Draft Core Strategy and Policies Focused Review

Object

Representation ID: 123

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The document only sets out its strategy for future development in part. Through reliance on windfall sites and deferring decisions about growth later in the Plan period, it only shows locations for just over 50% of the 10,500 homes needed to 2031. Although the Plan period is extended and the housing requirement increased, the strategy has not changed from the adopted Core Strategy. The Review fails to identify specific deliverable sites or broad locations for the full housing requirement, and fails the tests of Soundness.

Object

Representation ID: 124

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The document only sets out its strategy for future development in part. Through reliance on windfall sites and deferring decisions about growth later in the Plan period, it only shows locations for just over 50% of the 10,500 homes needed to 2031. Although the Plan period is extended and the housing requirement increased, the strategy has not changed from the adopted Core Strategy. The Review fails to identify specific deliverable sites or broad locations for the full housing requirement, and fails the tests of Soundness.
Sites/broad locations should be identified within the Borough first to meet the full housing requirement.

Object

Representation ID: 125

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The document only sets out its strategy for future development in part. Through reliance on windfall sites and deferring decisions about growth later in the Plan period, it only shows locations for just over 50% of the 10,500 homes needed to 2031. Although the Plan period is extended and the housing requirement increased, the strategy has not changed from the adopted Core Strategy. The Review fails to identify specific deliverable sites or broad locations for the full housing requirement, and fails the tests of Soundness. Should allocate sites in accessible locations.

Object

Representation ID: 126

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

This Policy relates to joint working in the wider Ipswich Policy Area. References that seek to defer decisions on locations for growth required within the Plan period to a future review of the Core Strategy should be deleted in favour of those locations being identified as part of this Core Strategy.

Object

Representation ID: 127

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Policy CS6 - This Policy relates to joint working in the wider Ipswich Policy Area. References that seek to defer decisions on locations for growth required within the Plan period to a future review of the Core Strategy should be deleted in favour of those locations being identified as part of this Core Strategy.
Paragraphs 8.73-8.74 - These paragraphs, which refer to the next Core Strategy review, should be deleted for the reasons given above.

Object

Representation ID: 128

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Policy CS6 - This Policy relates to joint working in the wider Ipswich Policy Area. References that seek to defer decisions on locations for growth required within the Plan period to a future review of the Core Strategy should be deleted in favour of those locations being identified as part of this Core Strategy.
8.73-8.74 These paragraphs, which refer to the next Core Strategy review, should be deleted for the reasons given above.

Object

Representation ID: 129

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

This paragraph includes the assertion that, because of a lack of housing land in the Borough, there will need to be negotiation with neighbouring authorities regarding future housing provision. The sentence appears to pre-suppose that there is no additional suitable land within the Ipswich boundary, which is not the case, and that decisions on locations should happen in the future. The relevant sentence requires deletion.

Object

Representation ID: 130

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Table 2 - The fifth row of Table 2 needs to refer to broad locations in the plural, rather than the singular, since it is evident that the single location at the Northern Fringe cannot meet the entirety of need up to 2031.

Object

Representation ID: 131

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

This paragraph recognises that the NPPF requires, at the very least, the identification of broad locations for the growth required in years 11-15 of the Plan, but then goes on to fail to identify where those locations may be.

Object

Representation ID: 132

Received: 06/03/2014

Respondent: Kesgrave Covenant Ltd

Agent: Mersea Homes Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The policy fails to provide a framework for housing delivery, because it only refers to the allocation of land for 5,909 units, rather than 10,520 required according to Table 2. Reliance on windfall sites and future work with neighbouring authorities to deliver the missing 4,611 units (44% of the total supply), does not meet the requirements of the NPPF. The fact that the opening sentence states that the Council will 'endeavour' to meet its housing requirement rather than a clear commitment to meet that requirement is testament to the lack of certainty in the Plan regarding housing delivery.