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

Object

Representation ID: 26519

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Council in its paper is mis-leading Councillors as the concept of corridors and the green rim was for the corridors to provide access on foot or by cycle to the countryside surrounding Ipswich. That countryside then became known as the green rim and the intention was for the green rim to be protected from development. We note that in subsequent CSs the green rim has been considerably reduced in size, which demonstrates the Council’s lack of commitment to protecting open space and improving biodiversity in its own Plans. The change in definition is effectively non-compliant with policy DM8.

Object

Representation ID: 26520

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Council in its paper is mis-leading Councillors as the concept of corridors and the green rim was for the corridors to provide access on foot or by cycle to the countryside surrounding Ipswich. That countryside then became known as the green rim and the intention was for the green rim to be protected from development. We note that in subsequent CSs the green rim has been considerably reduced in size, which demonstrates the Council’s lack of commitment to protecting open space and improving biodiversity in its own Plans. The change in definition is effectively non-compliant with policy DM8.

Object

Representation ID: 26521

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Argued for years that previous homes and employment targets set by IBC were too high, unrealistic and based upon flawed evidence. Now clear that previous Plans
were unsound and were therefore sub-optimal for Ipswich as we argued strongly at the time. Disappointing that IBC has taken so long to accept this. The proposed lower targets are more realistic. Agree with IBC that it has established a 5- year land supply of 5.06 years including a 20% buffer or contingency in the 5-year supply. Potential impact of Sizewell C on IGS and CS has not been assessed (rail freight Ipswich-Westerfield).

Object

Representation ID: 26522

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

This needs to include the following highway schemes that SCC assumes will proceed in Ipswich in its ISPA LOCAL PLAN MODELLING Methodology Report Table 3-2 along with the dates they are required by. Without these being implemented the modelling work, and hence the CS is unsound. See 12 highways schemes listed in attached letter. This list excludes improvements to the Henley Road/Dale Hall Lane junctions with Valley Road which are required to be delivered by Crest Nicholson. Needs to be confirmed whether this infrastructure project has been included and modelled accordingly. Support the inclusion of sewage infrastructure in ISPA2.

Object

Representation ID: 26523

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Sewage infrastructure should be included. No agreed sewage infrastructure. If sewage infrastructure cannot be provided at the right time and right price for the IGS (as a whole) then IGS cannot be delivered in accordance with the Plan. All off-line sewage storage should be provided on-site. Not clear what RAMS S106 payments agreed with CBRE and Crest as S106 not public. If no RAMS tariffs included this could be in breach of SPD and policies CS4, CS17 and DM31 of adopted CS. New CS unsound in relation to CS4 CS17 and DM8 as no means of funding the required.

Object

Representation ID: 26525

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Sustainable Development needs to reflect the legal requirement to comply with Air Quality targets, as well as considering them elsewhere in the CS for the CS to be sound.
At the Executive meeting 9th July 2019 Ipswich Borough Council Declared a Climate Emergency and will begin working to become carbon neutral by 2030. This commitment will clearly impact on the CS and needs to be referenced here and in relation to other relevant policies e.g. DM1 and DM2 for the CS to be sound. This would be consistent with the Court of Appeal’s ruling on 27/02/20 that the government's Heathrow's expansion decision was unlawful because it did not take climate commitments into account.

Object

Representation ID: 26526

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

At the Executive meeting 9th July 2019 Ipswich Borough Council Declared a Climate Emergency and will begin working to become carbon neutral by 2030. This commitment will clearly impact on the CS and needs to be referenced here and in relation to other relevant policies e.g. DM1 and DM2 for the CS to be sound. This would be consistent with the Court of Appeal’s ruling on 27/02/20 that the government's Heathrow's expansion decision was unlawful because it did not take climate commitments into account.

Object

Representation ID: 26527

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

At the Executive meeting 9th July 2019 Ipswich Borough Council Declared a Climate Emergency and will begin working to become carbon neutral by 2030. This commitment will clearly impact on the CS and needs to be referenced here and in relation to other relevant policies e.g. DM1 and DM2 for the CS to be sound. This would be consistent with the Court of Appeal’s ruling on 27/02/20 that the government's Heathrow's expansion decision was unlawful because it did not take climate commitments into account

Object

Representation ID: 26528

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Not clear what RAMS S106 payments agreed with CBRE and Crest sites as S106 are not publicly available. If no RAMS tariffs included in the S106 agreements this could be in breach of this SPD and policies CS4, CS17 and Policy DM31 of the adopted CS. New CS would be unsound in relation to CS4 CS17 and DM 8 as no means of funding the required.

Object

Representation ID: 26529

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Existing green rim is an asset and should be protected by adding it to CS4, especially as IBC have previously massively reduced its size and are now attempting to reclassify it and destroy it. Not clear what RAMS S106 payments agreed with CBRE and Crest sites as S106 are not publicly available. If no RAMS tariffs included in the S106 agreements this could be in breach of this SPD and policies CS4, CS17 and Policy DM31 of the adopted CS. New CS would be unsound in relation to CS4 CS17 and DM8 as no means of funding the required.