Draft Core Strategy and Policies Focused Review

Object

Representation ID: 618

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

BDC/MSDC is concerned over the change in direction away from the existing strategy especially the abandonment of the clear steer in existing paragraph 3.3 "that a jobs-led growth strategy is the right one for Ipswich". NPPF is clear that development should be sustainable with a need for employment centres to continue their role to provide for employment opportunities. This requires the Core Strategy to take a much more positive approach/ have a strategy to jobs provision including taking every sustainable opportunity available to provide employment land within the Borough.

Object

Representation ID: 619

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

BDC/MSDC are gravely concerned about the lack of employment opportunities on a development of this scale, in order to minimise commuting. The proposal lacks: employment opportunities outside the main education/community hub; mention of B Class uses at the hub; and opportunities for commercial employment generating users at the local centres. Most new working age residents will have to travel given a lack of opportunities within close proximity, contrary to sustainable transport principles. The allocation represents a key opportunity to provide jobs close to homes and provide further employment land. Without it the proposal will exacerbate commuting/congestion in the IPA.

Object

Representation ID: 620

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy CS11/8.119 implies that Gypsy and Traveller sites may be identified outside the Borough, without any justification for this approach. Provision outside the Borough would be beyond the control of Ipswich as local planning authority, thus deferring responsibility for delivery to other organizations. This is contrary to a Plan-led approach as required by the NPPF. Permanent gypsy and traveller pitches could be provided through major/comprehensive development schemes e.g. Northern Fringe. That option does not appear to have received explicit consideration. Specific reference should also be made to the provision/funding of infrastructure to support Gypsy & Traveller development outside the Borough.

Object

Representation ID: 622

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

BDC/MSDC would reiterate its concern over the abandonment of existing paragraph 3.3/making the plan "housing led" and whether the approach fits the wider role of Ipswich regards providing employment for a wider area.

Object

Representation ID: 623

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is essential that supporting infrastructure is available to provide for the level of growth proposed. BDC/MSDC are gravely concerned about the impacts of housing on transport infrastructure. Bringing forward the Northern Fringe proposal earlier in the plan period (before 2021) could mean that infrastructure is required earlier, or require different mitigation. The Borough need to make clear the consequential impacts on congestion and deal with the long-term problems caused by intermittent closure of the Orwell Bridge. Appropriate traffic modelling needs to be available to inform such decisions, based on the latest scale, distribution, and phasing of development.

Object

Representation ID: 624

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

CS2(e) BDC/MSDC support offices outside Ipswich centre as this is in line with proposals in BDC/MSDC but there remains the need to identify land for such provision within the Borough as the most sustainable location. The Core Strategy jobs target is reduced to 12,500. BDC/MSDC are concerned that the lack of job opportunities identified in the Borough will create an imbalance between jobs and homes, causing unsustainable commuting patterns. The Core Strategy must meet NPPF obligations: ensuring enough jobs for the in-migration resulting from housing provision; and ensuring job losses are made up for in addition to the projected provision.

Object

Representation ID: 625

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

BDC/MSDC notes that paragraph 8.240 supports the aspiration for a northern bypass and that the merits and options are fully investigated. However while the justifications regards the Orwell Bridge are accepted BDC/MSDC are concerned about the traffic impacts of the Northern Fringe on congestion given the development is being brought forward early. We are also concerned to understand the impacts on rural roads/villages that lie to the north of the development (such as Claydon/Coddenham), would this require any element of the northern by pass and if so that Policy CS20 should be revised accordingly.

Object

Representation ID: 626

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Amend para 8.111 and include it within the Policy text itself.
"The Council will work with Babergh, Mid Suffolk and Suffolk Coastal District Councils to ensure optimum sustainable distribution of any development within the Ipswich Policy Area, bearing in mind the amenity and ecological value of the countryside outside the Borough boundary as well as within it, and the increased congestion effects of any development outside the Borough boundary. Any such development must be supported by adequate infrastructure. Provision outside the Borough boundary will only be sought where evidence shows that locations within the boundary are unsuitable for such provision."

Object

Representation ID: 627

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Paragraph 8.69- refers to the membership of the IPA Board but implies whole districts being included within the IPA. The correct IPA area should be mentioned as well as the IPA Board membership.

Object

Representation ID: 628

Received: 10/03/2014

Respondent: Babergh District Council & Midsuffolk District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Paragraph 8.73/CS6 Under the Duty to Co-operate, involvement with LPA's significantly affected by the impacts of plans is crucial to resolve complex strategic planning issues. Involvement should be from the beginning of the process and be continuous to be effective. BDC/MSDC are concerned whether the pace of plan preparation will allow effective involvement - it has resulted in existing discussion forums being poorly used to engage on strategic issues. As a result while remaining keen to collaborate with the Borough on dealing with strategic issues BDC/MSDC reserves its position on the soundness of Core Strategy.