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

Object

Representation ID: 26581

Received: 02/03/2020

Respondent: Bloor Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We support the recognition within the Plan that the Council will need to work closely with neighbouring authorities regarding future development and infrastructure, as set out in the first strategic objective. However, as expanded upon below we do not consider that the Council have fully explored all opportunities to work with neighbouring authorities to meet full identified
housing needs throughout the Plan period as a whole, as also set out in response to the Suffolk Coastal emerging Local Plan (refer to Appendix C).

Object

Representation ID: 26582

Received: 02/03/2020

Respondent: Bloor Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No housing trajectory and the rate of delivery unknown. This is a significant failure. The Site can deliver a smaller scale housing development of around 200 homes within the early Plan period. Without full consideration of this and joint working to increase delivery, the stepped trajectory has not been justified and is unsound. Plan is also overly-reliant on delivery of IGS for stepped delivery. Question the overall housing requirement and whether the Council have adequately considered uplifting to support economic growth as this contradicts paragraph 8.168. Contrary to NPPF 35 and not positively prepared or effective.

Object

Representation ID: 26585

Received: 02/03/2020

Respondent: Bloor Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The plan allocates a total of 1,647 affordable dwellings
(assuming 30% IGS and ISPA4 and 15% on all other sites including windfall). In all likelihood this is overly optimistic given that most windfall sites are likely to be small and fall below the threshold set in Policy CS12. Based on the 239 dwellings per year in the SHMA, this would result in 38% of the affordable need. This is insufficient. Contrary to NPPF 20 and PPG. The Site can come forward to provide market and affordable housing to assist with meeting the need, working with East Suffolk.

Object

Representation ID: 26586

Received: 02/03/2020

Respondent: Bloor Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is a disconnect between Policy CS8 seeking a mix of housing to meet the identified needs and site allocations, contrary to national policy. 61% of dwellings proposed are at a high density. These are likely to be small flats and over saturate this market. 13% of dwellings will be low density and predominantly houses, we question if this will meet the actual housing mix identified in qualitative terms or the overall need figure. IGS only likely to deliver post 2024 so there is a need for 3-bedroom and larger homes in early plan period. The Site can deliver this.

Object

Representation ID: 26590

Received: 02/03/2020

Respondent: Bloor Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is a lack of a coordinated approach, with allocations proposed within Ipswich. Concerned that spatial strategy has been unduly influenced by the administrative boundary, e.g. SHELAA only looking at sites within IBC. The Site has the potential to help meet housing needs within a location (East of Ipswich) which has already been tested through the Suffolk Coastal Local Plan plan-making process and found to be a sustainable location for growth. Do not consider the Site has been robustly assessed, subsequently a sustainable option for growth being rejected without justification. 200 homes (shorter term) and 1,200 homes (medium term)