Proposed Submission Core Strategy and Policies Development Plan Document Review

CHAPTER 9: Development Management Policies

9.1 This chapter sets out borough wide development management policies. Site specific policies are set out in the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document.

9.2 In setting out the development management policies below, the Council has been particularly mindful of the following three factors:

• the clear government guidance that development management policies should not just repeat what is already contained within national policy (and in some cases legislation) - i.e. policies should be distinctive to Ipswich;
• the policies set out within the Ipswich Local Plan 1997; and
• the comments received during the previous round of consultation.

SUSTAINABLE DEVELOPMENT

9.3 This policy gives effect to a key strategic policy theme of the Local Plan. It sets out the method by which the Local Planning Authority will support the achievement of the progressively increased standards of sustainability (including reduced carbon footprint and water use) for new development required by national planning and energy policy, through the granting of planning permission.

9.4 The East of England is particularly vulnerable to the effects of climate change, which, considered in combination with the high level of planned development here with its potential contribution to emissions and water use, means that adapting and addressing climate change is a particularly urgent and challenging issue for the region.

9.5 The National Planning Policy Framework sets out how local planning can best support the achievement of sustainable development. Specifically it requires that local planning authorities plan with a presumption in favour of sustainable development. The aim of local planning authorities should be to adopt proactive strategies to mitigate and adapt to climate change and a move towards a low carbon future. When setting local requirements for a building's sustainability, local authorities should do so in a way consistent with the Government's zero carbon buildings policy and adopt nationally prescribed standards. The Government has further reiterated its commitment to reducing carbon emissions from new development, and that all new homes will be required to be zero carbon from 2016 through its current Housing Standards Review ^[9] and also proposes requiring non-residential developments to be zero carbon from 2019.

9.6 A zero carbon home, as currently defined through the zero carbon buildings programme, is one where there are no carbon emissions resulting from the regulated energy requirements of the home (i.e. heating, lighting, hot water and fixed appliances but not plug-in appliances). It is proposed that this can be achieved through fabric energy efficiency measures, on-site or off-site renewable or low carbon energy generation or through financial contributions to carbon abatement measures established as part of the 'allowable solutions' programme. It is intended that as part of this mix, all new homes must meet energy efficiency standards equivalent to at least Level 4 of the Code for Sustainable Homes, which will be regulated through amendments to the Building Regulations ^[10] . These proposed amendments to the Building Regulations equate to reductions in carbon emissions of around 20% above current (2014) requirements.

9.7 The Code for Sustainable Homes (CfSH) sets out nine categories against which a home can be rated. Energy efficiency and water efficiency categories have their own minimum standards that must be achieved at every level of the CfSH, recognising their importance to the sustainability of any home. Other categories include better management of surface water run-off, waste management (including construction waste and encouraging household recycling), pollution and management of the home, all of which contribute to the sustainable performance of homes.

9.8 The Council considers the CfSH to be a particularly appropriate tool to assess sustainability of new residential developments in that it is a nationally accredited system that considers a wide range of sustainability criteria in addition to energy and CO2 emissions, and in particular water use. Similar benefits apply to the use of the BREEAM system of assessment for multi-residential uses (e.g. care homes, sheltered housing, student accommodation) and for non-residential uses.

9.9 Through the Housing Standards Review, referred to above, in addition to securing delivery of the zero carbon homes programme, the Government also intends to replace all elements of the Code for Sustainable Homes with updated Building Regulations and powers for planning authorities to require more stringent 'optional' requirements through planning policies where these can be justified on the basis of need. The optional requirements are proposed to cover the accessibility (for example for the elderly and disabled) and water efficiency. The Government is also proposing a nationally described space standard through the Housing Standards Review (as referred to alongside policy DM30).

9.10 Whilst it is clear that much of the drive for carbon reduction in new homes and non-domestic buildings will be handled under the Building Regulations, the Council nevertheless considers it appropriate to have a planning policy requiring new development to achieve sustainability improvements beyond the requirements of Building Regulations both to support the carbon reduction agenda and to ensure the achievement of a more holistic approach to sustainable development through the achievement of the much wider range of environmental and social benefits that these schemes provide for.

9.11 The policy provides for some flexibility in exceptional circumstances where it can be clearly demonstrated that achieving the required rating for the type and scale of development in question would either be not feasible or not viable in the light of such considerations as site constraints, other planning requirements, other development costs, and the prevailing market conditions at the time. In such circumstances the Council may agree to a lower CfSH or BREEAM rating being achieved having regard to other merits of the scheme in terms of sustainability and urban design. Development will still need to meet the requirements of the Building Regulations in force at the time.

9.12 This is considered to be a relatively simple policy approach that prescribes clear targets based on recognised national codes, without being unduly prescriptive as to how the targets should be achieved.

9.13 The policy will be implemented through a requirement for the submission of Design Stage Assessments and Post Construction Reviews, carried out by a qualified CfSH or BREEAM assessor (as appropriate), for all planning applications for qualifying development. It will be expected that planning applications also be accompanied by a sustainability statement that explains and illustrates how sustainability considerations have influenced scheme design.

9.14 Where appropriate, mitigation measures shall be secured by condition to ensure that any pollution through air, noise, dust or vibration during the construction phase of development will not be detrimental to the amenity of neighbouring uses. Relevant policy guidance in respect of neighbouring amenity can be found in DM26.

9.15 This policy gives effect to Core Strategy policy CS1, which sets a target for achieving renewable or low carbon energy sources in major development. It builds on national policy in the National Planning Policy Framework with the aim being of contributing to the Government's zero carbon economy.

9.16 Given the acknowledged vulnerability of the region to the effects of climate change and the projected levels of development Ipswich will be required to accommodate, the Council considers it reasonable to require new developments above the given threshold to provide a minimum of 15% of energy demand from renewable or low carbon sources, to help achieve national targets of zero carbon homes by 2016 (public sector buildings by 2018 and non-residential buildings by 2019). ^[11]

9.17 The policy is worded to permit a reasonable degree of flexibility to developers as to how the requirement may be met. In this regard, energy from either renewable or low-carbon technologies and from sources that are either on- site or off-site in the locality of the proposed development, could be considered acceptable. The design of such developments should allow for the export of electricity back to the grid (i.e. 'feed in').

