Suffolk Coastal Local Plan - Final Draft

Document Section Final Draft Local Plan 12 Strategy for Communities Surrounding Ipswich Land at Humber Doucy Lane, Rushmere St Andrew Policy SCLP12.24: Land at Humber Doucy Lane [View all comments on this section]
Comment ID 1455
Respondent Bloor Homes Eastern (Cope, Guy) [View all comments by this respondent]
Agent Strutt & Parker (Butcher, Andy)
Response Date 25 Feb 2019
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
  • Justified
  • Effective
Details of Representation

1.0      Introduction

1.1 This representation is made by Strutt & Parker on behalf of Bloor Homes Eastern to the Final Draft Plan of the Suffolk Coastal Local Plan Review (2018-2036) (LPR), published for public consultation by Suffolk Coastal District Council between 14th January and 25th February 2019.

1.2 With regard to the tests of soundness which a Local Plan must satisfy, this representation is made on the basis that the Final Draft Plan is not Positively Prepared, Justified, or Effective for the reasons set out below.

1.3 Bloor Homes Eastern are promoting the residential allocation of the land to the north east of Humber Doucy Lane and south of Lamberts Lane, Rushmere St Andrew, Ipswich (Ref. 1145), which is the subject of  this representation. Bloor Homes Eastern are also promoting land to the north east of Humber Doucy Lane and Lamberts Lane, Rushmere St. Andrew, Ipswich (Ref. 1087) which is subject to a separate representation.

1.4 The land encompassed by this proposed allocation is referenced as Site 1145 in the Sustainability Appraisal Report (2018) and the Strategic Housing and Economic Land Availability Assessment (SHEELA) (December 2018). Strutt & Parker have previously submitted representations for the Issues and Options and Preferred  Options Consultation stages of the LPR in respect of this land.

1.5 A location plan outlining the site and an indicative masterplan accompanies this representation. It comprises 13.5 hectares of land north east of Humber Doucy Lane. It is being put forward for short-term delivery of housing.

1.6 Bloor Homes Eastern are also promoting land which lies to the north east of Lamberts Lane (Ref. 1087); which can be viewed as a medium-term opportunity for a Garden Village development. These opportunities have been promoted in response to the identified role of the LPR in addressing the strategic prospects in the area. This is dealt with in a separate statement to this consultation. We acknowledge that the Council will be reluctant, at this present time, to promote the development of a third Garden Village development in the LPR. However, the overall site represents a potential opportunity for such a development which could be brought forward at a future Review of the Plan.

1.7 In that context, this representation should be considered alongside the accompanying representation for the land to the north east of Humber Doucy Lane and Lamberts Lane (Ref. 1087) as part of a strategy to achieve a sustainable pattern of development in the “East of Ipswich” Major Centre to the north-east of the Ipswich urban area, and west of Rushmere Andrew.

1.8 This representation includes responses to the draft policies within the LPR and comments on the Interim Sustainability Appraisal (2018).


2.0      The Context for Growth in the Ipswich Strategic Planning Area

2.1 It is important to consider this potential residential development site in the strategic context of meeting and delivering the housing needs not only of Suffolk Coastal district but also in the wider context of the housing need in the Ipswich Housing Market Area

2.2 The four authorities of Ipswich Borough Council, Suffolk Coastal District Council, Mid- Suffolk District Council and Babergh District Council are presently progressing joint work through the Ipswich Strategic Planning Area Board (formerly the Ipswich Policy Area) on the strategic cross-boundary issues affecting the four authorities. In particular, and with specific relevance to this representation, the authorities (following the Inspector’s report in 2017 on the Examination of the now adopted Ipswich Local Plan) are working together in order to meet the housing need for the Ipswich Housing Market Area and agree the strategic distribution of development to meet that need..

