Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
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Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy DM22 Car and Cycle Parking in New Development
Representation ID: 26293
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy unsound and not consistent with national policy. DM22 requires compliance with adopted standards for car and cycle parking. However, these standards are not set out in the local plan but in supplementary guidance. We are concerned that such standards, which are issues of policy as the can be used to refuse an application, being set out in guidance and not the plan itself. Legislation is clear that policy issues must be set out in local plans. This is to ensure that should these standards change then appropriate consultation and public scrutiny of these changes is undertaken.
Two options are open to the Council, they can either include the standards as an appendix in the local plan or state in policy that development will need to have regard to the standards.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy DM21 Transport and Access in New Developments
Representation ID: 26295
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
HBF would prefer a national and standardised approach to the provision of electrical charging points in new residential developments. We would like this to be implemented through the Building Regulations rather than through local planning policy.
Suggest that part c is deleted.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy DM7 Provision of Private Outdoor Amenity Space and New and Existing Developments
Representation ID: 26299
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
DM7 is unsound as it not consistent with national policy or justified. This policy is too prescriptive as to the levels of open space required for homes within Ipswich. Housebuilders understand the market and the amount of open space that people expect and as such this policy needs to provide a greater flexibility. Ipswich is highly constrained and if the Council is seeking to set standards for open space within developments and meet its housing requirements it will need to offer flexibility.
We would suggest the following wording: “To ensure that new residential developments deliver a high quality and environmentally sustainable living environment, developments for houses and ground floor maisonettes will be required to incorporate well-designed and located private outdoor amenity space of an appropriate type and amount. When considering the provision of outdoor amenity space applicants should have regard to the need to meet other density and urban design requirements of the plan.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS12 Affordable Housing
Representation ID: 26303
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
CS12 is unsound and not consistent with national policy. The phrase 'at least 15%' does not provide the necessary clarity for applicants and decision makers and should be removed.
The phrase 'at least' should be removed from the policy.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS1 Sustainable Development
Representation ID: 26304
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The policy is unsound as it not consistent with national policy. When the presumption in favour of sustainable development was first introduced the Planning Inspectorate recommended that a policy reflecting this approach should be included in all local plans. This approach is no longer considered necessary by PINS and they have rescinded their original advice on this matter. Given this position and the fact that paragraph 16(f) of the National Planning Policy Framework (NPPF) states that policies in local plans should serve a clear purpose and avoid any unnecessary duplication we would suggest this policy is deleted.
We would suggest this policy is deleted.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS7 The Amount of Housing Required
Representation ID: 26311
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Housing supply -
The HBF welcome the decision to include a 10% contingency within the Council's housing supply.
It is not evident which sites form the basis of supply within the first five years of the plan.
It will be necessary for the Council to provide a detailed site by site assessment of delivery across the plan period.
This is particularly important with regard to the five year supply given the amended definition of deliverable within the 2019 NPPF.
Until such evidence is provided the HBF reserve the right to comment on this issue.
In order to make the plan sound the Council will need to provide evidence as to the delivery rates for specific allocations and other sources of housing supply within the local plan to ensure these can be scrutinised.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS7 The Amount of Housing Required
Representation ID: 26313
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Stepped requirement - Policy is not sound, the stepped trajectory has not been justified. Agree with the proposed requirement for the plan period, however do not agree with the steps proposed. In too many cases the step is required on the basis of the strategy chosen by the Council. The approach is not sufficiently challenging and is more likely to lead to the whole plan under delivering. We would suggest:
2018/19 to 2019/20 - 300
2020/21 to 2023/24 - 375
2024/25 to 2035/36 - 493
This would ensure the Council can maintain a five year supply on adoption.
In order to make the plan sound the Council will need to set a more challenging stepped trajectory that is more closely linked to expected supply.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS7 The Amount of Housing Required
Representation ID: 26315
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Housing requirement - Policy not sound the housing requirement has not been justified. Paragraph 2a-024 of the PPG states that an increase in the total housing figures may be considered where it could help deliver affordable housing. The Council recognise in paragraph 8.151 affordable housing need is 239 dpa, around 48% of their requirement and as such they will not meet all of their need for affordable housing. Consideration should have been given with the other authorities in the ISPA whether more sites could be allocated elsewhere in the ISPA to meet the affordable housing needs of Ipswich.
In order to make the plan sound the Council will need to justify why they have not considered a higher housing requirement that better meets their jobs growth assessments and affordable housing needs. Whilst we recognise that Ipswich is constrained the Council should have looked to secure additional provision within neighbouring areas
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS7 The Amount of Housing Required
Representation ID: 26323
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Housing requirement - Policy not sound the housing requirement has not been justified. The HBF is concerned that the desire for growth is not being matched by the Council's decision to adopt a housing requirement that is below previous assessment of need with regard to economic growth. The implicit suggestion would appear to be that any additional growth required will be covered by additional delivery elsewhere in the ISPA. However, there does not appear to be any assessment as to whether this will be sufficient and provided in appropriate locations to support the economic and jobs growth aspirations of Ipswich.
In order to make the plan sound the Council will need to justify why they have not considered a higher housing requirement that better meets their jobs growth assessments and affordable housing needs. Whilst we recognise that Ipswich is constrained the Council should have looked to secure additional provision within neighbouring areas.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy ISPA4 Cross Boundary Working to Deliver Sites
Representation ID: 26329
Received: 02/03/2020
Respondent: Home Builders Federation Ltd (HBF)
Agent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
It would appear from the Council’s evidence that they have co-operated effectively with neighbouring authorities to plan for housing needs across the ISPA. Growth expectations are set out in ISPA1 and we agree that the minimum number of homes to be delivered in the areas is circa 35,000 between 2018-2036. However, we cannot comment on whether this has translated into effective joint working regarding the cross-border infrastructure and sites issues set out in ISPA2 and ISPA3. It will be important that the Council can show that the cross-boundary issues concerning the deliverability of those sites in ISPA4 which will meet a considerable portion of the ISPA’s housing needs will be addressed by the Council and the relevant agencies.
Not specified
