Proposed Submission Core Strategy and Policies Development Plan Document Review

Ended on the 5 March 2015
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(1) CHAPTER 8: Development of the Strategy

8.1 The development of a spatial strategy is a vital component of this document and is central to the Council's Local Plan. It will form the basic framework that will guide the contents of the rest of the Local Plan.

8.2 This chapter is divided into six sections. The first provides a strategic spatial approach to the development of the town; the next four relate to the components of 'live, work, learn and play', and the final section relates to infrastructure to support growth and development.


8.3 This section sets out six strategic issues that will form the central component of the Ipswich spatial strategy - i.e. how and where growth is to be accommodated in order to deliver the Ipswich vision. These issues strongly influence the development of the content of the themed (live, work, learn and play) components of this Core Strategy and from there all the other components of the Local Plan

8.4 Six issues are addressed below. They are:


Sustainable Development - Climate Change


The Location and Nature of Development


IP-One Area Action Plan


Protecting our Assets


Improving Accessibility


The Ipswich Policy Area

8.5 Sustainable Development

8.6 Achieving more genuinely sustainable development in delivering growth is the key policy thrust of the plan. Sustainability considerations are diverse and need to be prioritised in all decisions relating to the location, form and design of development.

8.7 In the following policies, policy CS1 Sustainable Development - Climate Change covers the key areas of energy conservation, carbon reduction and water use; and policy CS4 Protecting our Assets covers the conservation of the built and natural environment and the use of natural resources.

8.8 Policies CS2 The Location and Nature of Development and CS5 Improving Accessibility set out the approach to locating development so as to maximise sustainable travel opportunities and to use land efficiently, taking into account existing and future flood risks.

8.9 The social and economic objectives of sustainable development are covered in subsequent policies relating to housing provision (see the 'Live' section) and employment provision (see the 'Work' section).

Sustainable Development - Climate Change

8.10 Achieving sustainable development is a fundamental aim of the planning system and lies at the heart of the vision and objectives set out earlier in this plan. The starting point for considering sustainable development is tackling climate change, because of the scale of the threat and the potential severity of its effects on ecosystems and human existence. The UK Climate Projections 2009 indicate the likelihood in the East of England of higher year round temperatures, higher winter rainfall, lower summer rainfall and sea level rise. Reducing carbon emissions, so as to reduce Ipswich's contribution to climate change, is an imperative of this plan. Not only is it required by national policy but it is also in the direct interests of a town with a central area situated on low-lying land on an estuary subject to tidal flooding.

8.11 A consequence of climate change is likely to be increased winter rainfall and decreased summer rainfall (CRed Suffolk report, Suffolk Climate Action Plan, and UK Climate Projections 09) and the full impact on the natural ecosystem is largely unknown. Therefore, as well as reducing the impact of development on climate change, it is equally important to manage water resources through policies for the efficient use of water and minimisation of run-off from new development.


In Ipswich a comprehensive approach will be taken to tackling climate change and its implications through:

  1. Requiring all new development to incorporate energy conservation and efficiency measures, to achieve significantly reduced carbon emissions for all new residential and major non-residential development;
  2. Requiring all major developments to achieve a target of at least 15% of their energy requirements to be provided through decentralised renewable or low carbon energy sources where feasible and viable;
  3. Seeking opportunities to develop renewable energy generating capacity including on Council-owned land and buildings;
  4. Supporting the implementation of the Suffolk Climate Action Plan produced by the Suffolk Climate Change Partnership and other appropriate local carbon reduction schemes;
  5. Implementing the IMPACT Carbon Management scheme and reducing carbon emissions from the Council's own operations;
  6. Supporting the protection, caring for and increase in canopy cover across the Borough during the plan period;
  7. Seeking opportunities to utilise parks and open space and ecological networks potential in the mitigation and adaptation against climate change;
  8. Supporting the implementation of the Ipswich Flood Defence Strategy by the Environment Agency;
  9. Requiring building and infrastructure design to incorporate water conservation, capture, recycling and efficiency measures and sustainable drainage systems (SuDS); and
  10. Supporting the implementation of Travel Ipswich to promote 15% modal shift to reduce carbon emissions.

When considering development proposals the Council will take a positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. It will always work proactively with applicants jointly to find solutions which mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area.

Planning applications that accord with the policies in this Local Plan (and, where relevant, with polices in neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise.

Where there are no policies relevant to the application or relevant policies are out of date at the time of making the decision then the Council will grant permission unless material considerations indicate otherwise - taking into account whether:

  • Any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, when assessed against the policies in the National Planning Policy Framework taken as a whole; or
  • Specific policies in that Framework indicate that development should be restricted [3] .

8.12 Ipswich has an estimated carbon footprint of 4.2 tonnes of carbon dioxide produced each year per head of population (2011 data from Department for Energy and Climate Change). About 42% of those carbon emissions are estimated to come from people's homes, 20.5% from transport (less than the Suffolk and national averages, because of the urban nature of the Borough), 36% from industry and 1.5% from waste. Nationally about 60% of domestic carbon emissions result from space heating and hot water. Therefore improving the energy performance of existing and new domestic buildings is a key sector to target in order to reduce the climate change impacts of new development.

8.13 The Government continues to work towards the target of achieving zero carbon homes by 2016. A zero carbon home is currently defined as one that delivers zero net carbon over a year from all 'regulated' energy uses which includes heating, hot water, lighting and fixed appliances. The Government is proposing to implement this through setting greater minimum standards for energy efficiency in the Building Regulations which would operate in tandem with 'allowable solutions' whereby developers can select to either incorporate greater efficiencies in the building's fabric, deliver on- or off-site renewable energy or provide a financial contribution to renewable energy projects elsewhere, or provide a mix of these measures. Ipswich is planning for high levels of housing and employment growth by 2031. This represents a vital opportunity to ensure that this significant addition to the building stock of the Borough minimises its impacts on climate change. Non-residential buildings also offer the opportunity to save emissions and the Government maintains a commitment for non-residential development to be carbon neutral by 2019.

8.14 Policy DM1 in Part C of this document provides more detail as to how sustainable buildings can be delivered in Ipswich through the Code for Sustainable Homes for residential development, and BREEAM ratings for non-residential development, in advance of any further Government measures. The Plan is not prescriptive about how developers should achieve these targets. There is a significant amount of existing advice available about sustainable construction [4] .

8.15 There is also a social sustainability imperative to reduce carbon emissions from homes. Since 2005, the UK has become a net importer of fossil fuels causing energy prices to rise sharply. Therefore Ipswich needs to be reducing its dependence on these fuels.

8.16 The National Planning Policy Framework states that Local Authorities should recognise that it is the responsibility of all communities to contribute to energy generation from renewable or low carbon sources, and that they should have a positive strategy to promote energy from renewable and low carbon sources. The Planning and Energy Act 2008 also allows local planning authorities to adopt policies which require developers to meet a proportion of their energy requirements from renewable or low carbon sources, and this is taken forward through policy DM2. The National Planning Policy Framework requires local planning authorities to support the move to a low carbon future and when setting any local requirements for a building's sustainability, to do so in a way consistent with the Government's zero carbon buildings policy and adopted nationally described standards. Policies should be designed to maximise renewable and low carbon energy generation whilst addressing any adverse impacts satisfactorily, including cumulative landscape and visual impacts. Implementation of this policy will help to make a significant impact on reducing carbon emissions because buildings are a major source of emissions in Ipswich, in advance of the zero carbon buildings programme taking effect. Funding streams such as the Feed in Tariff and Renewable Heat Incentive will be promoted to increase the addition of micro-generation equipment on private properties and Borough owned properties will also be equipped with micro-generation equipment where possible.

8.17 The carbon reduction and climate adaptation scheme, Suffolk Climate Change Partnership, is a partnership project with Suffolk County Council and others to help with information sharing, advice and practical measures so that individuals and businesses can reduce their carbon emissions and adapt to a changing climate. This is an essential strand of the strategy in tackling existing buildings and helping people to choose more sustainable lifestyles.

8.18 The IMPACT Carbon Management Plan sets out how Ipswich Borough Council will achieve carbon reductions from its own operations. Against a 2007/08 baseline the Council has achieved a 21% reduction by March 2014 against a target of 20% set by the Council in March 2012. The Council also signed the Nottingham Declaration on Climate Change in 2008.The Council applies the Ipswich Standard to its own dwelling stock. The standard includes the provision of energy efficient boilers, double-glazing and insulation.

8.19 A combination of the measures set out will help to achieve overall carbon reduction at least in line with national targets. The Climate Change Act 2008 calls for at least 26% reductions from 1990 levels to be achieved by 2020. The Suffolk Climate Change Action Plan 2012 takes this a step further and sets a target of 60% reductions from 2004 levels, by 2025. 2004 is the first year for which there is a full set of emissions data for Suffolk and therefore may prove more practical for monitoring purposes.

8.20 Many buildings in Ipswich are at risk of flooding, some from tidal surges and many from heavy rain. This risk will continue to grow as a result of rising sea levels and increasingly heavy rainstorms that can overwhelm drainage systems and cause localised flooding unless mitigation measures are implemented. At the strategic scale, tidal flood risk will be tackled through the completion of the Ipswich Flood Defence scheme including a tidal surge barrier. However developments located within the flood plain will still need to address residual risk in accordance with the National Planning Policy Framework (e.g. the risk of defences failing). Managing surface water run-off is also important. SuDS, rainwater harvesting, storage and where appropriate the use of green roofs or water from local land drainage will be required wherever practical. Such approaches shall be particularly mindful of relevant ecological networks. New buildings need to be more adaptable and resilient to climate change effects in future.

(2) 8.21 The Haven Gateway Water Cycle Study Stage 1 Report identified issues with water supply and sewerage in Ipswich. It advised that sustainable drainage and other demand management techniques are used to manage water demand and surface water run-off in the Borough. The Council's Drainage and Flood Defence policy DFD10 has required SuDS wherever reasonable practicable since 2002 [5] . In addition the Council has a surface water management plan and a strategic flood risk assessment, and there is also a Suffolk local flood risk management strategy and catchment flood management plan, and a National strategy for SuDS, all of which are referred to in the Council's Development and Flood Risk supplementary planning document (September 2013).

8.22 Trees, woods and canopy cover as a whole can provide part of the solution to limiting climate change, and to helping society to adapt to the changes that we all face. On a global scale, we must protect and manage the canopy cover we already have as well as planting new canopy cover to "mitigate" climate change. CABE Space - 'The benefits of urban trees' states a 10% increase in green cover can potentially eliminate the effects of climate change on increasing surface temperatures. Forestry commission scientists also state a 4% increase of UK land planted with new woodlands over 40 years could be locking up 10% of the nation's predicted greenhouse gas emissions by the 2050s.

8.23 There can be a multitude of benefits: for the climate, for people and for wildlife. Wood is a smart choice - timber is renewable and can replace other materials that require much larger fossil fuel inputs for their production. It can also replace fossil fuels directly in the form of renewable energy, or wood fuel. Trees can help Ipswich to adapt to a changing climate by intercepting rain in heavy rainstorms and to help alleviate flooding, moderate local microclimates - urban areas with trees are cooler in summer and warmer in winter, and help tackle the urban heat island effect, as well as creating a valuable wildlife habitat. Ipswich's canopy cover and health care needs is changing. The Council aims to help the Borough's canopy cover to adapt and become resilient to the changing climate. Canopy cover and arboriculture can be an important and attractive part of the solution in Ipswich.

8.24 Green spaces and functioning ecosystems help in adapting to the extremes of climate change. Green areas in the Borough have less of a heat island effect than built-up areas providing opportunities for people to keep cool in hot weather. Green spaces also improve air quality contributing to reduced ground-level ozone, fine particulates and respiratory irritants. Functional ecosystem can also mitigate the risks associated with downstream flooding from extreme rainfall events. In recent years there is also an upsurge in 'growing your own' food on allotments that helps reduce the miles food travels. From mitigating the effects of climate change to improving health, parks and green spaces play a vital part in Ipswich.

(1) 8.25 This policy implements plan objectives 1 and 2.