9.18 The policy also provides for some flexibility where it can be clearly demonstrated that achieving the required percentage provision of renewable or low-carbon energy would not be either technically feasible or financially viable in the light of such considerations as site constraints, other planning requirements, development costs, and the prevailing market conditions at the time. In such circumstances the Council may agree to a lower percentage provision being achieved where the introduction of additional energy efficiency measures (i.e. additional to those required under the relevant Code for Sustainable Homes or BREEAM requirements as set out in policy DM1 such as passive house design or other inbuilt energy efficiency measures) to achieve an equivalent reduction in carbon emissions.

9.19 The Council considers that, in addition to the provision of well-planned public spaces, the provision of high quality private outdoor amenity space for all types of new residential development must be considered to be an essential component of high quality design, and key to the creation of a sustainable residential environment both in terms of its contribution to liveability and to urban greening and the preservation and/or enhancement of local biodiversity and ecological networks.

9.20 Such space is needed for sitting out, socialising, play, drying washing, and gardening (flowers and food).

(2) 9.21 Garden sizes need to be sufficient to accommodate most household activities and at the same time be adequate to offer visual delight, receive some sunshine, and encourage plant growth. The BRE report "Site Layout for Daylight and Sunlight" recommends that no more than two fifths and preferably no more than a quarter of the garden should be prevented by buildings, walls or fences from receiving sunshine on 21 March. Garden sizes need to be calculated independently of any parking space(s) to be provided.

9.22 It is considered that a suitably designed 75 sq.m rear garden should be capable of achieving the above requirements for a three-bedroom or larger house.

9.23 It is accepted that smaller properties, less likely to be occupied by families with children, may reasonably function with a smaller rear garden of at least 50 sq. m. It should be noted that for both sizes of dwellings, gardens may need to exceed the minimum size specified in the policy where they need to accommodate soakaways.

9.24 Key characteristics of well designed private amenity space will normally be required, and these are: (i) a well shaped (rectangular), useable area having good accessibility and a well planned relationship to the internal living spaces within the dwelling; (ii) provision for a private sitting out area not overlooked by any window of a neighbouring property either at ground or first floor; (iii) high standards of security and privacy; (iv) a reasonable outlook; and (v) access to direct sunlight for part of the space for at least part of the day. The Council's Development Control Policies and Design Guidelines, which address matters such as spacing between dwellings, will apply, until the adoption of a Space and Design Guidelines supplementary planning document. The garden standards set out in the policy will equally apply to existing gardens remaining after garden severance.

9.25 The Council considers that in the case of low-rise housing development conventional rear gardens remain the best option for private amenity space. For apartment schemes and other forms of higher density development an imaginative combination of gardens (private and communal), terraces, roof- gardens, and balconies should be considered. In addition to functional benefits, well designed and fully integrated outside space can enhance the architectural quality and interest of a scheme.

9.26 Apartment schemes may typically choose to provide a combination of communal gardens for use by all residents together with private balcony spaces or terraces for use by individual households. All balconies should be well designed, positioned where they are convenient and comfortable to use, and large enough to accommodate a table and four chairs to suit the occupancy of the flat as well as some additional space for plants (a minimum size of 5 sq. m is a useful guide in this regard).

9.27 Poorly designed areas of grass to the rear of blocks of flats will no longer be an acceptable way of providing communal gardens. These spaces are rarely private and are often overshadowed by tall buildings. Private communal gardens therefore need to be:

• of sufficient size to be useable;
• secure and private;
• well-designed and integral to the character of the development; and
• providing a combination of sun and shade, particularly during the summer months of the year.

FLOODING AND SUSTAINABLE DRAINAGE

9.28 It is recognised that the need to reduce flood risk in Ipswich is essential to ensure accordance with guidelines set out in national government policy on development and flood risk, the National Planning Policy Framework. This includes planning for the effects of increasing rainfall intensities and sea levels. As a result of the Pitt Review and the Flood and Water Management Act 2010, much more emphasis will be placed on planning for flooding in future than previously.

(1) 9.29The Council will apply the NPPF hierarchy for managing flood risk i.e.:

TABLE 7

HIERARCHY	EXPLANATION
1. Assess	Strategic Flood Risk Assessment (SFRA) and site-specific Flood Risk Assessment (FRA).
2. Avoid	Layout should be designed so that the most vulnerable uses are restricted to higher ground at lower risk of flooding, with more flood-compatible development (parking, open space etc.) in the highest risk areas. Use Sustainable Drainage Systems (SuDS) at source.
3. Substitute	Apply the sequential approach to locate more vulnerable development in lowest risk areas.
4. Control	Use SuDS and implement Surface Water Management Plans (SWMP) to manage and reduce risk.

9.30 Flood risk management should be considered in all developments before site layouts are planned. It is necessary to locate development away from a risk of flooding and sequentially preferable sites will be those in Flood Zone 1 suitable for the development proposed, with planning permission and/or allocated for residential development in planning policy, and which are genuinely available. Highly vulnerable, more vulnerable and less vulnerable development will not be permitted in Flood Zone 3b (functional flood plain). Highly vulnerable development will not be permitted in Flood Zone 3a. Flood Zones 2 and 3 are shown on Plan 2.

9.31 The Ipswich Level 2 SFRA provides the necessary information to help facilitate the sequential approach as outlined in the NPPF. Site-specific Flood Risk Assessments (FRAs) are required for all development in Flood Zones 2 and 3, and for all sites over 1ha in size. The SFRA also provides additional guidance and information for locations where site-specific Flood Risk Assessments (FRAs) will be required as part of the development process. This includes certain sites in Flood Zone 1, which may be less than 1 ha. The SFRA also considers the effects of development on local flooding and minor watercourses and identifies mitigation measures including SuDS.

9.32 SuDS are an important method of reducing flood risk associated with development and are an essential element of any development in the Borough wherever practicable. Layout and form of buildings and roads must be designed around SuDS bearing in mind SuDS should be sited in lower areas, but preferably close to source, making use of topography.

9.33 The SFRA also identifies key surface water flood paths and watercourses (flow routes) and areas at risk of flooding. These are to be safeguarded for the future by protecting them from development and other obstruction. Development proposals should design for key flow routes. Surface water management plans will be able to facilitate this.

9.34 Site-specific FRAs may therefore be required to consider such issues, most likely aiming to identify the extent of the flow route, water levels and frequency so that appropriate site layouts and floor levels can be planned. In the future SWMP and the SFRA may provide much of this information.

9.35 SuDS standards and policies are currently set out in the Council's Drainage and Flood Defence Policy as referred to in the Development and Flood Risk SPD. In the future it is expected that National Standards will be followed.

