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

Support

Representation ID: 26641

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

It would appear that the Council has sought to co-operate with the neighbouring authorities and statutory bodies on the key strategic and cross boundary issues. This is welcomed, and we consider that this is important given the tightly drawn administrative boundary, which constrains the practical options for meeting needs for development within the Borough.

Object

Representation ID: 26643

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Welcomed that IBC are using regeneration opportunities to address deprivation, make places safer and create opportunities for all. Site should therefore be considered as an appropriate location for residential development, which would accord with National and Local Policy in this regard. Ipswich-specific issues being the limited availability of land, and large areas of protected land. Strongly recommended that the Council should be seeking to allocate additional residential sites to meet this unmet housing need within the Borough. Land north of Burrell Road is a suitable, available and deliverable site and should be allocated for residential development.

Object

Representation ID: 26644

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support the objective for housing set out in Paragraph 6.8 (2). Also agree with Point 4. that development will be directed to the central Ipswich IP-One area. recognise that, in terms of a sequential test there is no realistic alternative to locating some development in Flood Zone 3. Land north of Burrell Road is located in proximity to the Waterfront and its facilities and services. Its proposed regeneration would contribute to the regeneration of Burrell Road, and the wider IP-One Area, whilst also contributing to the attractiveness of the Waterfront.

Object

Representation ID: 26645

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The location of the IP-One area in Diagram 3 is supported, however it is considered that the extent of the Waterfront and the proposed location for major housing development could be extended westwards, especially in light of proposed allocations IP031a and IP031b for residential development. In doing so, this would incorporate the site to the north of Burrell Road, which is a suitable, available and deliverable site which is capable of accommodating residential development to meet the unmet need within the Borough. The site should therefore be allocated for residential development.

Object

Representation ID: 26646

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Discrepancy in the housing need figures agreed across the HMA. Understood the IPSA agreed SOCG 2020, and a copy of this is available on the IBC website signed January 2020 (see table 1). The East Suffolk Final Draft Local Plan relies on the standard methodology based on the 2016 household projections, whereas the IBC Local Plan Review focusses on the 2014 household projections, thus reducing their housing need figure. Without further clarification with regards to the discrepancies between these projections, it is unclear whether the Council’s emerging Local Plan meets the tests of soundness, as outlined in NPPF 35.

Object

Representation ID: 26647

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support Policy CS2. Agree that town centre, Portman Quarter and Waterfront will receive the highest densities of development, including high-density housing developments, with medium density and locally focused facilities to be provided elsewhere in IP-One and within and around district centres, with lower density development elsewhere. Recognised that this approach will: maximise opportunities to re-use previously developed land within central Ipswich; ensure that new housing is provided close to local shops, facilities and transport nodes; and support the ongoing regeneration of central Ipswich and particularly of the Waterfront and town centre. Allocating Land north of Burrell Road would achieve this.

Object

Representation ID: 26648

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concerned that the Action Plan does not make the most of allocating previously developed land for residential development. Therefore considered that the emerging Local Plan does not meet the tests of soundness in terms of ensuring the consistent delivery of housing in accordance with Paragraph 35 of the NPPF. considered that a greater number of short to medium scale sites should be allocated to ensure the consistent delivery of housing within the Borough. Land to the north of Burrell
Road offers an opportunity to accommodate a degree of residential development in the short to medium term.

Object

Representation ID: 26649

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

HDT identifies IBC only able to deliver 46% of identified need. Now requires a 20% buffer. Concerning paragraph 8.108 doesn't reference 20% buffer. Greater number of short/ medium-scale developments required to ensure consistent delivery. The Draft HDAP supports enhancement of small and medium-sized housebuilders, this is agreed. Our client willing to explore this developer consortium opportunities, exemplified though the current purchase of the neighbouring site. CS7 expects that 700 dwellings (50 annum) will be delivered on small windfall sites. Concerning AMR (2017-18) shows only 47 delivered. The Site would contribute to delivery of windfall. Support 100% PDL development in IP-One.

Object

Representation ID: 26650

Received: 02/03/2020

Respondent: Silverton Aggregates Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support that outside of defined Employment Areas, the conversion, change of use or redevelopment of sites and premises in employment use to non-employment uses will be permitted, subject to criteria c - e. Land at Burrell Road is located outside of defined Employment Areas, and it is considered that the redevelopment of the site to residential use would be a more effective use of land in accordance with Paragraph 117 of the NPPF. The proposed development is also compatible with the surrounding uses which comprise predominantly residential uses. The site should therefore be included as an allocation for residential development.