The Location and Nature of Development

8.26 The second vital element of sustainable development is where to locate new development so that people can easily access the jobs, goods and services they want and need, by the most sustainable modes of travel. This benefits individuals by encouraging cycling and walking, which are cheap and healthy ways to get around. It benefits communities by enabling facilities to be accessed by as many people as possible and providing opportunities for people to meet. It benefits the environment and health by reducing vehicular emissions, and the economy by reducing congestion.


The regeneration and sustainable growth of Ipswich will be achieved through:

  1. Focusing new residential development and community facilities into the town centre, the Waterfront, Ipswich Village, and Ipswich Garden Suburb and into or within walking distance of the town's district centres;
  2. Later in the plan period, working with neighbouring authorities to address housing need within the Ipswich housing market area;
  3. Focusing major new retail development into the Central Shopping Area;
  4. Focusing new office, hotel, cultural and leisure development into Ipswich town centre;
  5. Promoting a strategic employment site at Futura Park, Nacton Road, to support economic development and jobs growth;
  6. Directing other employment uses (B1 ( except office), B2 and B8) to employment areas distributed in the outer parts of the Borough, and there will be a town centre first approach to the location of offices;
  7. (1) Dispersing open space based (non- commercial) leisure uses throughout the town with preferred linkage to ecological networks and/or green corridors, and protecting the countryside from inappropriate development; and
  8. Development demonstrating principles of very high quality architecture and urban design and which enhances the public realm.

A sustainable urban extension to north Ipswich is planned subject to the prior provision of suitable infrastructure (see policy CS10).

Major developments within the town centre, Ipswich Village, and district centres should incorporate a mix of uses to help achieve integrated, vibrant and sustainable communities. Major developments (for the purposes of this policy) are defined as commercial developments of 1,000 sq. m or more or residential developments of 10 dwellings or more. Exceptions may be made for large offices or education buildings for a known end user.

Development densities will be high in the town centre, Ipswich Village and Waterfront, medium in the rest of IP-One and in and around the district centres, and low elsewhere, where it does not compromise heritage assets and the historic character of Ipswich.

8.27 This approach to the location of development is centred on the town centre (which includes Ipswich Village and the Waterfront), Ipswich Garden Suburb and on the town's district centres. The strategy is illustrated in the key diagram. The exact boundaries of these areas will be defined on the policies map through the policies of this plan and the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document. The town centre, Ipswich Village and Waterfront will receive the highest densities of development in the town - including high-density housing developments. Medium-density and locally focused facilities would then be provided elsewhere in IP-One and within and around district centres (defined in paragraph 8.34), with lower density development elsewhere. Developments at higher densities will require special attention being paid to their urban design and greening qualities. Residential densities are defined in policy DM30.

(5) 8.28 This approach to the location of development enables multiple objectives to be achieved.

  • It will maximise opportunities to re-use previously developed land within central Ipswich.
  • It will ensure that new housing is provided close to local shops and facilities that can be accessed by non-car modes, which contributes to reducing carbon emissions and supporting communities.
  • It will support the ongoing regeneration of central Ipswich and particularly of the Waterfront and town centre.
  • It will help to ensure the effective and efficient use of land through developing at appropriate densities according to the accessibility of the location.
  • It will create a sustainable Garden Suburb to help meet the housing needs of the Borough.

8.29 This policy therefore implements objectives 4, 6 and 9.

8.30 The central urban focus to the location of development also reflects the sequential approach to site selection required by the National Planning Policy Framework (which encourages the use of previously developed land) and maximises the chances of making central Ipswich an increasingly vibrant and dynamic place. Chapter 6 of the plan sets out flood risk considerations.

(1) 8.31 Later in the plan period after 2024, the Council's housing land supply opportunities within the Borough boundary become more limited and, therefore, there will be a need to consider future development opportunities beyond the boundaries with the neighbouring local authorities. Policy CS7 sets out the Borough's objectively assessed housing need.

8.32 The approach to locating employment uses focuses office activity into the town centre, in accordance with the National Planning Policy Framework, to support its vitality and viability. It also provides a strategic employment site, located where it can build on the success of Ransomes Europark. It directs other employment uses, particularly B2 and B8 uses, which tend to be more extensive and less suited to central locations, to the town's outlying employment areas. These are accessible from residential areas, yet sufficiently segregated from them to minimise the possibility of conflicts between residential uses and potentially noisy or odorous industrial activities. The boundaries of employment areas are delineated on the policies map.

8.33 Major developments within Ipswich town centre, Ipswich Village, the Waterfront and District Centres are required to include a mix of uses to help create more diverse neighbourhoods that can in turn contribute to the vibrancy of the town and district centres and reinforce a sense of place and distinctiveness. For example, including some residential uses within office areas helps to keep the areas populated after office hours. This in turn can encourage more shops and community uses to locate there creating truly mixed-use neighbourhoods. Living over shops is also a way to make more efficient use of buildings. However, where development is for the use of a known, single large user, an exception may be made if it is demonstrated that mixed use would harm the viability of the scheme. This mixed-use approach will not apply in the identified employment areas of the town centre unless specified in site allocations.

8.34 The district centres referred to in the policy and identified in the key diagram are as follows:

  • Meredith Road (3)
  • Norwich Road (1-91, 2-110) / Bramford Road (7)
  • Hawthorn Drive (9)
  • Stoke Park (11)
  • Wherstead Road (13)
  • Cauldwell Hall Road / Woodbridge Road (418-785) (18)
  • Felixstowe Road (55-201, 120-190) (23)
  • Nacton Road (270-374) (28)
  • Ravenswood (47)
  • Woodbridge Road East (27-53) / Heath Road (17)
  • Sproughton Road / Eastway (to be developed)
  • Duke Street (48)

8.35 Ipswich Garden Suburb (see policy CS10) will also contain a district centre that would join the above list.

8.36 Within a 400m straight line distance from district centres, the Council would support the provision of identified community facilities (see Appendix 4). Within a wider zone of 800m, the Council would support in principle medium density housing provision to try to increase the proportion of people living near to shops and community facilities.

8.37 It should be noted that many of the centres above already have some of the community facilities mentioned within 400m of their centres. Zonal maps of the above centres are shown on Plan 1.

8.38 In dispersing open space across the Borough, where possible provision should be in low-lying areas needed for flood storage or conveyance.

8.39 Delivering high quality change, which safeguards the best of the town's urban character and neighbourhoods and secures positive improvements, is not just confined to the IP-One Area and Conservation Areas. The NPPF advises that sustainable development 'involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people's quality of life'. To facilitate this, an Urban Character Study supplementary planning document is being undertaken to define the environmental characteristics of the Borough as a whole.

IP-One Area Action Plan

8.40 As the spatial strategy focuses development to a significant degree on central Ipswich and particularly on the areas that ring the historic core, the Council is preparing an area action plan for the area - known as IP-One - to guide its delivery, which will be incorporated into the Site Allocations and Policies development plan document (DPD). The IP-One area has been defined by the Council. It is slightly larger than the town centre and includes the central shopping area, Ipswich Village, the Waterfront and the Education Quarter. The IP-One area is indicated broadly on the key diagram. It is defined on the policies map.


The Council will prepare and implement an IP-One Area Action Plan incorporated in the Site Allocations and Policies development plan document to plan for significant change in central Ipswich. The Area Action Plan will include policies which:

  1. Define the extent of the Waterfront and Ipswich Village;
  2. Allocate sites for development in IP-One
  3. Set down development principles to apply in identified opportunity areas where change will be concentrated;
  4. Define and safeguard the Education Quarter to support the development of University Campus Suffolk, Suffolk New College and a new primary school;
  5. Identify heritage assets which development proposals will need to have regard to and integrate new development with the existing townscape;
  6. Define the Central Car Parking Core within which parking controls will apply;
  7. Identify where new community facilities and open space should be provided within IP-One;
  8. Provide a framework for the delivery of regeneration in IP-One and address the need for infrastructure, including the need for an additional access to the Island Site; and
  9. Provide tree-planting, urban greening schemes mindful of the ecological network to improve the street scene and permeability for wildlife throughout the town centre.

Sites and designated areas within the IP-One area will be identified on a revision of the policies map to be prepared alongside the DPD.

8.41 Area action plans are intended as a tool to guide development in areas where change is expected and/or conservation policies apply. IP-One includes both types of area, encompassing as it does the medieval core of the town, which now forms the focus for the Central Shopping Area; the Waterfront and Village where regeneration activities are focused at present; and the Education Quarter where University Campus Suffolk is taking shape. The IP-One Area Action Plan builds on earlier work that resulted in the publication of a non-statutory area action plan in 2003.

Protecting our Assets

(1) 8.42 Ipswich has a rich and varied heritage of built, historical and natural assets, including more square miles of park per thousand population than anywhere else in the UK. The Borough contains:

  • Over 600 listed buildings and structures;
  • 14 conservation areas;
  • A Ramsar Site and Special Protection Area for Birds (part of the Stour and Orwell Estuaries site);
  • 4 Sites of Special Scientific Interest - three for wildlife and one for geology;
  • 19 County Wildlife Sites;
  • 10 scheduled monuments;
  • 3 County Geodiversity Sites
  • 2 Regionally Important Geological Sites
  • An ancient woodland;
  • An area of archaeological importance for its Anglo-Saxon remains in central Ipswich; and
  • 3 registered parks and gardens and 518 hectares of parks and open spaces.

There is also a Suffolk Biodiversity Action Plan (BAP), which identifies certain habitats and species of particular importance to Ipswich, and a small part of the Borough lies within the Suffolk Coast and Heaths Area of Outstanding Natural Beauty.

8.43 These assets help to make Ipswich the place it is and they make an important contribution to people's quality of life in the Borough. They may also have a wider national and international value and interest and, in the case of wildlife, play an important role in the function of complex ecosystems. Therefore, these valuable elements of the Ipswich asset base must be protected, enhanced and integrated sensitively with new development.

8.44 The Ipswich asset base also includes all the finite natural resources that the Borough depends on, such as minerals used in construction and land and soil itself. The concept of 'one planet' living illustrates the issue of resource use and the impacts of our lifestyles on the environment. Currently our lifestyles in Europe are such that, if everyone worldwide lived in the same way, we would need three planets Earth. This is unsustainable. We therefore need to take opportunities to use natural resources more sparingly and efficiently, to re-use and recycle materials and to source materials locally where possible.


The Council is committed to conserving and enhancing the Borough's built, historical, natural and geological assets.

The Council will conserve and enhance the character and appearance of conservation areas, by preparing character appraisals and using them to guide decisions about development. The Council will also conserve and enhance heritage assets within the Borough through its development management policies.

The Council will also seek to conserve and enhance local biodiversity in accordance with the National Planning Policy Framework and national legislation by:

  1. Applying an appropriate level of protection to international and nationally designated sites;
  2. Requiring new development to incorporate provision for conserving and enhancing local biodiversity, canopy cover and geodiversity interests;
  3. Supporting the Greenways Project;
  4. Designating additional Local Nature Reserves where appropriate;
  5. Preparing and implementing management plans for Council owned wildlife sites; and
  6. Identifying an ecological network across Ipswich and linking into adjacent areas, and protecting and enhancing it in accordance with policy DM31 to maximise the benefits of ecosystem services.

The Council will encourage the use of local reclaimed, renewable, recycled and low environmental impact materials in construction, in order to conserve finite natural resources and minimise environmental impacts. New development will also be required to minimise the amount of waste generated during construction and through the lifetime of the building.

(1) 8.45 Most of the built, historical and natural assets are protected by one or more pieces of legislation, policy documents or circulars, including:

  • EU Habitats Directive;
  • Wildlife and Countryside Act 1981;
  • The National Parks and Access to the Countryside Act 1949;
  • Countryside and Rights of Way Act 2000;
  • Ramsar Convention on Wetlands;
  • Hedgerows Regulation 1997;
  • Plant Health Act 1967 and orders;
  • Forestry Act 1981;
  • Natural Environment and Rural Communities Act 2006;
  • The Town and Country Planning Act 1990;
  • Planning (Listed Buildings and Conservation Areas) Act 1990;
  • Ancient Monuments and Archaeological Areas Act 1979;
  • National Heritage Act 1983;
  • The National Planning Policy Framework (2012);
  • The Localism Act 2011; and
  • Government Circular 1/01.

