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

Object

Representation ID: 26361

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

Whilst collaboration between the IPSA authorities has occurred it has not resulted in effective and concrete outcomes to ensure the housing needs of the HMA will be delivered in full. The Local Plan does not form a strategy that will provide the necessary certainty that is needed to ensure that the minimum housing requirement across the Ipswich Housing Market Area can be achieved in full over the plan period. From the outset of the plan making process, the local authorities within the ISPA have been aware of the issue of unmet needs arising from Ipswich over the plan period.

Object

Representation ID: 26366

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

The policy should go further in its approach to ensuring the delivery of sustainable development is consistent with a localised approach to assessing development proposals in line with the ethos of achieving the delivery of sustainable development as required by the NPPF2019 which is key to assessing planning proposals and should be reflected in the policy wording linked to the vision and objectives of the Plan. Refer to the Sustainable Development Statement in the draft Durham Local Plan currently subject to examination. It is a local approach to how development proposals will be considered against the NPPF presumption.

Object

Representation ID: 26375

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

The Plan fails to provide a positive and effective mechanism to ensure the delivery of the HMA’s housing needs in full. It also relies on the delivery of housing from sites in high risk flood zones. IBC need to identify significantly more sites, which are realistically deliverable and viable. IBC must look outside the Borough’s boundary to enable the town’s housing need to be met and identify land that is more suitable for residential development. Gladman are promoting land east of Ipswich, within East Suffolk District, for the development of ‘Orwell Green Garden Village’ and land for a new settlement in Babergh District in a strategic location between Hadleigh and Ipswich.

Object

Representation ID: 26406

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

The Council should plan for a higher level of housing need. The need figure generated by the standard method should only be considered as the minimum starting point. A stepped housing requirement is only appropriate where there is a significant change in the level of housing requirement between plans. Historic delivery does not suggest that the Borough’s housing need will be delivered as they are relying on historic sites with known issues as a continuation of the existing spatial strategy. The historic completions data suggests that the stepped housing requirement will continue to delay meeting identified housing needs. Continued reliance on IP-One to deliver homes in Ipswich is unfounded and unrealistic; further distribution across the HMA is required. The Council’s housing requirement will fail to meet economic and affordable housing needs. It is not evident which sites within the Council’s housing land supply will come forward within the next five years. The rate of delivery at Ipswich Garden Suburb is over estimated. The Council’s assumptions made in respect of the housing trajectory risk the deliverability of the Local Plan.

Object

Representation ID: 26411

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

The Self-build/Custom build homes element of the policy lacks clarity on whether self-build plots should be provided on site. The Council’s Self Build Register identifies 70 interested persons which does not indicate a strong demand for this form of housing. It is recommended that this element of the policy is modified so it as the discretion of the developer to provide self-build homes on site. Gladman would not support an approach which requires all development to provide Self-build homes as there are potential health and safety concerns and practical difficulties in terms of aligning construction activity on the site.

Object

Representation ID: 26415

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

In principle, Gladman has no objections to the allocation of a new settlement as outlined in the proposed policy wording. However, it is essential that the Council has considered all options available for development and it is essential that realistic delivery assumptions have been applied to the sites delivery. Ipswich Borough has not delivered any large sites comparable to the scale proposed for the Ipswich Garden Suburb. It is clear that realistic assumptions on the delivery of Ipswich Garden Suburb have not been applied.

Object

Representation ID: 26417

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

The approach is not effective given the level of affordable housing needs within Ipswich will not be met over the plan period. The Council needs to address this situation if it is to meet the housing market areas full housing needs. NPPF p60 is clear that in addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. The Council must allocate additional housing land to make a meaningful contribution to housing land supply and boost affordable housing delivery.

Object

Representation ID: 26418

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy CS13 seeks to promote sustainable economic growth in the Ipswich Strategy Planning Area. It is noted that the Council has updated its economic evidence as a result of the more recent East England Forecasting Model (EEFM) dataset being published. This has reduced the jobs growth from 15,580 jobs to 9,500 jobs over the plan period. Gladman consider the Plan should be aspirational and should be seeking to increase jobs growth as identified in the preferred options plan as a minimum in order to meet the visions and objectives of the Plan to increase economic activity and access to employment.