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

Object

Representation ID: 26297

Received: 28/02/2020

Respondent: Constable Homes Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

These representations relate to the promotion of Red House Farm for residential development. Contstable Homes Ltd has an interest in the land referred to as Red House Farm. Constable Homes is an operating subsidiary of the Anderson Group, which is a private development and construction business. The extent of our client’s ownership is defined by the red line shown on Figure 1.

Object

Representation ID: 26298

Received: 28/02/2020

Respondent: Constable Homes Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Presume shortfall of 796 units is a result of the housing supply period being reduced to 2019-2036 (Table 4). Please clarify. Ipswich only delivered 46% of the minimum target. Previous year, the measurement for Ipswich Borough Council was 66%. This indicates that housing delivery has worsened and measures needed to recover the position. Also very close to the 45% threshold in 2019 NPPF paragraph 215b. Threshold will increase to 75% next year which reinforces the urgency of addressing the significant shortfall in housing delivery. Council should be proactively identifying opportunities to accelerate delivery to overcome the significant shortfall.

Object

Representation ID: 26300

Received: 28/02/2020

Respondent: Constable Homes Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Paragraph 73 (NPPF) states 20% buffer to the five year supply should be applied. This adds to significant challenge of meeting 75% of need. Assumed date is February 2021. No buffer applied to Policy CS7. To be effective, a buffer equivalent to one year’s supply (445 dwellings) should be added to five year housing land supply. Council is in a critical position of acute under supply and failing to quantify the need increases likelihood that unmet need won't be addressed. An immediate review of the Plan will be necessary if the Council is only targeting a capped need figure.

Object

Representation ID: 26301

Received: 28/02/2020

Respondent: Constable Homes Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Have considered suitability of an element of care accommodation rather than convention 100 dwelling scheme but told by Council officers there is no need for elderly accommodation. SHMA update explains that 65+ population will increase dramatically. Policy does not separate elderly provision from other forms of housing and so would contribute to the Council’s five year housing land supply. Therefore surprising that Council is not actively encouraging this form of development. A retirement village is also different to sheltered housing, where the surplus is noted. Trickle-down benefits from down-sizing to elderly provision. Will continue to engage with Council.

Object

Representation ID: 26302

Received: 28/02/2020

Respondent: Constable Homes Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Client's land is area N3(b) (Figure 2). Reiterate concerns that the Council continues to number the phases in a way that implies they should be delivered in numerical order. SPD shows development can come forward in a self-contained manner. A safe and effective access from Tuddenham Road can be achieved. Surprised that when the Council interprets its own policy that this development would be precluded rather than positively facilitated. Suggest that the policy wording be amended to outline how each parcel could come forward individually to be sufficiently flexible and facilitate timely delivery of much needed residential accomodation.