8.46 This framework of legislation, guidance and policy currently provides comprehensive protection for the assets. Considering first listed buildings, the Council will rely on this national legislation, policy and guidance to guide their protection. Local policy is also provided through policy DM8 Heritage Assets and Conservation. However, national policy has been consolidated into the National Planning Policy Framework with the Historic Environment Planning Practice Guidance produced by English Heritage remaining applicable to ensure that policy and guidance are properly inter-related and that listed buildings, conservation areas and other heritage assets will be adequately protected as at present. As the English Heritage guidance is described as a 'living draft' and has been the subject of a draft revision to coincide with the NPPF, the Council is preparing a supplementary planning document to protect the special local distinctiveness of Ipswich heritage assets if necessary (the Urban Character Supplementary Planning Document).

8.47 Conservation areas differ from listed buildings in that they are locally designated. Their designation is based on the particular character of the area and local planning authorities are encouraged to prepare character area appraisals and management plans for conservation areas as a tool to guide development management decisions. Therefore the policy will apply in conservation areas.

8.48 All conservation areas have been the subject of detailed Conservation Area Character Appraisals. Those for areas designated by 1994 were the subject of public consultation and Council approval during 1994-95. Subsequently three additional conservation areas were declared in 1995, 2003 and 2005 for which appraisals were also prepared. Periodic reviews of all conservation areas are required by heritage legislation and these have been undertaken at approximately five yearly intervals since 1994 involving a review of boundaries, the descriptive content of the appraisals and the area specific policies and proposals. The Local Plan anticipates major change in or adjacent to parts of the Central Conservation Area but this is not expected or proposed to the same extent for the remainder of conservation areas.

8.49 The Orwell Estuary provides an important ecological network and landscape setting for Ipswich and helps define its history. It is characterised by its broad expanse of water and its gently rolling, wooded banks. The transition between the built-up character of Ipswich and open countryside is quite sharply defined around most of the present Borough boundary, with the transition from urban to rural appearance and uses being clearly appreciable. The Orwell Estuary will be covered by the South East Inshore Marine Plan when it is completed. This will set out priorities and directions for future development within the plan area, inform sustainable use of marine resources, and help marine users understand the best locations for their activities, including where new developments may be appropriate. An East Inshore and Offshore Marine Plan was adopted on 2nd April 2014 which covers an area adjacent to the Suffolk Coast north of the River Orwell. Early consultation with the Marine Management Organisation will be required where any work requiring consideration under the Marine Works (Environmental Impact Assessment) Regulations 2007 is to be undertaken.

(1) 8.50 For wildlife habitats, an ecological network approach has been adopted in accordance with the National Planning Policy Framework. Ecological networks are an effective way to conserve wildlife and biodiversity where habitats have become fragmented. They support its resilience to pressures such as urban development and climate change. The network includes internationally, nationally and local designated sites which are protected in accordance with the National Planning Policy Framework. Development in the vicinity of areas with nature / wildlife and geological designations must take into account the wider effects on those sites. The Council also recognises its biodiversity responsibility under the Natural Environment and Rural Communities Act 2006. This Act introduced the requirement for public bodies, in exercising their functions, 'to have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity'.

8.51 Ipswich will see significant new building over the plan period. It is therefore essential that opportunities be taken through development to conserve and enhance the biodiversity and canopy cover that is essential to life. This will include in some cases providing and enhancing strategic green space, such as the existing ecological networks, with biodiversity features, and in all cases incorporating provision for biodiversity. This could include green roofs or walls for insects and birds, wood piles for beetles, nest boxes for birds, and in ecological networks can increase permeability of wildlife in new development through biodiversity enhancements. Therefore the policy will apply to all new developments in the Borough. Development at the Ipswich Garden Suburb will provide an opportunity to contribute to biodiversity.

(2) 8.52 The Stour and Orwell Estuary Special Protection Area is protected under the Habitats Directive due its importance for bird populations. The plan has been subject to an Appropriate Assessment under the Habitats Directive. This concluded that visitor numbers to the Orwell Estuary will increase as a result of growth in the Ipswich Policy Area and could adversely affect the Estuary's Special Protection Area for birds. Measures to avoid and mitigate any such potential impacts are included in the plan.

8.53 Scheduled Monuments are designated by the Secretary of State who must approve any works that might affect them, having consulted English Heritage as the body responsible for national policies on their maintenance and recording. National policy obviates the need for a local policy on this matter. Proposals affecting designated and non-designated Ipswich heritage assets should be informed by the Historic Environment Record for Suffolk maintained by the County Council which is also consulted on planning applications that could affect archaeology. Ipswich's archaeological legacy is important in helping to tell the town's story and will therefore be protected and managed in accordance with the NPPF and policies CS4 and DM8. Central Ipswich is an Area of Archaeological Importance, for which a development management approach is set out in policy DM8.

8.54 Living ancient monuments such as veteran and near veteran trees in the ancient stage of their life are of interest biologically, aesthetically and culturally because of their age. Ancient and semi-natural woodlands and veteran trees are irreplaceable habitats of high biodiversity value should be protected from development that would result in significant damage.

8.55 English Heritage also has a role registering historic parks and gardens. Whilst registration offers no additional statutory protection, it is a material consideration in development management.

8.56 In addition to protected Listed historic buildings, there are many buildings of local townscape interest (on 'local lists') that are not just confined to conservation areas but are located throughout Ipswich. Some of these buildings may be the main architectural landmarks of distinction in the local area. Many such buildings were designed during the 19th and 20th Centuries by local architects. Local authorities are encouraged to prepare inventories of such buildings and add these to the Historic Environment Record. It is government policy that these non-designated heritage assets should be taken into account when determining planning applications to ensure their retention so as to help maintain local distinctiveness and a sense of place. An Ipswich Local List dating from 1977 has been updated and adopted as a supplementary planning document in September 2013

8.57 All the designated sites or areas will be listed in the Site Allocations and Policies (incorporating IP-One Area Action Plan) plan document and will be identified on the policies map.

8.58 The Council will encourage the conservation and efficient use of natural resources in order to work towards sustainable 'one planet' living in Ipswich. This will be implemented through a development management policy in Part C of this document that applies the framework provided by the Code for Sustainable Homes and BREEAM rating, subject to any forthcoming Government changes to the Code. In addition, new development will be required to minimise waste generated.

8.59 Policies for the protection of assets through the development management process are set out within Part C of this document.

8.60 This policy supports plan objective 1.

Improving Accessibility

8.61 Ipswich is planning for growth and ways therefore need to be found to optimise the accessibility of new developments without increasing congestion. The town benefits from being relatively compact, which lends itself to cycling and walking.

8.62 In addition, the transport sector is a significant source of carbon dioxide emissions, which need to be reduced as part of a comprehensive approach to tackling climate change. It is also responsible for the pollution in the Ipswich Air Quality Management Areas and therefore there are also potential health benefits to tackling vehicular emissions through a comprehensive approach to mobility and access. Therefore the following policy will be applied to all development.


Development should be located and designed to minimise the need to travel and to enable access safely and conveniently on foot, by bicycle and by public transport (bus and rail). This will encourage greater use of these modes. The Council will support the implementation of the Travel Ipswich scheme and will work with the Highway Authority to manage travel demand in Ipswich and in doing so will prioritise the introduction of an integrated cycle network.

(1) 8.63 If people are to be encouraged to walk, cycle and use public transport, to help the town achieve environmental and health objectives, then developments must be located and designed such that these modes rival the car for cost and convenience and that routes are more pleasant in the surroundings such as along avenues or ecological networks.

8.64 The Travel Ipswich scheme has been developed over recent years to support regeneration objectives through an integrated package of sustainable transport measures. It will include changes to the town centre bus interchanges; expansion and improvement of other bus facilities; an Urban Traffic Management and Control system; a Real Time Passenger Information system; and a detailed programme of improvements to walk/cycle routes and crossings in and around the town centre.

8.65 The Travel Ipswich scheme will deliver wide-ranging improvements for users of these modes.

8.66 This policy is also aimed at ensuring the accessibility of buildings and developments by people whose mobility is impaired.

The Ipswich Policy Area

8.67 Ipswich has relatively tight administrative boundaries and clearly there are cross boundary issues that are relevant to the development and future of the Borough, the urban area of Ipswich and surrounding areas.

8.68 This has long been recognised within the former Suffolk Structure Plan via the identification of the 'Ipswich Policy Area'. The Ipswich Policy Area consists of parts of the areas of Suffolk County Council, Babergh District Council, Mid Suffolk District Council and Suffolk Coastal District Council and the whole of Ipswich Borough's area, and the Ipswich Policy Area Board consists of councillors and is a key vehicle for cross boundary planning. The boundary of the Ipswich Policy Area is mapped at Appendix 3 for information.

(1) 8.69 In planning strategically for housing, employment and infrastructure provision, the Council will need to continue to work closely with neighbouring local authorities to ensure a coordinated approach in line with the Duty to co-operate.


Ipswich Borough Council recognises the importance of joint working and the coordination of planning policies around the fringes of Ipswich, in order to deliver appropriate development. It will achieve this in a variety of ways:

  1. Formal working through the Ipswich Policy Area Board or other relevant forums and developing a jointly agreed strategy;
  2. Joint working on Local Plan evidence gathering, monitoring and updating, to ensure a consistent approach; and
  3. Joint working to develop shared approaches, such as that for strategic green infrastructure and strategic development sites.

The preparation of joint or aligned development plan documents is is to be explored later in the plan period, to ensure a coordinated approach to meeting the objectively assessed housing needs of the Ipswich housing market area and achieving economic growth.

(2) 8.70 The Council recognises the importance of joint working on Ipswich Policy Area matters. At present this is achieved through joint working on evidence base documents to inform development plan documents. In the future, the preparation of joint or aligned development plan documents is to be explored.

8.71 The Borough Council will continue to comment on key strategic planning applications in neighbouring authorities and their respective Local Plan documents. Neighbouring authorities, including parish councils, will have the opportunity to comment at all stages of the production of the Ipswich Local Plan.

8.72 Ipswich Policy Area Board involves councillors and officers from the Borough Council, the neighbouring authorities (Suffolk Coastal, Mid Suffolk and Babergh) and the County Council to focus on and discuss development issues. More details on this are provided within Chapter 10.


8.73 The strategic planning of new homes is a key part of the Local Plan. This section addresses the strategic issues associated with delivering new homes.

8.74 It is divided into the following six policies:


The Amount of New Housing Required


Housing Type and Tenure


Previously Developed Land Target


Ipswich Garden Suburb (formerly Ipswich Northern Fringe)


Gypsy and Traveller Accommodation


Affordable Housing

8.75 These are addressed in turn below:

The Amount of Housing Required

(2) 8.76 The Council had an adopted target to allocate land to accommodate at least 14,000 additional residential dwellings between 2001 and 2021 (at 700 dwellings per annum) and a further 700 dwellings per annum thereafter to 2027. Following updated population and household projection modelling work, the Council has an objectively assessed housing need of 13,550 dwellings at 677 dwellings per annum between 2011 and 2031. However given the capacity constraints of housing land supply in the Borough, there will be a need to engage with neighbouring authorities through the Ipswich Policy Area to meet future population and household needs.

8.77 Since 2001 various developments have been built or received planning permission and 6,903 dwellings were completed between 2001 and 2011. A number of developments continue to have unimplemented planning permissions and some remain under construction. Therefore, the number of dwellings that the Council will need to allocate land for through the Local Plan process is fewer than 13,550 required to 2031. Table 2 below sets out the housing land supply and requirement figures as at April 2014, looking forward to 2031.


Number of dwellings

Discounted Numbers

Cumulative Numbers


Dwellings completed between 2011 and 2014





Dwellings under construction





Dwellings with planning permission





Dwellings with a resolution to grant planning permission (subject to the prior completion of a Section 106 agreement)





Number of dwellings required on new site allocations, in a broad location and on windfall sites to 2031




The discounted numbers in the table allow 10% slippage for planning permissions that may not be implemented.

Line 1: Actual numbers of dwellings built between 1st April 2011 and 31st March 2014.

Line 2: Dwellings under construction at 31st March 2014 - assumed that all will be completed over the plan period.

Line 3: Other dwellings with planning permission at 31st March 2014 - assumed that 10% of these will not be completed.