9.36 The Council's Level 2 SFRA provides information relevant to both the existing tidal/fluvial defences at 2011 and also to the completed defences, with the proposed barrier in place. In each case the SFRA provides data on residual risks taking account of flood depth and the velocity of floodwater. The preparation of many site-specific FRAs can make use of mapped risks from the new SFRA. However in some instances, site-specific FRAs will still need to include detailed flood modelling to ascertain the flood risk.

9.37 FRAs for proposals in Zones 2 and 3 need to clearly state the frequency of flooding in and around the site and, until the EA's flood defence barrier is implemented, will need to assume existing defences are in place. Alternatively a FRA could be presented assuming the barrier is in place, however any planning permission would be conditioned to prevent construction until the final stage of the barrier is under construction.

9.38 More vulnerable and less vulnerable development sited in Flood Zones 2 and 3a, as defined in the NPPF, may be acceptable. However FRAs will be required to demonstrate that such developments will be 'safe' in accordance with the Development and Flood Risk SPD and consider flood risk from other sources. The assessment will follow the NPPF and its supporting technical guidance note. Planning permission will not be granted if submitted details do not comply with the Safety Framework. In addition, permissions should not be granted if emergency responders are concerned about their capabilities/plans.

9.39 Basements or lowered ground levels around buildings will increase flood risk to people contrary to the aims of the NPPF. Basements are particularly vulnerable to all types of flooding. Basement dwellings will not be permitted where the floor level is below 0.1% AEP tide level in 100 years time. Basement dwellings will not be permitted in 'Areas Susceptible to Surface Water flooding'. Basements in Flood Zone 1 will only be permitted subject to adequate FRAs, which must address groundwater, sewer and overland flood sources.

9.40 FRAs will be required for any land raising including impacts on Surface Water flood risk. No raising of ground levels should be permitted around the Wet Dock that would impede Surface Water flood paths from Bridge Street, Key Street, Fore Street and Coprolite Street to the Wet Dock.

URBAN DESIGN POLICIES

9.41 The Council believes that good urban design matters, in creating good architecture as a legacy for the future and attractive and distinctive public spaces that create a sense of place, encourage cultural and leisure activities, and foster a healthier lifestyle. Urban design adds value for the town both visually and functionally, but more importantly, it benefits people by making Ipswich more liveable and attractive to visitors.

9.42 National planning policy is clear that all new development should achieve high standards of design and environmental sustainability. Given high projected levels of growth in Ipswich over the plan period and the distinctiveness and quality of the central area of town where much of this growth is to be directed, design quality is considered to be a particularly important requirement for all new development in the town.

9.43 In an era of rapid social, economic, environmental and technological change, buildings need to be designed to be adaptable to respond in a sustainable manner to the changing needs of occupiers. This is the 'long-life, loose- fit' principle. It could be achieved using the lifetime homes principle to ensure that homes can meet families' changing needs over time. For commercial buildings, it could mean ensuring that a building designed as an office for one organisation is physically capable of being subdivided, should future patterns of demand change.

9.44 The public realm is defined as the parts of a town that are available without charge for everyone to experience and enjoy. It includes both formal and informal spaces such as streets, squares, parks and open spaces, the urban fringe and footpaths linking to nearby countryside. An attractive and well-functioning public realm that is friendly to all users is key to creating the sort of environment that people want to be in. It is also important in prioritising the needs of pedestrians and cyclists over those of the car in terms of safety and air quality for a healthier lifestyle. Specific proposals for new and improved areas of public realm in central Ipswich will be identified through the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document.

9.45 Integrating land uses into mixed use developments and neighbourhoods improves the overall sustainability of Ipswich and also reinforces community cohesion. It helps to create local vitality and reduce the need to travel. In areas such as the Waterfront, Ipswich has seen the benefit of a mixed use approach that combines living, leisure and culture, and working.

9.46 Community safety is fundamental to people's quality of life. This is not just about designing-out crime, although it is important, but about planning developments and neighbourhoods in ways that encourage neighbourliness, nurture healthy communities and assist social inclusion. Designing into schemes safety measures such as lighting and in some cases CCTV can support actual and perceived safety, however lighting must be carefully designed to maximise energy efficiency and avoid 'leakage' into the night sky and nuisance to nearby occupiers. It is expected that consideration should be given to the principles set out by Secured by Design wherever appropriate.

9.47 Greening the streets of Ipswich has visual, functional, social, economic and environmental benefits. In terms of climate change, street and car park trees help by providing shade from the sun, slowing surface water run-off, and combating the urban heat island effect. Trees also contribute to health, welfare and quality of life of everyone who lives and works in the urban environmental along with being an additional habitat for wildlife. Where underground services and hard surfacing are a potential issue, the use of root barriers and below ground engineered tree pits to provide viable soil volumes, and Tree Root Protection Systems will be explored. The appearance of streets will also be improved through a Tree Planting Design Guide and limiting the amount of 'street clutter', including unnecessary signage, bollards, railings, road markings and street furniture.

9.48 The wooded skyline that provides the backdrop to much of central Ipswich is a key part of the centre's character and setting and will be protected and sustainably enhanced. The Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document and the Ipswich Urban Character Study supplementary planning document will identify key viewpoints and key strategic views in relation to the wooded skyline around central Ipswich. Relevant policy guidance in respect of tall buildings can be found in policy DM6.

9.49 The character and distinctiveness of Ipswich is the product of a combination of Ipswich's geographical setting, history and communities. It is fundamental to the local identity and is described in Chapter 5. The character of different areas of Ipswich is analysed through the conservation area character appraisals (covering the conservation areas only) and the Ipswich Urban Character supplementary planning document (the first stage of the SPD covers Norwich Road, Parks, the Orwell and Gipping Valley, and California).

9.50 In order to support Ipswich residents in adopting sustainable lifestyles, the Council will ensure that the layout of new developments makes adequate provision for travel by cycle, their safe storage, and provision for the recycling of waste materials.

9.51 Assessment of design quality for major applications for residential development will be made using the Building for Life 12 criteria (CABE at the Design Council / Design for Homes / HBF) and applicants will be expected to demonstrate that scheme designs can achieve a 'green' score in each category enabling schemes to be eligible for 'Building for Life Diamond' status. However it is recognised that not every development proposal will meet this criteria and in these circumstances developers will be expected to justify why this is not possible. The Building for Life criteria are reflected in policy DM5 and therefore addressing the specific requirements of Building for Life will contribute towards meeting the requirements of policy DM5. The Council also encourages new housing to be built to the Lifetime Homes standard, which makes it easier for people to remain in their own homes as their mobility needs change, through encouraging homes to be built in a way in which rooms can be used flexibly over time. The criteria in policy DM5 also contribute towards the creation of safe, functional and well-designed communities as aspired to by the Government's Lifetime Neighbourhoods ambitions.