2.3 In 2017 the Ipswich Local Plan Inspector reported as follows:

“28. Given my concerns about the robustness of the 13550 OAN there is an urgent need for the Council to work with its neighbouring authorities to produce a fit-for-purpose objective assessment of need for new housing for the Ipswich Housing Market Area. This conclusion is consistent with my Interim Findings published in April 2016 following the initial Examination hearings but also has regard to the subsequently-published 2014- based household projections. Thus, and in line with the Memorandum of Understanding detailed in the assessment of the Duty to Co-operate, MM4 - MM6 (policies CS6 and CS7) commit the Council to working with its neighbours to prepare an updated OAN for housing for the HMA as a whole, a strategy for the distribution of it between the constituent districts and the adoption of joint or aligned local plans to deliver this by 2019. These modifications are thus necessary for the soundness of the plan, although I have amended MM4 MM6 slightly, reflecting consultation comments, to correct a typographical error and in the interests of clarity.”

29. However, the Council contends that appropriate, available and deliverable housing sites within Ipswich itself would only deliver 9777 dwellings during the plan period. Whilst with reference to specific sites there is some challenge to this figure, there is nothing to give confidence that substantially more than this number of dwellings can be delivered in the town to 2031. Based on all that I have read and heard, considered in the round and notwithstanding the 2014-based household projection figure, I conclude that it is highly likely that the forthcoming work will identify that the OAN for Ipswich for the period to 2031 is at least equivalent to the 9777 dwellings which the Council contends can be delivered in this period”

2.4 The authorities have prepared a Statement of Common Ground (SoCG) (December 2018) to address the strategic cross-boundary planning matters in the Ipswich Strategic Planning Area, which has been published alongside the Final Draft Plan. Key extracts from that document regarding the approach to the delivery of the housing requirement are set out below:

“Housing

C. Agreeing the approach to delivery of the housing requirement

Background

The SHMA Part 1 identified the objectively assessed housing need (OAN) for the four local planning authorities. Subsequently, the Government proposed a national standard method for the calculation of housing need through the ‘Planning for the Right Homes in the Right Places’ consultation (September 2017). The Government has carried these proposals forward through the revisions to the NPPF and the Planning Practice Guidance.

Paragraph 60 of the NPPF (July 2018) states that the standard methodology should be used as the basis for identifying the local housing need, unless there are exceptional circumstances that justify an alternative approach which also reflects current and future demographic trends and market signals

Paragraph 60 of the NPPF states that in establishing the amount of housing to be planned for, planning authorities should take into account any needs that cannot be met in neighbouring areas.

Evidence

The two key pieces of evidence relevant are the housing need and the housing supply.

 The housing need as calculated under the national standard method is set out in the table below, alongside the objectively assessed housing need identified through the 2017 Strategic Housing Market Assessment:

The standard method calculated as per the current policy in the NPPF and Planning Practice Guidance is shown in the shaded boxes above.

 On 26th October 2018 the Government  launched a consultation titled Technical Consultation on Updates to National Planning Policy and Guidance. This proposes that as an interim measure housing need using the standard method should be calculated using the 2014-based household projections. For all authorities in the ISPA this approach results in housing need numbers less than or equal to the need calculated using the 2016-based projections. These figures are shown in the table above.”

and.

“Process of reaching outcomes and agreements

 The Ipswich Strategic Planning Area Board provides a mechanism to discuss the authorities’ approach to housing requirements and to inform and guide the approach to be taken within each Local Plan.

Outcomes and agreements

C1) The housing need calculated under the standard methodology will form the starting point for identifying housing requirements (see shaded columns and bold text in Table 1). The Suffolk Coastal First Draft Local Plan, published for consultation between July and September 2018, was based upon the need figures published by MHCLG in September 2017 under the ‘Planning for the Right Homes in the Right Places’ consultation. The NPPF was published in July 2018 and the Planning Practice Guidance updated in September 2018. The 2017 ratios of median workplace earnings to median house prices were published in April 2018 and the 2016-based household projections were published in September 2018. In accordance with the Planning Practice Guidance, the September 2018 household projections and the April 2018 affordability ratios form the inputs to calculating housing need for each of the authorities.

