Draft Core Strategy and Policies Focused Review

Object

Representation ID: 575

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Council should be clear in understanding the scope of proposed changes to the plan. We are concerned that all aspects of the plan should have been reviewed, as the proposed changes go beyond a 'focused review'. In effect it is a full review and therefore all policies need assessment based on evidence. They must be made consistent with the NPPF. Inspectors will scrutinise these matters closely, as demonstrated by Thurrock and Colchester. Both sought to undertake focused reviews and were questioned on the scope of their changes by their Inspectors.

Object

Representation ID: 577

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Borough's boundary means that there are few areas of undeveloped land able to accommodate strategic development except the Northern Fringe. The Council acknowledges that it will have to rely on neighbours to accommodate the town's continuing growth, therefore demonstrating that the duty to cooperate has been fully engaged will be critical to the plan's success. The Duty involves more than discussions; for authorities which are reliant on neighbours it establishes a higher burden of proof. Changes to CS6 (and CS7) offer limited reassurance that the Duty has been effectively engaged. Refer to the Inspector's tests used in Mid Sussex.

Object

Representation ID: 585

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Need further, up-to-date evidence to substantiate the Borough's objectively assessed housing need, rather than a 2012 update to the 2008 study. Recent changes to the market, which underpin concerns about housing affordability and household formation, should be considered. There are unresolved concerns about household headship rates and it is unclear how ONS data have been used. The Council also needs to demonstrate how it will meet need. Much of the supply relies on broad categories e.g. large brownfield windfall sites. Other sources of land should be considered e.g. commercial sites including retail sites to identify a realistic and deliverable supply.

Object

Representation ID: 586

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The technical appendix to the Ipswich Housing Market Area Population and Household Projections report (September 2013) demonstrates that there are unresolved concerns about household headship rates. It is also unclear how the ONS data have been used as the Projections report refers to the use of an 'adapted version' of the CLG household model. Also the Housing Topic Paper makes no reference to the ONS household estimates used in the Projections report, which is of concern given that both result in a greater number of households than the trend based forecast adopted by the Council. This must be resolved.

Object

Representation ID: 587

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Northern Fringe is the largest single source of land identified through the plan - more significant than IP-One and the rest of the urban area combined, or any windfall sources. It is therefore a cornerstone of the spatial strategy, yet expressions of the spatial strategy e.g. CS2 (also paras 6.8,6.10,6.17,8.28,8.109) treat it as a subordinate element of the strategy. The Northern Fringe should be recognised as an integral and positive element of the spatial strategy and wording amended to reflect that role.

Object

Representation ID: 590

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Development should not be fettered by unreasonable financial burdens. We are concerned that the Borough's failure to review and consult upon key policies which affect viability and thus have a CIL relationship will undermine its approach and risk the adoption of the Core Strategy and CIL. Unrealistic and aspirational policy goals will undermine policy objectives through viability issues. Particular policies which raise viability concerns are: CS12 (unproven affordable housing target) and DM1, DM2, DM7, DM24, DM29 and DM30 (unproven requirements). E.g. Colchester recently reduced its affordable housing requirement to 20%.

Object

Representation ID: 591

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Bringing forward the Northern Fringe is critical to Ipswich's growth. It is important that the plan reads consistently. Currently paragraph 8.109 is outdated in suggesting that the Northern Fringe could undermine the spatial strategy and it should therefore be deleted.

Object

Representation ID: 592

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Bringing forward the Northern Fringe is critical to Ipswich's growth. It is important that the plan reads consistently. Currently paragraph 8.111 adds nothing to the plan and it should therefore be deleted.

Object

Representation ID: 593

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Bringing forward the Northern Fringe is critical to Ipswich's growth. It is important that the plan reads consistently. Currently paragraph 8.112 adds nothing to the plan and it should therefore be deleted.

Object

Representation ID: 594

Received: 10/03/2014

Respondent: Mersea Homes Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Bringing forward the Northern Fringe is critical to Ipswich's growth. It is important that the plan reads consistently. Currently paragraph 8.113 sets out inconsistent time frames for delivery, given the need to commence development in the Northern Fringe at the earliest opportunity. It should therefore be deleted.