9.52 The design quality of smaller residential developments will be assessed against the various Building for Life criteria as may be considered reasonably applicable to the type and scale of development under consideration. The Council's Development Control Policies and Design Guidelines, which address matters such as spacing between dwellings, will apply to all residential developments, until replaced by the Space and Design Guidelines supplementary planning document.

9.53 The design of all major non-residential or mixed-use developments will be assessed against the design criteria set out in By Design: DETR 2000.

9.54 Applicants for planning permission will be required to clearly demonstrate how the submitted development proposal achieves urban design quality through the design and access statement accompanying their application, addressing the relevant criteria as appropriate.

9.55 It will be necessary to ensure that the siting, layout, scale, form, massing, materials and detailing of any proposed buildings will have a positive visual relationship with surrounding buildings. Matters of silhouette, proportion, and solid to void ratios, will all be important considerations to be addressed.

9.56 It is important that the design of development creates buildings that work well for their occupiers. This includes the provision of adequate storage in new developments, be that for wheelie bins, cycles, or for the storage of mobility scooters. Provision for waste storage should support the aim to increase recycling. It may also mean designing for an ageing population to reflect demographic trends. In order to promote sustainable use of materials encouragement will be given to the reuse of previously used materials in construction.

9.57 Urban greening is important, to enhance the townscape, tackle and help adapt for climate change and enhance biodiversity. It could include the incorporation of canopy cover, green walls and green roofs and the creation of urban greenspace, as part of soft landscaping considerations. Opportunities for greening should be maximised in all developments, where appropriate. Provision to support biodiversity should include measures such as bird boxes, bat boxes and swift bricks, where possible incorporated into the fabric of the building. The Council will also refer to its Open Space and Biodiversity Policy.

9.58 Ipswich has four Air Quality Management Areas where it is important to ensure that new development does not compound existing air quality problems for example by blocking the movement of air. Criterion h in policy DM5 will equally apply to development proposed in areas that are known to be of poor air quality but where an Air Quality Management Area has not been designated due to there not currently being any receptors.

9.59 Public art can play a critical part in the development and regeneration of places by making the architecture and/or the setting or public space around them more attractive, and establishing a sense of place and local identity. It also has intrinsic cultural and aesthetic value.

9.60 The placing of public artworks on development sites is a material consideration in the planning system. The Council encourages all major developments to integrate public art installations or bespoke features as part of the overall design concept from the outset. Applications should incorporate information on the content and quality of any public art into the accompanying Design and Access Statement.

9.61 Tall buildings can only be considered appropriate in certain limited locations in Ipswich and various special considerations, over and above standard urban design considerations, should apply to their planning and design, particularly in listed building and conservation area terms.

9.62 Tall buildings may be defined as 'buildings which are substantially taller than their neighbours and / or which significantly change the skyline'. The definition is taken from 'Guidance on Tall Buildings' EH /CABE 2007, to which proposals should have regard.

9.63 Detailed guidance and planning submission requirements for proposed schemes are set out in detail in the above mentioned document and will be used by the Council in the assessment of any such proposals.

9.64 The boundaries of the arc of land to which this policy applies will be identified in the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document. Central Ipswich is circled by a wooded skyline, which is particularly important to the setting of the central area including Ipswich Village and the Waterfront. Developments will only be permitted where they do not seriously disrupt this setting, especially when viewed from key viewpoints. Strategic views in and across central Ipswich have been identified through the Ipswich Urban Character Study supplementary planning document and in Conservation Area Statements and Management Plans.

9.65 The impact of any proposed tall building on listed buildings will be assessed under the provisions of Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990.

9.66 Buildings listed for their special architectural or historic interest have statutory protection under the Planning (Listed Buildings and Conservation Areas) Act 1990. The Council has a statutory duty to preserve and enhance the character and appearance of listed buildings in Ipswich and will therefore only grant planning permission and listed building consent for works and changes of use which complement this obligation.

9.67 A change of use of a listed building may affect its character and appearance and involve alterations to the fabric to meet either the functional or statutory requirements for the proposed use. The Council will be unable to grant permission for a proposed change of use of a listed building where sufficient details have not been submitted.

9.68 The National Planning Policy Framework (NPPF) states that consent will not be granted for the demolition of a listed building other than in exceptional circumstances, and not unless the Council is satisfied that every possible effort has been made to continue the present use, or find a suitable new use. Demolition will not be permitted until there are approved detailed plans for redevelopment that would immediately follow the clearance of the site.

9.69 The Council is keen to protect and enhance the town's 14 designated conservation areas which are shown on Plan 3. The character appraisals and management plans for each area highlight what is distinctive about the area including building styles, street patterns, land form, historical development and key views. Future character appraisals will include landscape and tree assessments. Proposals for development will need to indicate precisely how each scheme will preserve and enhance the conservation area in which it is located by a thorough appreciation of these distinctive characteristics.

9.70 Proposals for development in Conservation Areas should indicate precisely how each scheme will preserve and enhance the conservation area in which it is located. A development proposal lying outside the boundary of a conservation area yet clearly affecting its character and appearance will be considered as if it formed part of the designated conservation area.

9.71 National advice and policy on the conservation of the historic environment is set out in the NPPF and the Planning (Listed Buildings and Conservation Areas) Act 1990. The NPPF supersedes Planning Policy Statement 5 (Planning for the Historic Environment) although the Practice Guide to PPS5 remains in place as guidance. The general approach to managing heritage assets will also follow the guidance set out in BS7913 ^[12] .

9.72 The NPPF establishes a presumption in favour of sustainable development and states that great weight should be given to the conservation of designated heritage assets such as conservation areas. Where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, planning permission should not be given unless substantial public benefits can be identified that outweigh that harm or loss.

(1) 9.73 The NPPF sets out specific requirements for assets with archaeological interest. Where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, developers will be required to submit an appropriate desk based assessment and, where necessary, a field evaluation. Scheduled Monuments are designated by the Secretary of State and the records held by English Heritage who develop policies to protect them. Suffolk County Council Archaeology Service holds the Historic Environment Record for Ipswich and is consulted on planning applications that could affect archaeology.