 C2) The standard method will, therefore, also provide the starting point for identifying the total amount of housing to be provided in the Ipswich Strategic Planning Area.

 C3) Each local planning authority will seek to meet its housing need within its own area. Where the need cannot be met within the local planning authority’s own area, the ISPA Board will provide the mechanism for informing potential distribution across the HMA.

 C4) Provision for Gypsies and Travellers – the 2017 Gypsy, Traveller, Travelling Showpeople and Boat Dwellers Accommodation Needs Assessment identified a need for additional pitches to be provided for Babergh, Mid Suffolk, Ipswich and Suffolk Coastal. Each local planning authority will seek to meet their own need for permanent pitches. Should any authority not be able to meet their own need for permanent pitches, the ISPA Board will provide a mechanism for considering how to address the need.

 C5) Mix and type of housing:

 The Authorities commissioned an update to Part 2 of the Strategic Housing Market Assessment in 2018. This updates the size, type and tenure of housing needed, including the need for affordable housing, based upon the housing need calculated under the standard method.

 C6) Strategic policies in Local Plans are to reflect agreements relating to the outcomes above.

 

Arrangements for necessary ongoing co-operation

 Land Supply:

Throughout the plan-making process should any authority identify that overall land supply falls below that required to meet the housing need, further co-operation will be required across the ISPA to identify potential solutions to inform distribution across the ISPA, for example through re-prioritisation of land uses or new strategic infrastructure.

 Housing numbers:

Where plans have not reached Publication and Submission stage, consideration will be given to any future reviews to the standard method and future data releases.

 D. Consideration of bordering strategic housing developments

Background

Due to the close functional relationship between Ipswich Borough and the surrounding Districts, there is potential for cross-boundary issues relating to infrastructure provision, transport and highways and landscape/townscape as well as site selection where sites adjoin or cross the Ipswich Borough boundary.

 Evidence

The Councils have jointly commissioned transport modelling (with Suffolk County Council). The Methodology Report and the Results Report Volume 1: Suffolk Coastal and Ipswich were published in August 2018 as part of the consultation on the Suffolk Coastal First Draft Local Plan. Further transport modelling of preferred options has been undertaken.

The Councils jointly commissioned a Settlement Sensitivity Assessment in relation to identifying landscape sensitivity around Ipswich.

The Strategic Housing and Employment Land Availability Assessments identify sites which border or cross authority boundaries.

 

Process of reaching outcomes and agreements

The conclusions of the above evidence have been, and will continue to be, considered in site selection and in identifying any necessary mitigation.

 

Outcomes and agreements

Land north east of Humber Doucy Lane is identified as a cross-border location for future development (within Ipswich Borough and Suffolk Coastal District) for housing delivery post 2031. This joint approach will help enable land within Ipswich Borough to come forward for housing.

The relevant policies in Local Plans are:

  • Ipswich Core Strategy and Policies DPD Review Preferred Options (November 2018), Policy ISPA4 ‘Cross Boundary Working to Deliver Sites’
  • Suffolk Coastal Final Draft Local Plan (January 2019), Policy 24 ‘Land at Humber Doucy Lane, Rushmere St Andrew’

 

Arrangements for necessary ongoing co-operation

 Further transport modelling will take place where necessary to inform the Babergh and Mid Suffolk and Ipswich Regulation 19 plans.

2.5 The key points arising from this strategic cross-boundary assessment regarding housing need across the Ipswich Strategic Planning Area as set out in the Statement of Common Ground are that the four authorities are presently planning to meet a housing need of some 39,000 (rounded figure) dwellings up to 2036. Secondly, the Draft SoCG recognises that “due to the close functional relationship between Ipswich Borough and the surrounding Districts, there is potential for cross-boundary issues relating to infrastructure provision, transport and highways and landscape/townscape as well as site selection where sites adjoin or cross the Ipswich Borough boundary”.