Line 4: Dwellings with a resolution to grant planning permission from the Council's Planning and Development Committee but which are awaiting completion of a Section 106 Agreement before planning permission is issued, at 31st March 2014 - assumed that 10% of these will not be completed.

Line 5: To reach the local target of 13,550 dwellings by 2031 together with windfall sites, further land will need to be allocated within the Borough, and other locations within the Ipswich Policy Area identified with neighbouring authorities later in the plan period, for at least 10,585 new homes.

8.78 National guidance in the National Planning Policy Framework, is that Local Planning Authorities should set out their policies and strategies for delivering the level of housing provision, including identifying broad locations and specific sites that will enable continuous delivery of housing for at least 15 years from the date of adoption of the relevant development plan document.

(1) 8.79 This should include identifying a specific supply of developable sites for years 1-10 from adoption and, where possible, for years 11-15. Where it is not possible to identify specific sites for years 11-15, broad locations for future growth should be indicated. In the case of Ipswich this will be within the Borough boundary at this stage but future discussions will be required with neighbouring authorities within the Ipswich Policy Area due to capacity constraints. Windfall sites will also contribute to the housing supply and these are defined in the National Planning Policy Framework as sites not specifically identified as available in the Local Plan process and normally comprise previously-developed sites that have unexpectedly become available.


The Council will endeavour to enable housing delivery to meet its objectively assessed housing need throughout the plan period. The Council will allocate land to provide for at least an additional 5,434 dwellings net in the Borough, with a lower amount of 4,734 expected by 2031 to account for a long build out period for the development of the Ipswich Garden Suburb. Sites will be identified through the Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document in accordance with the spatial strategy in this Core Strategy, in addition to the land allocated at the Ipswich Garden Suburb.

The Ipswich Garden Suburb development will contribute significantly to meeting the housing needs of the Borough throughout the plan period.

To meet the remaining requirement of 5,851 dwellings to 2031, the Council will rely on windfall sites and will work with neighbouring local authorities to address housing need later in the plan period.

8.80 Table 2 shows that, as a result of housing completions between 2011 and 2014, 13,004 dwellings remain to be delivered between 2014 and 2031 in order to meet the requirement.

8.81 Sites will be allocated through the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document, having regard to the strategy set out within this document and in CS10. The Council has undertaken an update to the 2010 Strategic Housing Land Availability Assessment (SHLAA) and is satisfied that sites within the Borough are capable of delivering the housing requirement in the ten years to 2024. The SHLAA will be periodically updated.

8.82 The phasing of housing sites will be informed by the findings of the SHLAA, infrastructure delivery and the preparation of master plans. The SHLAA informs the Council's housing trajectory. It is based on recent contact with developers and landowners. It is from this potential supply that site allocations are drawn. Within the tightly drawn boundary of Ipswich, options for the housing land supply are inevitably limited, hence the need to consider future development opportunities beyond the Borough boundaries. Table 3 below provides a breakdown of the housing land supply whilst Table 4 provides a breakdown by delivery period. Delivery will be monitored closely through the Council's Authority Monitoring Report.

8.83 In working with neighbouring authorities to address housing need later in the plan period, consideration will need to be given to avoiding or minimising effects in these areas including environmental designations, landscape, townscape and historic assets. This policy supports plan objective 3.


Area of Ipswich

%age (dwellings) Previously developed land

Total Additional dwellings





Rest of built up area


1,002 (PDL: 702)

Ipswich Garden Suburb (see policy CS10)



Total 2014-2031 (excluding windfall and broad locations)


4,734 (PDL: 1,634)

Small windfall sites (fewer than 10 dwellings) 2015-2031


900 (PDL: 810)

Large windfall sites (10 or more dwellings) 2020-2031


900 (PDL: 810)

Residual need later in plan period



Total 2014-2031


10,585 (PDL: 3,254)


Time period

2001- 2011



Housing Delivery








Housing Type and Tenure

8.84 National policy in the National Planning Policy Framework calls for a variety of housing to be provided in terms of tenure, type and size in order to support the creation of mixed and sustainable communities. This demands an understanding of the existing dwelling stock, and the nature and needs of existing and projected future households. It also requires some understanding of the Ipswich housing market. A Strategic Housing Market Assessment (SHMA) of the Ipswich housing market area was published in November 2008 and provides evidence to support policy preparation on this matter. The SHMA has subsequently been updated with the most recent version published in August 2012.

(1) 8.85 It identifies key housing issues for Ipswich as follows:

  • Ongoing need for significant affordable housing, primarily small homes reflecting decreasing household size;
  • Ipswich's cheapest housing stock for sale is dominated by small, two and three bedroom terraced homes, but this stock is ageing and often in poor repair;
  • Meeting the housing needs of an ageing population;
  • Responding to demographic changes - Ipswich is seeing growth in its student population, and in Black and Minority Ethnic communities;
  • Reconciling a constrained land supply and decreasing household size with a current oversupply of flats and poor perceptions of flats; and
  • Matching the jobs to be created with the housing workers will want and need.

8.86 The affordable housing need is primarily for small homes including smaller family homes, whilst for market housing, provision will need to match aspirations for job creation and improved qualification levels.

8.87 Creating sustainable communities requires the Council to compare the stock with the need for both market housing and affordable housing and the likely profile of household types requiring housing (e.g. do they contain children, are they single person households?).

8.88 The main drivers for change identified in the SHMA are:

  • The growth of employment and housing;
  • Investment aimed at raising qualification and income levels in Ipswich;
  • An ageing population;
  • The growing presence of students; and
  • Fast growing BME groups in Ipswich.


The Council will plan for a mix of dwelling types to be provided, in order to achieve mixed and sustainable communities. All major schemes over 10 dwellings will be expected to provide a mix of dwelling types and sizes in accordance with the Council's Housing Needs Study and Strategic Housing Market Assessment.

Exceptions to this approach will only be considered where:

  1. The site location, characteristics or sustainable design justify a different approach; or
  2. A different approach is demonstrated to better meet housing needs in the area; or
  3. A different approach would expedite the delivery of housing needed to meet targets and is acceptable in other planning terms.

The Council will support Self Build, Custom Build and Co-Housing developments for residential accommodation in appropriate locations, in the interests of supporting high quality homes which meet the identified needs of the Borough.

(1) 8.89 A balance of types of properties is needed across the plan period, rather than a significant majority of one type at one time. The approach set out in this policy will help to ensure a variety of provision.

8.90 The market has a key role to play in this issue. Between 2001 and 2011 housing supply in Ipswich consisted mainly of flats. More recently flats have proved vulnerable to changing market conditions, demonstrating the speed with which the market view can change.

8.91 In the wider Ipswich housing market however, the growth in the provision of flats in central Ipswich has been complemented by housing development elsewhere in the Borough, such as at Ravenswood, and on residential sites outside the Borough but within the Ipswich Policy Area.

8.92 The approach to mix on major sites reflects the fact that larger schemes can best integrate a variety of housing types and can do so whilst still achieving appropriate densities, according to their location.

8.93 This policy links closely with policy CS2, which sets out a locational approach to development density, policy CS7 in setting out the housing requirement, and policy DM30 which covers housing density. Density is inextricably linked with the dwelling types and sizes that a development can incorporate together with the amount of land needed to meet the housing requirement. Central sites should be high-density developments (containing a higher proportion of flats); sites in or close to district centres should be medium-density developments (a mix of flats and houses or town houses); and sites elsewhere should be low-density developments (containing a higher proportion of houses).

8.94 It is important to strike an appropriate balance between providing freedom and flexibility for the housing market to operate and ensuring that a range of sites are available for different areas of the housing market. The exceptions in this policy allow a degree of flexibility in controlled conditions. For example it may be appropriate in certain circumstances for some sites to deliver more market housing in response to viability constraints. Additionally, where the market is failing to provide an appropriate level of affordable housing to meet the identified need, the Council may deliver up to 100% of a site for affordable housing within the context of the wider needs of the community.

(1) 8.95 Self Build or Custom Build is seen to support the individual self-builder, or community group for the delivery of low cost sustainable housing on small scale infill or windfall sites, or as part of large-scale planned development, for example at the Ipswich Garden Suburb, and will help in the delivery of a wide choice of high quality homes.

8.96 The Council will check the mix of housing being provided on large sites through the Authority Monitoring Report.

8.97 This policy supports plan objectives 3 and 4.

Previously Developed Land

8.98 The Government encourages the use of previously developed land known as brownfield land through the National Planning Policy Framework and enables local planning authorities to consider setting locally appropriate targets.


The Council will focus development on previously developed land first while recognising that greenfield land will need to be developed to meet its objectively assessed housing need and forecasted jobs growth. This reflects the locational strategy set out in policy CS2, which focuses development primarily into central Ipswich. It will in turn be reflected in site allocations made in the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document.

(2) 8.99 Between 2011 and 2014 73% of new residential development in Ipswich took place on previously developed land. The Council is proud of its very strong record in this area. However, as previously developed sites become redeveloped and regenerated, it will become more difficult to sustain this proportion of development on previously developed land over the plan period. The twin approach adopted of urban regeneration plus greenfield urban extension ensures that the Council can address its objectively assessed housing need.

8.100 In terms of employment development, between 2001 and 2014, quite a high proportion has taken place on greenfield land, largely because of the role that Ransomes Europark has played in meeting demand. This will decline now as Ransomes Europark nears completion. Of the Borough's employment land supply at April 2014 the majority the supply is on previously developed land, except the remaining land at Ransomes Europark, land north of Whitton Lane and land at Airport Farm Kennels.

8.101 It does not necessarily follow that previously developed land is less biodiverse than greenfield land. For example, in some instances former industrial processes can create conditions suitable for certain communities of plants and animals to flourish that would not normally be found in such a locality. Therefore policy DM31 will apply to all sites.

Ipswich Garden Suburb

(1) 8.102 The Council needs to meet the full, objectively assessed needs for housing in the Borough (National Planning Policy Framework paragraph 47). Specific sites will need to be identified for the first five years of the plan period. For the following ten years, specific sites or broad locations can be indicated.

8.103 Urban regeneration objectives have led the Council to focus development into central Ipswich over recent years. This has supported the successful regeneration of the Waterfront and Ipswich Village, introducing a greater range of uses into each, thereby adding to their diversity and vibrancy. This strategy has seen significant redevelopment of previously developed sites within the town (including 93%of all housing between 2001 and 2014). It has benefited from rationalisation and restructuring in the employment sector away from more land intensive activities such as manufacturing, so that sites such as that on Ranelagh Road (formerly Compair Reavell) have come forward for mixed use redevelopment. However, the manufacturing sector has shrunk significantly and therefore it raises the question as to how far into the future the rationalisation of land uses in the centre of Ipswich will sustain a supply of brownfield sites.

(1) 8.104 The tight urban boundary to Ipswich Borough means that there is only one area of extensive greenfield land still available on the periphery of the town and within the Borough. The land is located on the northern edge of the urban area and is known as the Northern Fringe. Development of the Northern Fringe following garden suburb principles would represent a major urban extension to the town and, therefore, it is a strategic proposal to be planned through the Core Strategy.


Land at the northern fringe of Ipswich, which is referred to as Ipswich Garden Suburb, will form a key component of the supply of housing land in Ipswich during the plan period due to the limited availability of previously developed land.

The site, identified on the policies map, consists of 195ha of land which will be developed as a garden suburb of three neighbourhoods: a Northern neighbourhood (east of Henley Road and north of the railway line), a Southern neighbourhood (west of Westerfield Road and south of the railway line) and an Eastern neighbourhood (east of Westerfield Road). Over the plan period, the site will deliver land uses as set out below:

Land use
Approximate area in hectares
Public open space 40

A Country Park (additional to the public open space above)

24.5 (minimum)

Residential development of approximately 3,500 dwellings


A District Centre providing: 

  1. A maximum of 2,000 sq m net of convenience shopping, to include a medium/large supermarket between 1,000 and 1,700 sq m net;
  2. Up to 1,220 sq m net of comparison shopping;
  3. Up to 1,320 sq m net of services uses including non-retail Use Class A1, plus A2 to A5 uses;
  4. A health centre;
  5. A library;
  6. A police office;
  7. A multi-use community centre; and
  8. Appropriate residential accommodation in the form of upper floor apartments.