9.74 Attention is drawn to the policies maps, which show the Area of Archaeological Importance of the Anglo-Saxon and Medieval town, aspects of which are internationally recognised. Beyond this area, the Borough includes parts of the wider landscape of the Gipping Valley and Orwell Estuary, and there are Prehistoric, Roman, Anglo-Saxon and other period archaeological sites within its boundaries. The County Council strongly encourages applicants to contact the archaeological service well in advance of seeking planning permission, in order that assessment and recording requirements can be discussed. This helps make the application process simpler and reduces the risk of heritage assets presenting an obstacle to delivery at a later stage. For information, the Area of Archaeological Importance is also shown on Plan 4.

9.75 The Council acknowledges the townscape importance of buildings of local interest which have no other statutory protection, and encourages their retention and upkeep. In situations where the benefits of a replacement development outweigh the retention of an existing building on the local list, the Council will expect a high standard of design.

9.76 The Local List (Buildings of Townscape Interest) supplementary planning document was published in September 2013 updating the previous list and identifying buildings of particular local interest.

9.77 Whether viewed individually or collectively from a distance trees make an important contribution to the environmental quality of Ipswich. They contribute to the townscape, biodiversity and air quality.

9.78 Established trees are a scarce resource and will be protected by Tree Preservation Orders when under threat. The Council will also impose planning conditions where appropriate to secure replanting schemes under circumstances where felling of trees is unavoidable.

9.79 Tree planting on development sites should not be an afterthought. BS5837: 2012 provides guidance in respect of development sites, on tree retention, protection during development and incorporating trees into design of the development. The level of detail expected with a planning application should be appropriate to the scale of the proposal.

9.80 Trees are important elements of green infrastructure, contributing to urban cooling through evapotranspiration and providing micro-climatic effects that can reduce energy demands in buildings. They therefore represent a key resource that can significantly contribute to climate change adaptation. Tree planting should help shape the built environment and new development in a way that strengthens the positive character and diversity of the area and increase climate change resilience. Climate change has a direct and indirect effect on trees in a number of ways including higher temperatures, and greater fluctuations in rainfall and wind. Climate change needs to be considered as part of a process to ensure the tree-scape continues to flourish and retains its unique qualities of landscape, botanical and bio-diverse richness.

9.81 Community woodlands offer valuable opportunities for improving the environment around Ipswich by upgrading the landscape and providing for recreation and wildlife. Any new development will need to take account of any community woodland plan in place at the time of a planning application.

9.82 Where the Council permits the removal of trees, replacement planting will be on a two for one basis. This may not always be possible or appropriate on the development site in question, and in such cases off-site provision will be expected as an alternative. Applicants are advised to liaise with the Council's Arboricultural Officer at the earliest opportunity to discuss appropriate replacement species and locations. All replacement tree planting proposals will need to be accompanied by a tree care and management plan for the new trees.

9.83 The Council deals with trees through its function as landowner and local authority in line with its Tree Management Policy, unless the need for, and benefits of the development in that location clearly outweigh the loss. The 1997 Hedgerow Regulations protect 'important hedgerows', as defined through Schedule 1 of the Regulations, from being removed.

POLICY DM11:
Central Ipswich Skyline

This policy has been deleted

SMALL SCALE RESIDENTIAL DEVELOPMENT

EXTENSIONS AND ANCILLARY BUILDINGS

9.84 The vast majority of planning applications the Council receives relate to proposals for residential extensions or for small infill or backland residential developments.

9.85 Extensions to houses are often a convenient way of providing additional living space for growing households. Extensions often benefit from 'permitted development' rights, which enable households to extend their property without the need for planning permission, so it will often be the larger and potentially more problematic extensions that are the subject of consideration by the Council under the following policy.

9.86 Extensions and ancillary buildings must be well designed and must be appropriate given the particular context of the property in question. Detailed guidance is given in the form of the Council's supplementary planning guidance 'Good practice guide to extending your home' and in particular care should be taken to ensure that two storey side extensions to semi-detached or detached houses do not close the gaps between houses and create a 'terracing effect'. Such extensions would normally have to be set back behind the main front wall of the house by 4 metres. Such development should also maintain the possibility of external access to rear gardens. A new Space and Design Guidelines supplementary planning document will supersede this guidance document.

9.87 Any increase in carbon emissions resulting from an extension should where practicable be offset through improvements to the existing building(s). Extensions are likely to lead to an increase in the overall energy footprint of a dwelling through additional space heating, lighting and appliances. Therefore any such increase should be offset through retrospective improvements to the original dwelling, such as extra loft insulation. This will help to achieve carbon reduction targets.

9.88 The Council has seen a rise in the number of applications for residential annexes in recent years. Development which assists households to adapt to changing circumstances should be encouraged so long as it forms a linked extension to an existing dwellinghouse and retains some shared facilities (e.g. kitchen or bathroom), to ensure that it cannot evolve into a self-contained unit. To qualify as an annex the accommodation should have a degree of dependency on the main dwelling house to ensure a single planning unit is retained and a separate residential dwelling is not created. Annexes will not be approved for private rental purposes as this would involve the creation of a separate planning unit.

SMALL SCALE INFILL AND BACKLAND RESIDENTIAL DEVELOPMENTS

9.89 Severance of rear and side gardens, infilling between existing development and development of backland sites often provide opportunities for the provision of additional homes. However, care should be taken to ensure that such development is appropriate, well designed and well related to its surroundings. The following policy will therefore apply.

9.90 The tight Borough boundary around Ipswich means that small sites, such as backland plots behind existing dwellings, have historically been an important source of additional dwellings for the town. However, given the nature of such sites often close to existing housing, new development needs to be carefully controlled in order to protect the character and amenity of the neighbourhood and the quality of life of its inhabitants.

9.91 In the case of severance plots, it is important that the original dwelling(s) shall retain sufficient garden space to meet the Council's minimum standards. The Council's Development Control Policies and Design Guidelines, which address matters such as spacing between dwellings, will also apply, until superseded by the Space and Design Guidelines supplementary planning document.

THE SUBDIVISION OF FAMILY DWELLINGS

9.92 In recent years there has been significant pressure, particularly in central locations, to convert existing houses into flats, bedsits and houses in multiple occupation. Furthermore it is possible that this pressure may increase further as a result of the growth of University Campus Suffolk and Suffolk New College.

9.93 It is also important to note that not all shared accommodation will trigger the need for planning permission. However, where planning permission is required it is considered important to ensure that such development takes place in an appropriate form and location. In particular it is considered important to have regard to amenity and also to prevent the conversion of small and modest sized family housing.