2.6 This representation site clearly falls into the category of a cross-boundary (Ipswich and Suffolk Coastal) matter where its selection as a residential development allocation has direct functional implications for both authorities, which the processes of co-operation are to address. The strategic context described above is, in many respects, the most important consideration to be addressed in relation to this site. It is submitted, as part of this representation, that the Final Draft Plan fails to fully address the strategic cross-boundary issues between Suffolk Coastal and Ipswich Borough. The site falls to be considered as a potential sustainable residential development site that assists in meeting the identified housing need of both Ipswich and Suffolk Coastal districts. The site, and its availability for residential development in the short-term, should clearly be viewed in that context.

 

 3.0      Planning Policy Assessment

3.1 Policy SCLP3.2 (Settlement Hierarchy) defines “East of Ipswich” – comprising Kesgrave, Martlesham Heath, Brightwell Lakes, Purdis Farm and Rushmere St Andrew (excluding village) – as one of the two Major Centres in the Plan area; the other being Felixstowe. Table 3.5 indicates that the proposed housing growth at East of Ipswich over the period 2018-2036 will comprise 2,567 dwellings (or 22% of the Plan-wide distribution). More significantly, the Final Draft Plan only makes one new allocation in the East of Ipswich Major Centre up to 2036, being a site for 150 dwellings at Rushmere St. Andrew as set out at Policy SCLP12.24 (see below). A further 20 dwellings is to be allocated in the Kesgrave Neighbourhood Plan.

3.2 The existing village of Rushmere St Andrew is classified as a Small Village in Policy 2, despite its proximity to the existing Ipswich urban area. The Final Draft Plan makes no new housing allocations within the village beyond existing commitments.

3.3 In spatial terms, Rushmere St Andrew is one of the closest settlements in Suffolk Coastal district to Ipswich, and it clearly functions in housing, social, economic and transportation terms as part of the Ipswich catchment area, rather than as part of any other major settlement catchment.

3.4 The Plan’s approach to potential development in the North East Ipswich area is disjointed and contradictory. Policy SCLP12.24 makes an allocation of 9.9 hectares of land to the east of Humber Doucy Lane for development of approximately 150 dwellings post-2031.  The policy states that development will come forward as part of a master planned approach with land in Ipswich Borough. However, the section of the Plan’s Spatial Strategy dealing with “Communities Neighbouring Ipswich” (at paragraphs 3.34-3.35) is contradictory by stating that “… it is not currently considered appropriate to focus the strategy of the Plan on development in this part of the District, etc….” whilst also acknowledging that “in future Local Plan revisions, the Council will reconsider growth opportunities” in the parts of the District neighbouring Ipswich.”

3.5 The Final Draft Plan therefore makes one allocation of land (Policy SCLP12.24) in the North East Ipswich area, whilst acknowledging that there will be a need for a master- planned approach with land in Ipswich Borough. It is submitted that the Plan’s approach to addressing the wider housing needs of the Ipswich Strategic Planning Areas fails to fully consider the strategic cross-boundary considerations described in paragraph 2.6 of this representation.

3.6 It is considered that the final Draft Plan pays insufficient regard to the context of meeting the full housing need up to 2036 across the Ipswich Strategic Planning Area, the potential need for Ipswich Borough Council to consider sites beyond its administrative boundaries to meet its housing need as part of strategic cross-boundary redistribution (as reflected in Agreement C3 in the submitted SoCG) and the fact that a small part of this representation site falls within the Ipswich Borough Council administrative area. As a consequence, there is a failure to address the cross- boundary opportunities for providing sustainable patterns of growth in the Ipswich area in this Plan period, which would clearly be of benefit to both authorities. This failure to address such considerations is most apparent with reference to Policies SCLP3.1, SCLP3,2 and SCLP3.3 in the Final Draft Plan, as further referenced below.

