentary within this representation, and in line with the conclusions of this, it is considered that reliance on the Ipswich Garden Suburb puts site ISPA4.1 at risk of delay.

Object

Representation ID: 26444

Received: 02/03/2020

Respondent: Pigeon Investment Management Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy CS2 – The Location and Nature of Development. The subtext to the policy sets out that the central urban focus to the location of development also reflects the sequential approach to site selection required by the NPPF (which encourages the use of previously developed land). However, Pigeon still seriously dispute the Council’s ability to deliver housing on many of the brownfield sites, which are discussed in further detail in the following section of this report.

Object

Representation ID: 26445

Received: 02/03/2020

Respondent: Pigeon Investment Management Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy CS7 sets out a policy with the minimum housing number that Ipswich Borough Council proposes to deliver in its area. The Housing Land Supply only amounts to a total of 7,214 dwellings, including an allowance for windfall development. Therefore, the Council already acknowledge that they have an unmet housing need of 1,597 dwellings over the Plan period, taking into account the 10% contingency that is allowed for in the final paragraph of the policy. Steps should therefore be taken with the ISPAB to now identify locations outside the boundary of Ipswich Borough Council where this unmet need can be accommodated.

Object

Representation ID: 26446

Received: 02/03/2020

Respondent: Pigeon Investment Management Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is an adopted SPD for this site, and within this it states that ‘the success of the development of the Garden Suburb will depend to a large extent on the continued partnership working of the landowners, IBC and other key stakeholders to secure delivery’. This site is therefore reliant on multiple landowners coming forward and Pigeon would therefore argue that this complication will significantly delay the delivery of the development during the plan period. This concern should be afforded significant weight by the Council given that the Garden Suburb accounts for around half of the supply of housing.

Object

Representation ID: 26447

Received: 02/03/2020

Respondent: Pigeon Investment Management Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Therefore Pigeon retain the view that, whilst there appears to be much mention of Ipswich Borough Council working with neighbouring authorities, this does not appear to materialise into any real contribution to delivering housing outside of the Ipswich Borough Council area during the plan period. Despite the comments made by Pigeon previously as part of the Regulation 18 Consultation, the Council do not appear to have given these any significant weight.