9.94 Proposals for flats, bedsits and houses in multiple occupation are often controversial and can have significant impact upon the amenity of an area. The growth of University Campus Suffolk and Suffolk New College and the likely increase in demand for flats, bedsits and houses in multiple occupation provide a further justification for a policy specific to Ipswich in order to ensure that conversions are appropriate. The Council requires applicants to consider the amenity of residents in adjacent dwellings, and within the building itself. The latter will be assisted through careful internal layout, which for example avoids positioning living rooms next to bedrooms in adjacent dwellings and within the building itself.

9.95 Overload will be assessed in relation to each application on the basis of the existing proportion of houses in multiple occupation in the area. Generally, no more than 30% of the dwellings in the area would be expected to be houses in multiple occupation.

TRANSPORT AND ACCESS

9.96 The Council is keen to ensure that new developments have an acceptable impact on and relationship to existing transport infrastructure. Therefore the above will be important considerations in determining planning applications. The Council will need to be satisfied that impacts can be managed in a satisfactory way and that suitable additional infrastructure provision is made where necessary.

9.97 Ipswich is a regional transport node and a compact town and therefore it should be possible to access the town centre and other parts of the town by sustainable means. In accordance with the Ipswich Transport Strategy 2007 and the Suffolk Local Transport Plan 2011-2031, the Council is keen to ensure that a modal shift away from the car can occur within the Borough. This policy should also be considered alongside the growth aims of the Strategy, principally policy CS2.

9.98 New development should have an acceptable impact on and relationship to existing transport infrastructure, therefore the above will be important considerations in determining planning applications. The Council will need to be satisfied that the impacts can be managed in a satisfactory way and that suitable additional infrastructure provision is made where necessary. Where relevant, development should take opportunities for providing new infrastructure through well-designed cycle and pedestrian routes and high quality cycle storage with workplace shower and locker facilities. It should also link with public transport facilities and services and seek to improve existing rights of way to reduce journey times to employment, schools and services.

9.99 A Rights of Way Improvement Plan forms part of the Suffolk County Council Local Transport Plan 2011-2031, where improvements to the access network focuses on the needs of non-motorised users. This Council also expects development on sites which abut or relate closely to the town's rivers to provide for the improvement of public access alongside these.

9.100 Necessary mitigating measures to improve public transport infrastructure and services may be secured where this would reasonably relate to a development, whilst the introduction of car club schemes in larger developments may also contribute to reducing levels of private car ownership in the town (the need for car club provision in new developments will generally be informed by the agreed findings of a Travel Plan). The inclusion of electric charging points in residential plots, employment developments and commercial car parks are also considered a sustainable measure that can help to reduce greenhouse gas emissions in line with the aims of the National Planning Policy Framework. The provision of charging points for electric vehicles within new developments should be made in accordance with the Suffolk Guidance for Parking (November 2014).

(1) 9.101 In proposals for the development of 10 or more dwellings, 1,000 sq. m or more of non-residential floorspace or where more than 50 people would be employed, the Council will require a Transport Assessment to be undertaken to include an assessment of the likely impact on the local highway network. A long term management strategy (Travel Plan) to increase sustainable patterns of travel to a site will also be secured in some instances.

9.102 Where a development is likely to have an impact on an Air Quality Management Area or other sensitive area, an assessment of the air quality impacts of the development will be needed with appropriate mitigation measures proposed as necessary. Confirmation on the level and extent of transport and highways reports that would be required to support development proposals can be found within the Council's Validation Checklist.

PARKING

9.103 An explicit requirement to set maximum parking standards is no longer part of national planning policy. This previous approach has led to parking on verges and on street in a number of recent developments, to the detriment of the street scene and highway safety.

9.104 Local planning authorities are now free to apply parking standards that are appropriate and necessary to address local circumstances. In Ipswich, the standards within the Suffolk Guidance for Parking (November 2014) are currently being applied.

9.105 Whilst the emphasis of transport policy remains firmly on encouraging people to switch to more sustainable modes where possible, it is also recognised that many people still own cars. Therefore, adequate levels of residential parking should be provided that uses land efficiently and is designed in from the outset to ensure that cars do not dominate the street scene.

9.106 There are a number of publications which look at the design of car parking in more detail, notably 'Car Parking: What Works Where' (English Partnerships, 2006) and 'Manual for Streets' (Department for Transport, 2007). Underground parking is also an efficient way to accommodate the car and should be considered where this is acceptable in flood risk terms as demonstrated through a Flood Risk Assessment.

9.107 In order to reduce congestion, manage air quality and encourage a modal shift away from the car, particularly amongst the commuting public, it is important to limit long-stay car parking within the central car parking core and for organisations to encourage employees to travel to work by more sustainable means through travel planning. Therefore, only necessary operational parking will be allowed for new non-residential development within the central car parking core. This excludes staff parking but would include access which is considered essential.

9.108 Safe, convenient and secure cycle parking is essential to encouraging increased cycle use in Ipswich. The emphasis on provision for both residential and commercial development relates to more strategic measures being taken across the town to improve cycle routes, through the Local Transport Plan and the Ipswich Cycling Strategy.

PROPOSALS IN RETAIL AREAS

9.109 Protecting the vitality and viability of the town centre and district and local centres is a key part of national policy and the importance of the town's shops is set out in the strategic policies of the Core Strategy. The NPPF advises that town centre policies should:

• Define the extent of centres and primary shopping areas;
• Define primary and secondary frontages within designated centres;
• Retain and enhance existing markets;
• Allocate a range of suitable sites to meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community and residential development needed; and
• Allocate appropriate edge of centre sites for main town centre uses that are well connected to the town centre, where suitable and viable town centre sites are not available.

9.110 The purpose of the Central Shopping Area (CSA) is to focus retail activity within a defined, concentrated area and enable visitors to easily combine other activities in the centre with their shopping trip, such as meeting friends at a caf�, going to the bank or having a haircut. The concentration of activities benefits shoppers who wish to compare goods and prices in different shops before making their purchases or combine several activities in one trip, and retailers who want to see the maximum footfall possible outside their store. The policy approach of concentrating such activity within a defined area supports the vitality and viability of the centre.

9.111 The CSA boundary has been amended, to include additional land at Westgate to accommodate a retail allocation and exclude land east of Cox Lane. These changes respond to evidence in the Ipswich Town Centre Opportunity Areas Report 2013. The Council considers that the boundary changes will help to strengthen the CSA's vitality and viability. Annual monitoring of town centre indicators such as shop vacancy will continue to be used to assess the CSA's health.