Two Local Centres together providing: 

  1. Up to 500 sq m net of convenience retail floorspace 
  2. Up to 600 sq m net of comparison retail floorspace; and 
  3. Up to 500 sq m net of service uses including non-retail Use Class A1, plusClasses A2 to A5.
1.5 including 0.5ha per local centre in the Northern and Eastern neighbourhoods and 0.5ha within the Northern neighbourhood for the country park visitor centre / community centre.
A secondary school within the Eastern neighbourhood 9
Three primary schools 6
Primary road infrastructure, including a road bridge over the railway to link the Northern and Southern neighbourhoods 8.5

The broad distribution of land uses is indicated on the policies map. The detailed strategic and neighbourhood infrastructure requirements for the development and the triggers for their delivery are included in Table 8B in Chapter 10.

Future planning applications for the site shall be supported by an Infrastructure Delivery Plan based on the identified infrastructure requirements set out in Table 8B. The Infrastructure Delivery Plan shall set out in more detail how the proposed development and identified strategic and neighbourhood infrastructure will be sequenced and delivered within the proposed schemes.

A prerequisite for any development being granted planning permission in the Garden Suburb will be the preparation by the Council of a supplementary planning document providing a development brief to:

  1. guide the development of the whole Ipswich Garden Suburb area;
  2. amplify the infrastructure that developments will need to deliver on a comprehensive basis alongside new housing, including community facilities and, at an appropriate stage, the provision of a railway crossing to link potential development phases, in the interests of sustainability and integration;
  3. identify the detailed location of a district and two local centres and other supporting infrastructure; and
  4. provide guidance on the sequencing of housing and infrastructure delivery required for the development

Any development will maintain an appropriate physical separation of Westerfield village from Ipswich and include green walking and cycling links to Westerfield station, and provide the opportunity for the provision of a country park as envisaged by CS16 and is more particularly identified in the SPD.

The land to the west of Tuddenham Road north of the railway line is allocated for the replacement playing fields necessary to enable development of the Ipswich School playing field site as part of the Garden Suburb development.

(1) 8.105 The indicative capacity at the Northern Fringe (Ipswich Garden Suburb) identified in the Strategic Housing Land Availability Assessment: has been reduced to 3,500 dwellings following early capacity work on the Ipswich Garden Suburb supplementary planning document. The Council has identified a need for 13,550 dwellings between 2011 and 2031, and the Garden Suburb forms a key component of meeting this need. The Council will work with Babergh, Mid Suffolk and Suffolk Coastal District Councils to ensure optimum sustainable distribution of housing 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.

(1) 8.106 The policy provides for residential led development at the Ipswich Garden Suburb. The County Council's Structure Plan in 2001 concluded that of all major greenfield sites around the edge of Ipswich, the north Ipswich area was the most appropriate next one to build on. This conclusion was reached following an independent examination of various options.

8.107 In practical terms there are no other areas within the Borough boundary that the Council could realistically identify as having the potential as a location of future growth across the plan period.

(2) 8.108 The infrastructure requirements at the Garden Suburb will be significant and include new roads ecological networks and green corridors, new public transport routes and services, green infrastructure such as allotments and sports facilities, new schools, new recreation provision, healthcare provision and local shopping facilities. This infrastructure can also deliver benefits to the existing communities in the area and help to sustain them. The proper planning and delivery of this infrastructure is most likely to result from a comprehensive approach to development in the area. The detailed infrastructure requirements of the development of approximately 3,500 dwellings at the Garden Suburb and trigger points for the delivery of the items of infrastructure are identified in Table 8B in Chapter 10 of the Core Strategy. Prior to development on the Ipswich School Playing Fields site, replacement sports facilities will be required to be first provided in accordance with policy DM28. The site for replacement playing fields is allocated to the west of Tuddenham Road and north of the railway line.

(2) 8.109 The total number of dwellings likely to be accommodated within the Garden Suburb is approximately 3,500. In order to ensure that any development proposed for this area conforms to a coherent plan, work on the supplementary planning document commenced in early 2012 following the adoption of the Core Strategy in December 2011. Any planning application for the development of the area, which is submitted before the adoption of the Core Strategy Review or the Supplementary Planning Document, will be required to have regard to the content of emerging policy and guidance in policy CS10 and the Supplementary Planning Document respectively. This is to ensure the proper long term planning of the Ipswich Garden Suburb area to deliver sustainable, integrated development. Key conclusions about infrastructure provision at the Garden Suburb from the Secretary of State's dismissal of the appeal by Mersea Homes in September 2010 are reflected in the policy above.

8.110 This policy supports plan objective 3.

Gypsy and Traveller Accommodation

8.111 Ipswich has 43 permanent pitches for Gypsies and Travellers at present, and the future Gypsy and Traveller Accommodation Assessment (GTAA) identifies the Borough needs to 2031. In addition, national guidance requires the Core Strategy to include a criteria based policy to guide the siting and location of sites for Gypsies and Travellers. The accommodation needs of Gypsies and Travellers need to be considered alongside those of the 'settled' population. At the time of writing, the Government is consulting on changes to national guidance for Gypsies and Travellers, including amending the definition of 'traveller' to exclude those now permanently not travelling.

8.112 Work is being undertaken with neighbouring authorities, the County Council and the Gypsy community to identify possible sites to meet the need to provide additional pitches in the Ipswich Policy Area. The policy will provide the context for the ongoing provision of pitches over the plan period.


Provision will be found within the Ipswich Policy Area for additional permanent pitches to meet the need as identified through the Gypsy and Travellers Accommodation Assessment.

Sites for additional Gypsy and Traveller pitches will be assessed against the following criteria.

  1. The site should be located:
    1. where it would be well served by the road network; and
    2. where possible, within 1km of basic services including the public transport network.
  2. The site should be:
    1. accessible safely on foot, by cycle and by vehicle;
    2. large enough to allow business activities to be carried out;
    3. free from flood risk and significant contamination;
    4. safe and free from pollution;
    5. capable of being cost effectively drained and serviced, including with waste disposal and recycling facilities;
    6. proportionate in size to any nearby settlements, to support community cohesion; and
    7. where possible, located on previously developed land.
  3. The site should not have a significant adverse impact on:
    1. the residential amenity of immediate or close neighbours;
    2. the appearance and character of the open countryside;
    3. sites designated to protect their nature conservation, ecological networks, geological or landscape qualities;
    4. historic assets including their setting; and
    5. the physical and social infrastructure of local settlements.

Site identification will be carried out in consultation with the Gypsy and Traveller and settled communities. Site size and design will be in accordance with government guidance.

The Council will work with Suffolk County Council and neighbouring authorities to develop a South Suffolk transit (short stay) site between Ipswich and Felixstowe.

The needs of travelling showpeople will be kept under review. Applications for new sites will be assessed against criteria a. to c. above.

8.113 Sites for Gypsies and Travellers could be privately or publicly provided - the criteria will apply equally to both, as they are about creating safe and healthy living conditions and providing sites within a reasonable distance of basic services such as schooling. Basic services include primary school, secondary school, convenience store, health centre or GP surgery, children's play facility, pharmacy and meeting place.

8.114 Sites will be sought to meet the joint needs of Ipswich and neighbouring authorities for permanent pitches within the Ipswich Policy Area (note that the boundary of the Ipswich Policy Area may change). Need for Ipswich and its neighbouring authorities was identified by the Gypsies and Travellers Accommodation Assessment (GTAA) carried out in 2013 by Opinion Research Services. The 2013 assessment identified a need for 18 pitches in Ipswich Borough to 2027, out of a need for 101 pitches across the five local authority areas included in the assessment (Ipswich, Babergh, Mid-Suffolk, Suffolk Coastal and Waveney). Of the 18 pitches needed, 5 are needed between 2012 and 2017, 6 between 2017 and 2022 and 7 between 2022 and 2027. Projecting this forward to the end of the Plan period, and based on 2.5% per annum compound growth, beyond the timescale considered by the assessment, it is possible that around a further 6 pitches would be needed between 2027 and 2031.

8.115 The Council will work with Suffolk authorities to meet the joint transit (short stay) and permanent needs and the needs of travelling showpeople.

8.116 Just as affordable housing is delivered through the planning system in larger housing developments where there is a local need, so the needs of Gypsies and Travellers should be met in a more systematic manner.

8.117 The Council will work with the Gypsy and Traveller communities to ascertain need in particular locations, prior to the identification or allocation of sites.

8.118 The existing site at West Meadows is a large one containing 41 pitches. Whilst the Council would not limit the size of new sites, anecdotal evidence of preferences in the Gypsy and Traveller community locally is for smaller sites to provide pitches for family groups.

8.119 This policy supports plan objectives 3 and 10.

Affordable Housing

8.120 Affordable housing is defined in the National Planning Policy as 'including social rented [4] , affordable rented [5] and intermediate housing [6] , provided to specified eligible households whose needs are not met by the market'. National policy requires local planning authorities to set an overall target for the amount of affordable housing to be provided.

(1) 8.121 The Ipswich Housing Needs Study 2005 looked at housing needs across the Borough. It has been partly updated through the Strategic Housing Market Assessment (SHMA) in 2008, which has further been updated through a SHMA in 2012. In addition, the Suffolk Housing Survey is due for publication in 2015. The combined findings of the three previous studies indicate that:

  • around 66% of households are owner occupiers, 22% live in the social rented sector and 12% in the private rented sector;
  • one quarter of households consist of older persons only, and such households account for 37% of all Council accommodation;
  • around 12% of the net affordable housing requirement comes from key worker households;
  • when households were asked in 2005, around two thirds of their previous house moves had been within the Borough;
  • Ipswich has lower than average property prices;
  • there is a need for an additional 584 affordable homes per year;
  • the need is most acute for small properties, notably 2 bedroom homes, and is geographically widespread; and
  • 80% of any affordable target should be social rented housing (the affordable rent tenure was introduced in 2011 which has become the default rental provision for Registered Providers).


The Council will seek to ensure that a choice of homes is available to meet identified affordable housing needs in Ipswich. This will be achieved by requiring new development at the Ipswich Garden Suburb to provide for at least 35% on-site affordable housing by total floor space and new developments of 15 dwellings or more (or on sites of 0.5ha or more) in the remainder of the Borough to provide for at least 15% on-site affordable housing by total floor space. At least 80% of affordable housing provision shall consist of affordable rented homes or homes for social rent.

The Council will only consider reducing the requirement for the proportion of affordable housing on a particular development site, or amending the tenure mix to include more intermediate housing, where:

  1. Alternative provision is outlined by the applicant within a site-specific viability assessment (using a recognised toolkit) and the conclusions are accepted by the Council; or
  2. An accepted independent review of development viability finds that alternative provision on viability grounds is justifiable; and
  3. The resultant affordable housing provision would ensure that the proposed development is considered sustainable in social terms through its delivery of housing integration, with particular regard to meeting the identified need for small family dwellings where these can reasonably be integrated into the scheme.

8.122 The independent review process will require the applicant to submit its development appraisal (to include a prediction of all development costs and revenues for mixed use schemes) to a Council-appointed assessor, who will produce an alternative appraisal for comparison by the Council. The independent review shall be carried out entirely at the applicant's expense. Where little or no affordable housing would be considered viable through the appraisal exercise, the Council will balance the findings from this against the need for new developments to provide for affordable housing in the Borough. In negotiating a site-specific provision with the applicant, the Council will have regard to whether or not the development would be considered sustainable in social terms.

8.123 The Council will aim to supplement affordable housing provision from private developments by developing its own sites and providing in excess of 15% affordable housing by total floor space. This will contribute to meeting the policy requirement for affordable housing on sites outside of the Ipswich Garden Suburb to comprise at least 15% of new residential floor space over the Plan period.

(3) 8.124 There is a specific affordable housing target for the Ipswich Garden Suburb based on a number of site characteristics, including higher than average house prices in the immediate locality of the site and its relatively low existing use value. Furthermore, an independent viability appraisal carried out in 2013 indicated that provision near to 35% was achievable on site alongside other development and infrastructure costs at that point in time. However, some flexibility around the provision of affordable housing on site is considered necessary where this would enable the delivery of new infrastructure to support a particular phase of the development. As such, the policy requirement will similarly be subject to site-specific viability considerations.