5.0      Conclusion

5.1 It is submitted that the Final Draft Plan is not Positively Prepared, Justified, or Effective for the following reasons:

a) The Plan has not been Positively Prepared

The Final Draft Plan pays sufficient regard to the context of meeting the full housing need up to 2036 across the Ipswich Strategic Planning Area and the potential need for Ipswich Borough Council to consider sites beyond its administrative boundaries (in order to meet its housing need as part of strategic cross-boundary redistribution). There is a failure to fully address the cross-boundary opportunities for providing sustainable patterns of growth in the Ipswich area in this Plan period and particularly towards the end of the Plan period. Such an approach and strategy which would clearly be of benefit to both authorities. This failure to address such strategic considerations is most apparent with reference to Policies SCLP3.1, SCLP3,2 and SCLP3.3 in the Final Draft Plan.

b) The Plan is not Justified

Policy SCLP3.1 (Strategy for Growth in Suffolk Coastal District) and its accompanying supporting justification fails to make any reference at all to the “East of Ipswich Major Centre” as defined in the Plan’s settlement hierarchy. Existing commitments in that Major Centre are not referenced in the Policy, nor is there any indication that the area is part of the “Strategy for Growth” through to 2036 or indeed part of any strategic cross- boundary considerations with Ipswich Borough Council. Policy SCLP3.1 is therefore defective through its failure to recognise and address the strategic cross-boundary issues arising from the Plan’s strategy for growth over the period 2018-2036, and its further failure to take account of the “East of Ipswich Major Centre”. The Plan’s approach, and specifically Policy SCLP3.1, is therefore not Justified.

c) The Plan is not Effective

The Plan’s approach to potential development in the North East Ipswich area is disjointed and contradictory. Policy SCLP12.24 makes an allocation of 9.9 hectares of land to the east of Humber Doucy Lane for  development of approximately 150 dwellings post-2031.  The policy states that development will come forward as part of a master planned approach with land in Ipswich Borough. However, the section of the Plan’s Spatial Strategy dealing with “Communities Neighbouring Ipswich” (at paragraphs 3.34-3.35) is contradictory by stating that “… it is not currently considered appropriate to focus the strategy of the Plan on development in this part of the District, etc….”, whilst also acknowledging that “in future Local Plan revisions, the Council will reconsider growth opportunities” in the parts of the District neighbouring Ipswich.” The Plan is therefore not addressing in full the strategic cross-boundary matters concerning Ipswich Borough Council that will arise during the Plan period and which are already evident. It is seeking to postpone further consideration to future Local Plan revisions. The Plan is therefore not Effective through its failure to address such matters in full at this stage.

5.2 The site which is the subject of this representation is suitable, deliverable and achievable for residential development. Allocation of the site would allow for a sustainable extension to the existing settlement area of Rushmere St. Andrew to help meet existing housing needs in both Suffolk Coastal and Ipswich districts in the short term. The allocation of this site would provide an appropriate element of the Council’s strategy for the “East of Ipswich” Major Centre, without compromising other policies of the Final Draft Plan. It would provide added flexibility to the delivery of additional housing in the first five years of the Plan period, when the likelihood of risks to the projected delivery rate of housing at the Brightwell Lakes development are already evident.

 

Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound

5.3 We therefore seek the inclusion of the land identified and defined at Appendix A to this representation as a medium-term strategic housing opportunity for a new Garden Village in the Local Plan, as part of the strategy for the “East of Ipswich” Major Centre. We respectfully request that the Inspector consider this as a proposed main Modification to the Plan for the reasons set out in this representation.

Attachments
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:

Within our representations we have set out concerns, which may necessitate modifications to the version of the Local Plan which is proposed to be submitted. We would welcome the opportunity to discuss potential modifications with the Inspector, Council, and other participants as part of the Local Plan Examination. We consider we would be well-placed to assist in the examination of the Local Plan, given our work to date in promoting the allocation of land at Rushmere St Andrew.

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