9.112 Within the CSA, the predominant land use at ground floor level should be shops (i.e. Use Class A1 retailing). However, there are other uses which complement A1 shops, which also have a role to play within the CSA, for example: financial and professional services such as banks (class A2), cafes and restaurants (class A3), drinking establishments (class A4) hot food takeaways (class A5) and main town centre uses including leisure, entertainment, offices, arts, culture and tourism and residential uses.

9.113 The CSA is therefore divided into three 'Shopping Areas'. The Primary Shopping Area is the area where the greatest concentration of A1 retail uses is expected. It is a relatively small area which largely coincides with the 'prime pitch' for retailers and it has the highest rents and footfall. The Secondary Shopping Areas are generally characterised by lower rents and footfall than the Primary Shopping Area. In these areas, the focus remains on A1 retailing, but a greater diversity of uses is permitted. The Speciality Shopping Areas contain the greatest diversity of uses. Shops tend to be in smaller units occupied by more specialist retailers. Some of the streets in this area consist of attractive historic buildings, which give them a special character, for example St Peters Street and Fore Street. For the purposes of the sequential approach to locating new retail development, only the primary and secondary shopping areas defined on the IP-One Area inset policies map would be considered 'in town centre' sites. The streets within the CSA are broken down into 'shopping frontages' by the Council. The frontages usually consist of a continuous line of buildings fronting the street or pavement, segregated by intersecting streets. Individual frontages will continue to be set out in the supplementary planning guidance: 'Central Shopping Area - Identified Frontages' document, which is monitored and updated annually.

9.114 The approach to land use within the CSA is to maintain a balance between A1 retail and other A-class and main town centre uses, through the control of frontages. The proportion of frontages permitted for non-A1 uses, as set out in the adopted Core Strategy 2011, has been the subject of review. An assessment of the existing percentage of groups of frontages in non-A1 uses in the CSA has influenced the policy percentages. In the Primary Shopping Area, the percentage of non-A1 uses permissible within frontages has been increased from 10% to 15%. This is based on monitoring of the current frontage uses and recognition of the need to provide an attractive range of uses to enable high street retailing to compete with out of centre and Internet shopping. The Council's Town Centre Master Plan identifies the need to permit more food and drink uses in the Central Shopping Area to disperse these activities and public spaces throughout the centre.

9.115 In the Secondary and Specialist Shopping Areas, the previous percentages have been retained in this plan but the policy now also refers to other main town centre uses being supported, in recognition of the need for centres to offer a range of attractions in order to maintain vitality and viability.

9.116 Protecting the visual character of listed buildings in the Central Shopping Area is covered elsewhere.

9.117 Mixed-use development will be supported in the Central Shopping Area only where a ground floor use in accordance with policy DM20 is provided. This reflects government policy to encourage diversification and mixed uses, and can help to create a vibrant centre including outside shopping hours. Main town centre uses as defined in the NPPF will only be permitted within the Central Shopping Area where specified criteria are met as set out in policy DM20.

9.118 Under a change to the Permitted Development Order that came into force on 30th May 2013, changes from a use falling within Classes A1 (shops), A2 (financial and professional services), A3 (restaurants and cafes), A4 (drinking establishments), Class A5 (hot food takeaways), B1 business), D1 (non-residential institutions) and D2 (assembly and leisure) to another use within that same group of uses became, for a temporary period of up to two years, Permitted Development. Such changes are subject to Prior Notification of the local planning authority and exclude changes to floor areas in excess of 150 square metres and listed buildings. Monitoring indicates that there have been few such changes of use to date within the CSA.

9.119 The Council will seek funding opportunities to make environmental enhancements to the public realm of the centre and help it to remain competitive and attractive to users. The priority for improvements during the plan period will be the Cornhill, Tavern Street and Westgate Street.

9.120 District and Local Centres perform an important role serving, to varying degrees, the day-to-day convenience, food and services needs of their local resident catchment populations. Ipswich contains 11 existing District Centres and 34 Local Centres (with additional centres of both types proposed through the Core Strategy).

9.121 The District Centres are the more strongly performing centres and rely on a stronger convenience retail offer to underpin their function, vitality and viability. All the District Centres contain a supermarket. The District Centres also tend to be located on radial routes and benefit from some passing trade.

9.122 The Local Centres tend to contain fewer units that the District Centres and offer a more limited diversity of uses. However, they remain an important facility for meeting people's every day needs.

9.123 The approach to District and Local Centres is to strengthen their role and function and seek to retain shops and community facilities. Within the District and Local Centres, a balance between A1 retail (shops) and non-A1 uses (such as food and drink establishments) will be maintained. A2 to A5 uses and sui generis uses appropriate to a centre will also be supported, provided the overall percentage of the frontage does not exceed the levels specified in the policy. District centres are listed under policy CS2. The local centres are listed below.

• Fircroft Road (1)
• Garrick Way (2)
• Dale Hall Lane/Dales Road(4)
• Ulster Avenue (5)
• Norwich Road (197-307a) (6)
• Dickens Road (8)
• Cambridge Drive (10)
• Maidenhall Green (12)
• Ellenbrook Green (14)
• Colchester Road (61-65) (15)
• Brunswick Road (16)
• Cauldwell Hall Road/Spring Road (19)
• Cauldwell Hall Road/St John's Road (20)
• Foxhall Road (25-97, 34-124) (21)
• Bixley Road/Foxhall Road (22)
• Selkirk Road (24)
• Clapgate Lane (207-221)/Landseer Road (325-327a) (25)
• Reynolds Road (26)
• Queen's Way (29)
• Felixstowe Road (474-486) (30)
• Penshurst Road (31)
• Cliff Lane (32)
• St Helen's Street (33)
• Bramford Lane (34)
• Bramford Road (35)
• Spring Road (36)
• Albion Hill, Woodbridge Road (291-386) (37)
• Lavender Hill (38)
• Prince of Wales Drive (39)
• Bramford Road (560 and 651-677) (40)
• Bramford Lane (483-487) (42)
• St Matthew's Street (44)
• Grimwade Street (45)
• Woodbridge Road (28-110) (46)

9.124 The policy will help focus community development in the Local and District Centres. The community facilities are defined in Appendix 4.

9.125 Zonal maps for each District Centre to support community facilities within 400m straight-line distance are defined on Plan 1. Local Centres are also defined on Plan 1.