8.125 The Ipswich 2005 Key Worker Study recognised the need for appropriate housing for key workers, but also found that key workers' wage rates compared well with other pay levels in the local economy. For this reason, we believe that current HomeBuy arrangements meet the needs of key workers locally and we would not wish to encourage development of specific housing for key workers.

8.126 Policy CS17 sets out the approach to delivering infrastructure in the Borough and re-iterates the legislation governing the Community Infrastructure Levy that affordable housing will remain outside the standard charge system. A more detailed affordable housing policy (policy DM24) is set out in Part C.

8.127 The NPPF definition of affordable housing will apply in implementing this policy.

8.128 The policy implements plan objective 3.


8.129 It is equally important that the Council plans for employment issues as well as for new housing. This section addresses the strategic issues for jobs growth within Ipswich and the Ipswich Policy Area to 2031

8.130 It is divided into the following two Policies:

Policy CS13: Planning for Jobs Growth

Policy CS14: Retail Development and Main Town Centre Uses

8.131 These are addressed in turn below.

Planning for Jobs Growth

8.132 The 'wider Ipswich Policy Area' of Ipswich Borough and 19 electoral wards in the neighbouring districts is identified through the Suffolk Growth Strategy 2013 as a principal economic growth location. Whilst the focus of monitoring and meeting delivery targets is generally on residential development at a national level, it is essential that housing growth in Ipswich is supported by employment growth.


The Council will promote sustainable economic growth in the Ipswich Policy Area, with a focus on the delivery of jobs within the Borough. It will encourage the provision of in the region of 12,500 jobs between 2011 and 2031 by:

  1. allocating at least 30ha of land for employment development (in Use Classes B1, B2 and B8) through the Site Allocations and Policies (incorporating IP--One Area Action Plan) development plan document;
  2. protecting land for employment uses in existing employment areas defined on the policies map;
  3. allocating land for other employment- generating uses including education, leisure, tourism and hospitality, and retail , through the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document;
  4. safeguarding approximately 10ha of land at Futura Park, Nacton Road as a strategic employment site, with the principal access taken from Ransomes Way. The site will be safeguarded for B1, B2 and B8 uses;
  5. supporting the growth of University Campus Suffolk and Suffolk New College in order to raise skills and qualifications levels in the workforce; and
  6. taking a lead with local partners to ensure that coordinated action is taken to encourage sustainable economic growth and protect local jobs, and by drawing up a delivery plan with local partners to ensure these aims are implemented.

8.133 Ipswich is a key economic driver of the Ipswich Policy Area within the Suffolk Economy.

(1) 8.134 A joint Employment Land Review was undertaken in 2009 by Ipswich Borough Council, Suffolk Coastal District Council and Babergh District Council through the Haven Gateway Partnership and in conjunction with Suffolk County Council. It recommended that a cross boundary approach be taken within the Ipswich Policy Area to ensure jobs provision. The Council is working in partnership with local authorities on the Suffolk Growth Strategy as agreed in February 2013 and also through the Ipswich Policy Area Board and other joint working forums as they arise to ensure that sustainable economic growth is achieved. This is aligned with the New Anglia Local Enterprise Partnership Strategic Economic Plan and the Greater Ipswich City Deal.

8.135 The Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document will translate the overall land requirement into sites. The Council will ensure that enough land is available, including a variety of site sizes and locations to suit different employment-generating activities. The 10ha of land allocated at Futura Park is additional to the 30ha specified in clause a. of the policy.

8.136 It should be noted that the jobs growth aspiration covers all sectors and not just the employment use classes of B1 business, B2 general industry and B8 warehousing and distribution. The jobs figure is lower than that previously identified to reflect more recent evidence from the East of England Forecasting Model between 2012 and 2014 and covers the period 2011 to 2031.

8.137 In allocating sites for employment development, the Council will take account of the sectors projected to have the highest jobs growth over the plan period as identified in the Suffolk Growth Strategy and those growth sectors identified in the New Anglia Local Enterprise Partnership Plan for Growth. These include:

  • advanced manufacturing and technology;
  • energy;
  • information and communication technology;
  • finance and insurance;
  • food, drink and agriculture;
  • ports and logistics;
  • life sciences, biotechnology and bloodstock;
  • tourism; and
  • creative and cultural industries.

The sectors which are particularly well represented in Ipswich are: information and communication technology, finance and insurance, ports and logistics, tourism and creative and cultural industries.

8.138 The Regional Spatial Strategy required that readily serviceable regionally significant strategic sites were identified within the Haven Gateway to support regeneration at Ipswich including its role in communications technology, and development associated with port expansion at Felixstowe. The Suffolk Growth Strategy identifies these in conjunction with local authority Local Plans.

8.139 The Employment Land Review investigated both demand/need for and the possible supply of strategic employment sites in the Ipswich area. It concluded that there was capacity for a site in Ipswich, in addition to other possible sites within the Ipswich Policy Area. The former Crane's site was allocated through the 2011 Core Strategy as a strategic employment site to function as Phase II of the Ransomes Europark development and help to consolidate an important employment corridor. Now known as Futura Park, approximately 10ha of land is safeguarded for B Class employment uses through this policy. The site's location is indicated on the key diagram. A detailed site boundary is defined on the policies map.

8.140 The site is allocated for B1, B2 and B8 uses under the Use Classes Order. Office uses are directed to the town centre through the approach to the location of development set out in policy CS2. This will further be reflected in site allocations to be made in the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document and is in accordance with the National Planning Policy Framework, which defines offices as a town centre land use. However, B1 office uses may exceptionally be considered acceptable at Futura Park if they are linked to other on-site activities such as research and development that require a large site, or are directly related to the key growth sectors identified and are therefore performing a strategic role. The site could also be suitable for the provision of some starter units to support new businesses.

8.141 The tourism sector, education sector and Ipswich Port are significant sectors in Ipswich. Policies elsewhere in this plan and/or the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document set out the approach to arts, cultural and tourism provision in the town, the Education Quarter and employment areas including the Port. The Council will support University Campus Suffolk by safeguarding the campus for uses needed to deliver the university and college developments.

8.142 The Council will work with partners and the market to aid jobs delivery. Particularly important will be joint work through the Suffolk Growth Strategy and with the New Anglia Local Enterprise Partnership to deliver the infrastructure needed for jobs.

8.143 The Council will also work through other areas of service delivery to support jobs growth, for example through marketing, promotion and investment activity to support employment, where appropriate.

Retail Development and Main Town Centre Uses

8.144 As the county town serving a significant rural hinterland, Ipswich is an important focus for shopping, working, sport, culture, leisure, education and civic life for Ipswich residents and a wider population.

8.145 Within the Ipswich Policy Area the population is forecast to grow over the plan period, which will generate new retail expenditure. However, neighbouring centres such as Colchester and Bury St Edmunds have both enjoyed more recent investment in town centre retailing, and there are other pressures on the centre such as the general economic downturn, nearby out of town retail parks largely outside the Borough, and Internet shopping. Therefore there is no room for complacency in planning to maintain and enhance Ipswich's role as a regional centre.

8.146 Improving the retail offer in Ipswich is an important objective of the Council. It is recognised that this needs to be done in as sustainable a manner as possible having regard to transport issues and the importance of increasing the vitality and viability of the central area and key district centres (see policy CS2).

8.147 For retail policy purposes, Ipswich town centre is the defined Central Shopping Area. The area sits in the historic core of the town to the north of the Waterfront. It has the advantages for the user of being attractive, compact and largely pedestrianised. The area is also a focus for other town centre activities such as the New Wolsey Theatre, the Regent Theatre and the Town Hall and Corn Exchange. The Central Shopping Area is complemented by a growing specialised retail role with food and drink venues in the vicinity of the Waterfront. It is important that the Council manages the physical and functional linkages between the two areas to maintain a positive relationship and ensure that retail development at the Waterfront does not harm the vitality and viability of the town centre.


The Council will promote high quality investment and development in Ipswich Central Shopping Area, to maintain and enhance its attraction and market share, and strengthen its regional role.

Through the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document, the Council intends to extend the Central Shopping Area to include the Westgate quarter and allocate sites for retail development within it. This will enable the delivery in the region of 15,000 sq m net of additional floorspace to diversify and improve the retail offer. Further allocations will be made through a future Site Allocations DPD review following a review of the Retail capacity study to address provision after 2026. Retail development over 200 sq m net in edge of centre or out of centre locations will be considered in light of national policy and the Council's aim to enhance the role, vitality and viability of the Ipswich Central Shopping Area (CSA).

The Council will direct other town centre uses including offices, leisure, arts, culture, tourism and hotel developments into an extended town centre area, with some provision being appropriate in the CSA and Waterfront, in recognition of the area's good accessibility by public transport, cycle and foot.

The Council will also promote environmental enhancements and urban greening to the town centre and improved public transport accessibility.

In the district centres and local centres, the Council will permit retail development of a scale appropriate to their size, function and catchment.

8.148 The policy responds to the findings of the Ipswich Retail Study 2005, as confirmed by the Retail and Commercial Leisure Study 2010, the Ipswich Town Centre Opportunity Areas Report 2013 and Ipswich's role and status as a county town and a regional centre.

(1) 8.149 The Ipswich Retail Study 2005, as confirmed by the Retail and Commercial Leisure Study 2010, identified gaps in the retail offer of Ipswich town centre as follows:

  • significant capacity for new town centre comparison goods (non-food) retailing;
  • a need for a better balance of 'higher end' retailers;
  • limited capacity for additional convenience (food) retailing;
  • a need for an additional department store to anchor the town's retail offer;
  • a need for a more flexible approach to food and drink uses within the primary and secondary shopping areas;
  • a need to boost the evening economy through considering more leisure activity within the centre; and
  • a need for large and modern shop units to satisfy the needs of major retail and leisure operators.

(1) 8.150 An extended Central Shopping Area with additional retail site allocations will go some way to addressing these gaps in the offer, subject to general market conditions. Sites will be allocated through the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document. Clearly delivery will be the key to success, and the Council will work with others and through its own land holdings and as local planning authority to achieve it. In addition the Council will evaluate the practicalities of improving evening access in the principal pedestrianised streets after normal trading hours, to encourage the use of facilities in the evening.

8.151 The Council will work with Ipswich Central, landowners and other partners to develop an active strategy to bring vacant premises in the town centre back into active use or, at a minimum, to introduce a scheme to make vacant premises look more visually attractive.

8.152 An increase in the retail offer of key district centres is likely to be supported provided the retail offer is of a scale relevant to the catchment of that centre rather than the town as whole. Enhancing the facilities available in district centres can help to provide more choice for local residents within walking distance of their homes.

8.153 The Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document will extend the Central Shopping Area boundary from that shown in the 1997 Local Plan and will allocate new sites for additional retail development within it. It will also extend the wider town centre boundary as the focus for other 'town centre' uses such as leisure, offices, cultural uses and hotels (see NPPF for full list of main town centre uses). Enhancing the town centre forms an important part of the strategy for urban renaissance in Ipswich over the plan period.

8.154 Issues associated with the uses permitted within centres are addressed within Part C of this document.

8.155 This policy implements plan objective 5.


8.156 Whilst the previous two areas of 'LIVE' and 'WORK' make up the main components of the Core Strategy along with the 'INFRASTRUCTURE' section, the Council recognises the importance of education to the development of the town. This section therefore addresses the strategic component of this issue. The more detailed elements are left to the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document.

There is only one policy relevant to this topic: policy CS15: Education. This is dealt with below.

Education Provision

8.157 In planning for sustainable growth, it is essential that high quality education provision is available at all levels, in order to offer people the best possible opportunities to fulfil their potential and to enhance qualification and skills levels in the workforce. This includes opportunities for retraining or other lifelong learning. Ipswich fares relatively poorly in levels of educational attainment when compared with county and regional averages. It is a key objective of the Council to improve educational attainment and skills levels and access to such opportunities.


The Council will continue to support the development of educational facilities at Suffolk New College and University Campus Suffolk. Land for the further development of these facilities will be identified and safeguarded for education use through the Site Allocations and Policies (Incorporating IP-One Area Action Plan) development plan document.

The Council supports the upgrading of education facilities and will seek to ensure that community access to school facilities is maximised. Should school facilities become redundant, any application for a non-community use will need to be supported by evidence that the facility and site is no longer needed for community uses.

New primary school provision will be needed to meet the demands of growth. Sites for new or extended primary schools in Ipswich will be identified through the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document.

