Suffolk Coastal Local Plan - Final Draft

Document Section Final Draft Local Plan 12 Strategy for Communities Surrounding Ipswich Policy SCLP12.18: Strategy for Communities surrounding Ipswich [View all comments on this section]
Comment ID 1211
Respondent Carlyle Land Limited (Sir/Madam) [View all comments by this respondent]
Agent CODE Development Planners (Car…
Response Date 25 Feb 2019
Do you consider that this part of the Plan meets the legal and procedural requirements? Yes
Do you consider this part of the Plan has met the tests of soundness? No
Do you consider this part of the Plan to be unsound because it's not:
  • Positively prepared
  • Consistent with national policy
Details of Representation

See comments on paragraphs 3.34 – 3.35

It is disappointing and, in our view demonstrates inappropriate inflexibility to so categorically dismiss large scale development being accommodated in the communities neighbouring Ipswich. The plan, which seeks to guide development delivery over a long period of time to 2036 should retain sufficient flexibility for the possibility of further appropriate development in the communities neighbouring Ipswich particularly to the east and including Brightwell Lakes. Indeed, it is precisely because of the significant infrastructure delivery which flows from the Brightwell Lakes development that makes this a highly sustainable option for more development if required. The policy as drafted would not be sound.

The area referred to including and especially Brightwell Lakes has been identified in earlier local plans for large scale development due to its highly sustainable location and its close relationship to existing facilities. Furthermore, the scale of new development has allowed the viable delivery of additional facilities, thereby ensuring improved sustainability credentials.

Paragraph 72 of the NPPF encourages local planning authorities to consider larger scale development such as new settlements or significant extensions to existing villages and towns where they are well located and designed and supported by the necessary infrastructure and facilities. Paragraph 72 of the NPPF states:

“The supply of large numbers of new homes can often be best achieved through planning for large scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities……. In doing so, they [local planning authorities] should:

  1. Consider the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for the net environmental gains:
  2. Ensure that their size and location will support a sustainable community, with sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access;
  3. Set clear expectations for the quality of the development and how this can be maintained (such as by following Garden City principles), and ensure that a variety of homes to meet the needs of different groups in the community will be provided;…..”

In the case of Brightwell Lakes, the identification of the site for the development of up to 2000 homes directly adjacent to substantial areas of employment and the grant of planning permission with conditions and legal agreements will ensure the delivery of a highly sustainable and well-designed community with substantially improved infrastructure and facilities which could accommodate further potential opportunities for growth over the plan period.

We therefore urge a less dismissive and inflexible statement than that in paragraph 3.34 together with associated revisions to policies 3.1, 12.18 and 12.19 sufficient to consider the potential for further appropriate well planned and complementary development in the area and particularly at Brightwell Lakes.

The importance of maintaining the policy potential for growth in areas to the east of Ipswich is emphasised by the draft plan’s focus on the achievement of sustainable employment generation. The achievement of successful employment growth is, in part, dependent upon appropriate alignment and proximity of housing and employment land. The consented and emerging residential development at Brightwell Lakes is likely to assist in attracting high tech business to the east of Ipswich where the existing cluster of globally leading high technology industries has favoured space adjacent and related to BT’s research campus at Adastral Park.

We urge revisions to draft policies 3.1, 12.18 and 12.19 sufficient to encourage further intensification and expansion of employment space in the areas to the east of Ipswich and to permit well designed and sustainable residential development which complements the existing and future infrastructure.

The Interim Sustainability Appraisal fails to consider all reasonable alternatives to such a policy, it considers only one additional option, i.e. no policy (pages 938 to 941 of Interim Sustainability Appraisal). We would urge a consideration of other reasonable alternatives which would consider the effects of policy options which seek to guide appropriate and proportionate scales and forms of development to complementary to the existing and emerging development, making the best and most efficient use of existing and committed infrastructure improvements.

Overall, we regret to observe that the proposed policy would not be found to be sound.

If your representation is seeking a change, do you consider it necessary to participate in the public examination?
  • Yes, I wish to participate at the oral examination
If you wish to participate in the public examination, please outline why you consider it to be necessary:

As the Promoters of Brightwell Lakes with specific knowledge of the relevant circumstances, the representor may be able to assist the Inspector's understanding on site specific features as they relate to draft policies.

Being kept informed
  • Yes, I would like to be kept informed