Any additional nursery and children's centre provision will be encouraged to locate within or adjacent to District and Local Centres or co-located within schools in order to facilitate linked trips by parents. Where land is available, this would also apply to schools. The sustainable location of such facilities so that they are accessible by walking, cycling or public transport will be a requirement.

Education needs associated with development at the Ipswich Garden Suburb are identified, a secondary school site allocated and broad locations for primary schools safeguarded through policy CS10 of this plan and the policies map.

8.158 The developments at Suffolk New College and University Campus Suffolk are vitally important to the future well-being and prosperity of the town. The Council has been fully supportive of these initiatives and it is important that this support continues.

(1) 8.159 It is not considered by the County Council that a new secondary school site is required within the Borough boundary other than at the Ipswich Garden Suburb (see policy CS10).

8.160 The Council is supportive of the principle to substantially upgrade education facilities - and recognises that there is a need for substantial regeneration within existing sites. However, in some cases school facilities are not available for community use out of hours. The Council will therefore press for the community use of facilities where possible.

8.161 At primary level, whilst local issues will be set out within the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document, the specific growth related development pressures and the need to improve facilities are considered to necessitate new or extended primary school provision within the town. These are facilitated within the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document and are included within the list of strategic projects in Part D.

(1) 8.162 At pre-school level the Council recognises the importance of nursery and children's centre provision and the importance of these being located in sustainable locations.

8.163 Measures identified through Travel Ipswich could assist in ensuring sustainable travel to educational establishments and new education development will be expected to encourage sustainable means of transport. This policy supports objectives 5 and 9.


8.164 Cultural facilities, including leisure, play and sporting provision, are important for residents and visitors to the town, as is open space.

8.165 The Government in the National Planning Policy Framework points out how open space, sport and recreation can support many different objectives, including making an important contribution to the health and well-being of communities. There is one key policy under this heading, which is policy CS16.

Green Infrastructure, Sport and Recreation

8.166 Ipswich contains a variety of public and private open spaces, sport and recreation facilities that serve a range of different functions. The strategic spaces, ecological networks, green corridors and facilities contribute fundamentally to the character and appearance of the town, and to quality of life. Examples include: the River Gipping corridor, the importance of which is recognised through the River Strategy; Belstead Brook Park; Orwell Country Park; and the large town parks such as Christchurch Park, Holywells Park, Chantry Park and Bourne Park. There are also smaller local spaces and facilities, which are essential for sustaining communities. The Ipswich Open Space, Sport and Recreation Study 2009 identifies all the different types of open space, sport and recreation facility. Open space provision is generally lowest in the north of the Borough, with an under-provision of parks and gardens in the North West and North East Area Forum areas, amenity green space in the North East area, and natural and semi-natural green space in the North West, Central and North East areas. Other deficits affect more of the Borough, for example there is a significant shortfall in provision for young people across the Borough (such as skateparks, kickabout areas and youth shelters).

8.167 As the Borough grows, it is essential to protect, enhance and extend the network of open spaces, ecological networks, canopy cover, green corridors, and sports and recreation facilities. This is important in order to: allow people access to green space and nature; strengthen ecological networks that enable wildlife to migrate more easily around the town; link inner and outer parts of the Borough by providing walking and cycling routes; provide opportunities for formal and informal recreation; and to enhance the appearance of the town. The potential benefits are many - for example improved biodiversity, health and fitness, flood attenuation and better air quality.

8.168 The National Planning Policy Framework states that local planning authorities should set out a strategic approach in their local plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure. It also requires local authorities to set local standards for open space, sport and recreation facilities, based on a local assessment of needs. It states that existing sites and facilities should not be built on unless they have been shown to be surplus.


The Council will safeguard, protect and enhance biodiversity and the environment by working in partnership with others to ensure that our parks and open spaces are well designed, well managed, safe and freely accessible, encouraging use and benefitting the whole community. The Council will enhance and extend the ecological network and green corridors, open spaces, sport and recreation facilities for the benefit of biodiversity, people and the management of local flood risk. It will do this by:

  1. requiring all developments to contribute to the provision of open space according to the Borough's standards, identified strategic needs and existing deficits in an area;
  2. requiring major new developments to include on-site public open spaces and wildlife habitat. On-site provision must create a network or corridor with existing green infrastructure where such an ecological network or green corridor exists beyond the site boundaries;
  3. supporting proposals or activities that protect, enhance or extend open spaces and sport and recreation facilities;
  4. working with partners to prepare and implement management plans for green spaces, including visitor management plans for key parts of European sites within the Suffolk Coast and Heaths AONB to be completed by 2015, and a plan for Orwell Country Park that will result in a reduced impact upon birds in the Orwell Estuary;
  5. supporting the Greenways Project in working with communities and volunteers to manage green corridors in Ipswich;
  6. support the enhancement of canopy cover and ecological networks;
  7. working with partners to improve green infrastructure provision and link radial ecological networks and green corridors with a publicly accessible green rim around Ipswich;
  8. working with partners to ensure the provision of a new country park and visitor centre within the Ipswich Garden Suburb, and an extension to Orwell Country Park and possible provision of a visitor facility there subject to assessing its impacts on the Special Protection Area;
  9. promoting improved access to existing facilities where appropriate; and
  10. reviewing the town's estate of sports facilities to consider how they can best meet the needs of a growing population.

Policies in this plan and the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document identify existing, new and proposed open spaces, sport and recreation facilities, green corridors and networks and allocate sites for new open spaces and facilities.

8.169 The Council considers that an integrated network of accessible open spaces, sport and recreation facilities is an essential part of the Borough's infrastructure and character. It provides opportunities for formal and informal recreation and sport, for wildlife to flourish and migrate around the area and for sustainable travel around the town on foot or by cycle. It also improves the townscape, helping to break up and soften the urban area. The Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document will identify the sites and networks.

8.170 A development management policy in Section C of this document and Appendix 6 set out the local standards of provision of open spaces, sport and recreation facilities, based on the Ipswich PPG17 Study, which has been updated by the Council's Parks and Open Spaces team. The infrastructure plan in Section D of this document sets out the strategic green infrastructure needs. The Council recognises that it will need to work with neighbouring local authorities to implement this, as realistically parts of any such network will be outside the Borough boundary. Strategic needs were identified by the Haven Gateway Green Infrastructure Strategy and the Council will consider the recommendations in planning future provision. In relation to the proposed 'green rim', the Council will work with neighbouring local authorities to address cross boundary green infrastructure provision and identify sites or routes later in the plan period.

8.171 Open spaces can perform more than one function. An important role for some open spaces will be to act as flood water storage areas or flood paths. Flood risk assessments should where possible and appropriate, identify areas in valley bottoms at risk of flooding as flood management assets and keep them open.

8.172 The Council is investigating the need for sports, cultural and leisure provision in Ipswich. This will include a review of how the Borough's sports halls and school facilities can best meet the need for additional sports provision.

8.173 One of the findings of the Appropriate Assessment of the Core Strategy and Policies plan was that the combined growth in Ipswich Borough and Suffolk Coastal District could harm the Special Protection Area in the Orwell Estuary, and could contribute to harm to European nature conservation sites in the Suffolk Coast and Heaths AONB. Policy CS16, particularly CS16 (d) and CS16 (h) commit the Borough Council to working with others to ensure the necessary mitigation is provided so that harm is avoided.

8.174 This policy links closely to policy CS17 and, as part of the standard charge payable in association with new developments, will relate to the provision of strategic green infrastructure for the town.

8.175 This policy implements plan objective 8.


8.176 For development to take place in an appropriate manner it is essential that proper consideration is given to the infrastructure needs associated with the levels of development proposed. Whilst many infrastructure issues will just relate to individual developments, the Council believes that there are four areas where there is a need for strategic consideration of relevant issues within this document. These are:

Policy CS17: Delivering Infrastructure

Policy CS18: Strategic Flood Defence

Policy CS19: Provision of Health Services

Policy CS20: Key Transport Proposals

Delivering Infrastructure

(3) 8.177 It is critical that Ipswich receives the infrastructure it needs to support the delivery of both housing and jobs growth, and to ensure that existing communities can be sustained. It is important that growth should bring benefits to, and not adversely affect the quality of life of, existing communities. The development at Ravenswood has shown how a new urban community can be developed, such that housing is delivered alongside schools, shops, open space, bus services and other facilities.

8.178 There are a number of ways to ensure infrastructure delivery through the planning system. The existing system in Ipswich is that of: developer obligations secured in Section 106 Agreements, which cover on- and off-site requirements including affordable housing, open space provision, transport measures, and education provision. However, this system has not adequately picked up more strategic infrastructure impacts or needs, and can be accused of lacking transparency for developers when providing for standard off-site infrastructure in particular.

8.179 Therefore the Council is considering whether it shall adopt a standard charge approach to the delivery of infrastructure alongside Section 106 Agreements, which was brought into force by the Community Infrastructure Levy (CIL) Regulations in April 2010. This would permit the Council to pool developer contributions raised through the levy and spend on infrastructure requirements for both the neighbourhood in which the development forms a part and the whole of Ipswich, although in turn would limit the use of Section 106 Agreements. A review of the best way forward with securing infrastructure funding is ongoing.

8.180 Infrastructure can take many different forms. Appendix 5 to this plan lists the types of infrastructure referred to in this policy.


The Council will require all developments to meet the on- and off-site infrastructure requirements needed to support the development and mitigate the impact of the development on the existing community and environment.

Each development will be expected to meet site related infrastructure needs and where the provision of new, or the improvement or extension of existing off- site infrastructure is needed to support a new development or mitigate its impacts, developments will be required to contribute proportionately through a Section 106 Agreement commuted sum or CIL charge.

Section 106 Agreements will apply to all major developments and some minor developments but may be varied according to:

  1. the scale and nature of the development and its demonstrated viability; and
  2. whether or not a planning obligation meets all of the statutory reasons ('tests') for granting planning permission.

The broad categories of infrastructure to be secured or financed from new developments are as follows and detailed further in Appendix 5:

  1. highways and transport;
  2. childcare, early years and education;
  3. health and emergency services;
  4. environment and conservation;
  5. community and cultural facilities including heritage and archaeology;
  6. sport and recreation;
  7. economic development; and
  8. utilities.

Key strategic infrastructure requirements needed to deliver the objectives of the Core Strategy include the following (not in priority order):

  • Ipswich flood defences;
  • sustainable transport measures e.g. the Ipswich Major Scheme 'Travel Ipswich' and accessibility improvements between the Central Shopping Area, Waterfront and railway station;
  • measures to increase east-west capacity in the transport system to ease congestion;
  • strategic education provision of new schools;
  • strategic green infrastructure including a country park;
  • sports and leisure facilities serving the whole Borough;
  • community facilities including GP surgeries and health centres;
  • water management infrastructure;
  • new primary electricity substation in Turret Lane; and
  • town centre environmental enhancements.

There will be specific requirements linked to the Ipswich Garden Suburb that will be identified in the Ipswich Garden Suburb supplementary planning document that has been prepared in advance of any development taking place there.

8.181 Growth requirements across the Borough will place additional pressure on existing infrastructure and will therefore require improvements to be made to existing infrastructure, and the provision of new infrastructure. A number of pressures can be relieved through site-specific provision such as open space, children's play areas and the provision of affordable housing. However, there are other infrastructure improvements and requirements that cannot always be accommodated on-site, or that relate to strategic off-site facilities serving the whole neighbourhood or Borough. It is therefore considered appropriate to pool up to a maximum of five developer contributions towards off-site provision to help ensure its delivery.

(1) 8.182 Responsibility for the delivery of infrastructure will be shared between developers, Ipswich Borough Council and key partners such as the New Anglia Local Enterprise Partnership, utilities companies, Highways Agency, Suffolk County Council, neighbouring local authorities, the Environment Agency, the Homes and Communities Agency, Natural England and local community groups.

Strategic Flood Defence

8.183 Much of central Ipswich lies within the tidal floodplain of the River Orwell. Existing flood defences do not meet modern standards and will be inadequate to resist rising sea levels in the future. Thus many existing communities in the vulnerable areas do not or will not have adequate flood defences, and further regeneration in central Ipswich at the Waterfront and in Ipswich Village depends on the delivery of improved defences.

8.184 The Environment Agency, DEFRA and Ipswich Borough Council have agreed a Strategic Flood Defence Management Plan for Ipswich, which is in the process of being implemented. Its implementation is occurring in three phases:

  1. raising the lock gates at the entrance to the Wet Dock - this was done in December 2008;
  2. raising the river walls on the east and west banks to the south of the Island Site - this commenced in 2009; and
  3. installing a tidal flood barrier in the New Cut at the southern end of the Island Site - due 2017.

The strategy is for the next 100 years and will include repairs to existing tidal and fluvial defences upstream of the barrier. The strategy is being planned to avoid the need to raise the level of these defences.


The Council will continue to work with partners to implement the Ipswich Flood Defence Management Strategy as a key piece of infrastructure needed to support regeneration in Ipswich.

This policy links closely with policy CS17, as the flood defences are a key piece of strategic infrastructure needed to enable the continued growth and regeneration of the town.

8.185 The need for and importance of the Ipswich Flood Defence Strategy is central to the Core Strategy document. This is reflected within the objectives set out in Chapter 6. As such it should be recognised as one of the key pieces of infrastructure for which funding from the standard charges (policy CS17) could be used as matched funding to help secure national flood defence funding.

(1) 8.186 It is recognised that the tidal surge barrier is unlikely to be in place until 2017, but the Council will work with the Environment Agency to ensure it is implemented as soon as possible and that, in the short term, as much preparatory work as possible is undertaken to enable the third phase (installation of the barrier) to be delivered as soon as the funding is secured.

8.187 The Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document will need to have particular regard to the flooding issues and the need to phase some developments to relate to the delivery of the tidal surge barrier. The DPD will identify those sites at risk. The Ipswich Strategic Flood Risk Assessment (SFRA) Level 2 will inform allocations in this area and identify residual risks.

8.188 Part C of this document includes policies relating to flooding to reflect the NPPF and the detailed findings of the Ipswich Strategic Flood Risk Assessment.

8.189 In the interim period it is recognised that the Council needs to work with its partners to put in place better arrangements to cope with emergency planning scenarios associated with flooding.

8.190 The Council is reasonably certain that the funding for the final phase of the flood defences will be forthcoming. It has already obtained Growth Point funding via the Haven Gateway Partnership to contribute to the overall cost of the project, and has secured funding via the Growing Places Fund through the New Anglia Local Enterprise Partnership. The Council has made this project its top priority for the Community Infrastructure Levy.

8.191 If it were not completed at all, then the Council would need to review urgently the spatial strategy and housing delivery in the Borough. It is the Council's belief that, without the barrier, the completion of regeneration at the Ipswich Waterfront and in the part of the town centre near the railway station would not be possible. If the Flood Defence Management Strategy were not completed, the Level 2 SFRA would need to be based on the existing situation with the current defences to ascertain the flood risk to the town.

8.192 This policy implements objective 7.

Provision of Health Services

8.193 It is important for the health and well-being of the Ipswich community that there is adequate provision of health infrastructure, be that GP surgeries, clinics, health centres or hospitals.


The Council supports the bringing together of health sector facilities onto the Heath Road Hospital site.

Proposals for development at Heath Road shall be accompanied by a strategy that includes a satisfactory travel plan and measures to address local car parking issues.

In the case of the St Clement's Hospital site, the Council is satisfied that part of the site is no longer needed for health facilities, subject to related health facilities being acceptably relocated first. A detailed site allocation for alternative use on 11.85ha of the site will be made in the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document.

Proposals to develop additional, new local health facilities such as GP surgeries will be acceptable provided that they are located in or adjacent to the town centre or a district or local centre. Exceptions will only be permitted where the applicant can demonstrate to the Council's satisfaction that the location would be fully accessible by all modes of transport, and would serve the patients or fill a gap in existing provision more effectively than any other better located and realistically available site.

8.194 The Heath Road Hospital is a strategic health facility serving Ipswich and the surrounding area. It is important that any rationalisation of uses there takes place in the context of a planned strategy for healthcare provision which itself takes account of the future growth of Ipswich and the Ipswich Policy Area. Decisions on changes to acute care provision need to be considered in the context of their health impact, in particular the community's ability to access services appropriately and in a timely fashion.

8.195 It is also essential that the travel implications are fully considered and measures put in place to encourage the use of sustainable modes where possible by staff, out-patients, and visitors. In particular, measures should tackle existing parking issues in surrounding residential areas and the Hospital should put in place monitoring to ensure that any measures are proving effective.

8.196 The St Clement's Hospital site consists of a number of buildings and open spaces, including the Victorian hospital building, and grounds to the front and rear. It excludes the St Clement's Golf Course. The Strategic Housing Land Availability Assessment update identifies this as a site that would be appropriate (in part at least) for a housing allocation for approximately 227 homes following discussions with the landowner's representatives. Accordingly, the reallocation of the site for these purposes will be dealt with through the Site Allocations and Policies: (incorporating IP-One Area Action Plan) development plan document.

8.197 Where other healthcare sites become available for re-use, the Council will wish to be satisfied that they are not needed for other community uses before considering non-community uses. This is because it is difficult to find sites for such uses and once they are lost they are extremely difficult to replace.

8.198 With a growing population in Ipswich, several of the GP practices are currently looking to relocate, merge, expand or even all three. This process of adaptation could continue over the plan period. Allocations that include healthcare facilities will be made in the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document to deal with known needs now. For needs that emerge later in the plan period, the Council will seek to direct such uses to the town centre and district and local centres as these are the most accessible locations. Such locations are likely to result in less potential disturbance than in an entirely residential area and the centres could benefit from linked trips.

8.199 This policy supports plan objectives 9 and 10.

Key Transport Proposals

(1) 8.200 A key objective of the Council is to improve the pedestrian and cycle accessibility between key nodes in the central area, two of which are the Central Shopping Area and the Waterfront. It is recognised that better pedestrian crossings and other measures could improve the linkages between the shopping area and the Waterfront, and a number of such crossings are already planned.

8.201 Public transport is an important part of the current and future transport packages and therefore the Council continues to support the Travel Ipswich scheme. More details on these proposals will be included in the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document. The Council will look to close the Waterfront Northern Quays route to general traffic but retain limited access, e.g. for public transport and appropriate operational use by Waterfront businesses. The reduction in cars using the route along the Northern Quays will help to enhance the area as a pedestrian environment and a visitor attraction.

8.202 The Felixstowe to Nuneaton rail line is part of the Trans-European Network and there are long‑standing proposals to upgrade this route - particularly to enable greater rail based freight movements from Felixstowe Port.


The Council supports the Travel Ipswich scheme, which aims to reduce dependency on the private car by 15% within the lifetime of the Plan. This will improve bus station provision, passenger information, shuttle bus provision and pedestrian links between the Central Shopping Area, the railway station and Waterfront.

The Council also supports the completion of the upgrading of the Felixstowe to Nuneaton rail line.

In the short term the Council will look to close the Waterfront Northern Quays route to general traffic, maintaining access only for pick up/drop off and the shuttle bus.

8.203 The Local Transport Plan (LTP) is a programme of transport works prepared by the Highway Authority. It is used to set out a strategic overview of transportation needs, and an implementation plan. The current LTP covers the period 2011 to 2031.

8.204 The Council supports the thrust of current national and local policy on transport which is on travel demand management.

(3) 8.205 There are concerns about highway capacity in the town centre, particularly within the Star Lane area. These capacity implications are closely linked to issues associated with the wider transport network - including the A14 and the Orwell Bridge. There are, in addition, four Air Quality Management Areas (AQMAs) within the central area of Ipswich, as a result of pollutants from road traffic. Air Quality Management Areas are designated in areas where poor air quality may have an effect on people's health. Other areas of poor air quality have been identified in the central area and consideration is currently being given to revising the extent of the AQMAs.

8.206 The Council and partners commissioned a study to advise on the Gyratory, which reported in 2007 (the Ipswich Waterfront Study). The consultants advised that the two lanes of traffic should be reduced to one in both an easterly and westerly direction.

(1) 8.207 In the longer term, and to assist with addressing issues in the Star Lane gyratory, the Council also supports the provision of significant alternative east-west transport capacity. To this end, it will, where it can be justified, continue to make a case for a package of measures including a Wet Dock Crossing and traffic management schemes to be included within each version of the Local Transport Plan, in order to:

  1. enable improvements to pedestrian and cycle routes between the Waterfront and the historic core of the town by subsequently reducing capacity on the Star Lane gyratory;
  2. enable the development of the Island Site for which access improvements, but not necessarily a Wet Dock Crossing, would be a prerequisite;
  3. enable the linking of high quality walking and cycling routes around the entire Waterfront area; and
  4. provide an alternative route for east-west movements which, along with appropriate traffic management schemes, would help to relieve congestion and air quality issues in the Gyratory, which in turn will support the town's economy and health.

8.208 Detailed proposals, including those for the Star Lane gyratory, are included in the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document.

(1) 8.209 The delivery of a Wet Dock crossing (i.e. a new road linking Holywells Road/Duke Street with Hawes Street) is a long term prospect and it is as yet uncertain. It is recognised that it would only be likely to happen if the Island site comes forward for redevelopment. Potential funding sources include:

  • LTP funding;
  • Growth funding;
  • developer contributions; and
  • part funding from any Island Site development.

8.210 The Island site in the Wet Dock is a key site in relation to the Waterfront regeneration. However, access to the Island is limited and therefore some form of additional access would be needed to bring the site forward for redevelopment.

8.211 At a minimum, a road bridge from the west bank to the Island site and a pedestrian and cycle bridge across the Wet Dock lock gates to the east bank will be required to enable any significant development on the Island.

8.212 In any event, the Council would resist any significant reduction of road capacity on the gyratory without the prior provision of either some alternative capacity (e.g. the Wet Dock Crossing) or significant and successful travel demand management measures.

(8) 8.213 This alternative capacity could also be provided via a northern bypass or a link road to the north of the town. The Council will actively encourage key partners to investigate the possibility of a northern bypass, to address the issue of:

  1. central east-west movement;
  2. movements within and around the north of Ipswich; and
  3. the capacity of the A14, particularly around the Orwell Bridge.

The Council will work with neighbouring authorities and Suffolk County Council to ensure that the merits and delivery options for some form of northern bypass are fully investigated. It is recognised that any such route would be within the Suffolk Coastal District Council and Mid Suffolk District Council areas (i.e. not between the Ipswich Garden Suburb - policy CS10 - and Westerfield village) and therefore it is not practical to include such a route within this Strategy. However, the Council will encourage those authorities, together with Suffolk County Council and other interested parties, to actively investigate such a route, and would be prepared to contribute to any such investigation.

(1) 8.214 A further issue is that of access by heavy vehicles to Ipswich Port, which is essential for its ongoing viability. At present vehicles often approach from the A14 via Nacton Road and Landseer Road and this causes disturbance problems for local residents living along the roads. In the First Deposit Draft Local Plan in 2001, the Council proposed a new link road from the port to a new junction with the A14. This attracted significant objection. The Council considers that this East Bank Link Road is unlikely to be deliverable over the plan period because public funding is not available and the Highways Agency is opposed to additional junctions on the A14. Therefore the Council does not propose to allocate a New East Bank Link Road within the Plan.

8.215 This policy supports objective 6 of the plan.

[3] For example those policies relating to sites protected under the Birds and Habitats Directives (NPPF paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Local Green Space; and Area of Outstanding Natural Beauty; designated heritage assets and locations at risk of flooding or coastal erosion.

[2] Examples include By Design, CABE Building for Life

[3] Ipswich Borough Council Drainage and Flood Defence policy (May 2002, updated August 2009)

[4] Rented housing owned and managed by local authorities and private registered providers for which guideline target rents are determined through the national rent regime, or by other persons and provided under equivalent rental arrangements as agreed with the local authority or with the Homes and Communities Agency

[5] Rented housing let by local authorities or private registered providers of social housing to households who are eligible for social rented housing. Affordable Rent is subject to rent controls that require a rent of no more than 80% of the local market rent (including service charges, where applicable).

[6] Homes for sale and rent provided at a cost above social rent but below market levels and which meet certain criteria. It can include shared equity products, other low cost homes for sale and intermediate rent, but not affordable rented housing.

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