9.126 As an indication of appropriate scale the Council expects additional food stores in District and Local Centres should not exceed 1,500 sq. m. net. This is to ensure the development is of a scale appropriate to serve the centre and not the town as a whole, which could in effect divert retail away from the town centre. The applicant should also demonstrate that it can meet the requirements as set out in the NPPF, which covers the following points:

1. that the development is of an appropriate scale;
2. that there are no more central sites for the development;
3. that there are no unacceptable impacts on existing centres; and
4. that locations are accessible.

9.127 The approach is to maintain a balance between retail and non-retail uses, through the control of frontages. An analysis of the existing frontages in a sample of the District and Local Centres supports the increase in the thresholds of A2 to A5 uses to 40%.

9.128 The introduction of use class categories A4 and A5 (drinking establishments and hot food takeaways previously use class A3) has been reflected in the policy. This will assist in controlling the night-time economy. A proportion of 20% has been set, which is higher than the threshold set for the Central Shopping Area, but appropriate, as the District and Local Centres serve residential communities.

9.129 The policy allows change of use to take place from retail to proposals for community uses where certain criteria apply. Residential uses will be encouraged on upper floors in the centres and in the vicinity of the centres to maximise access to shops and facilities.

9.130 The boundaries of the District Centres are shown on the policies map and, within them, policy DM21 applies to development proposals.

9.131 The National Planning Policy Framework (NPPF) defines a town centre as an area defined on the policies map, which includes the primary shopping area and areas predominantly occupied by main town centre uses within or adjacent to the primary shopping area. The main town centre uses are defined in the following paragraph. In the Ipswich Local Plan, the primary shopping area is called the Central Shopping Area (see policy DM20).

9.132 This policy reflects the NPPF, which identifies the main uses appropriate to a town centre as: retail (including warehouse clubs and factory outlet centres); leisure (such as dance halls), entertainment facilities, intensive sports and recreation facilities such as cinemas, restaurants, bars, night clubs, casinos, health and fitness centres, indoor bowling centres and bingo halls; offices; and arts, culture and tourism including theatres, museums, galleries, concert halls, hotels and conference facilities. In addition, living is encouraged within town centres, to improve vitality and viability outside business hours and enable sustainable lifestyles.

9.133 The non-retail main town centre uses which are managed through this policy are predominantly focused away from the Central Shopping Area, with the exception of a small element permitted in the Secondary and Specialist Shopping Areas or as part of certain mixed use developments as described in policy DM20, in order to maintain A1 retail use as the predominant use in the Central Shopping Area. For the development of non-retail town centre uses outside the Town Centre, the NPPF shall apply.

9.134 The town centre boundary is defined through the IP-One Area inset policies map. It overlaps to a degree with Ipswich Waterfront and Ipswich Village.

9.135 Within the 1997 adopted Local Plan, the Ipswich town centre boundary was drawn tightly around the very centre of Ipswich, broadly within the ring formed by St Matthews St/Crown Street, Grimwade Street, Star Lane, Franciscan Way and Civic Drive. However few sites remain within that area which could accommodate new office or leisure development.

9.136 The Borough has an ambitious job creation target set in policy CS13. As retail is the primary use within the Central Shopping Area, the town centre area beyond the Central Shopping Area is the key location for many of the other uses listed above, in particular large scale leisure uses and offices.

9.137 Therefore, there is a need to extend the town centre boundary and identify the area at the centre of Ipswich where the Council wishes to concentrate development of non-retail main town centre uses. It is also vital to ensure that the town centre remains the most accessible part of the Borough, because concentrating a variety of work and leisure opportunities in the town centre can make a major contribution to ensuring social inclusion in the Borough through opportunities being accessible to everybody.

9.138 The criteria for identifying the town centre boundary are therefore a predominance of main town centre uses within it, areas adjacent to the Central Shopping Area containing sites allocated for main town centre uses, and sites with good accessibility (within 800m of a main transport interchange).

9.139 Defined Centres in Ipswich consist of the Central Shopping Area, District Centres and Local Centres. The town centre is not a defined centre for the purposes of this policy.

9.140 Out of town retail parks, sole retail warehouses and large foodstores (such as supermarket and superstores) are not defined as centres and therefore policy DM23 should apply to proposals within these locations. Retail warehouses are large stores specialising in the sale of household goods (such as carpets, furniture and electrical goods), DIY items and other ranges of bulky goods, generally selling goods that would require transportation by car.

9.141 Listed below are items which the Council considers to be bulky goods:

• domestic household electrical;
• audio-visual equipment (including radio, TV, Hi-Fi, and computer goods);
• furniture, lighting, carpets and floor covering;
• hardware and DIY goods;
• garden centre goods and garden furniture;
• builders merchants;
• automotive products and accessories together with associated fitting;
• caravans boats and boat equipment;
• cycles, cycle products and accessories;
• camping equipment;
• pets and pet supplies;
• furnishing fabrics and curtains; and
• blinds and poles.

9.142 Items such as clothing, footwear and food are not considered to be bulky goods.

9.143 The National Planning Practice Guidance states that conditions may be attached to appropriately control the impact of retail uses. Conditions may therefore be attached, including the following:

• to prevent developments from being sub-divided into a number of smaller shops or units;
• to ensure that ancillary elements remain ancillary to the main development, by allowing up to 10% or 200 sq. m of net floorspace (whichever is the smaller) to be devoted to ancillary and incidental goods taken together;
• to limit any internal alterations to increase the amount of gross floor space by specifying the maximum retail floor space permitted; and
• to limit the range of goods sold, and control the mix of convenience and comparison goods.

9.144 This policy applies to retail proposals which are defined as those uses falling within Use Classes A1 (Shops), A2 (Financial and Professional Services) and A5 (Hot Food Takeaways) only. Use Classes A3 (Restaurants and Cafes) and A4 (Drinking Establishments) are classified as leisure within the NPPF definition of main town centre uses and therefore this policy does not apply to these uses. It is important to distinguish between these use classes as it affects the application of the sequential test, as set out in the NPPF.

9.145 Policy DM23 applies to proposals which give rise to more than 200 sq.m net floorspace, either from a single unit or the aggregation of units within the proposed development.

9.146 The Retail and Commercial Leisure Study 2010, indicates that there is no need or justification for further major out-of-town retailing in Ipswich.

9.147 The sequential approach to the consideration of retail proposals will be applied as follows:

• firstly, to consider whether there are sites available in the Primary Shopping Area, comprising Primary and Secondary Shopping Frontages, and in the District and Local Centres only where the scale of the proposed development is appropriate to the catchment areas the centres serve;
• secondly, to consider sites in edge of centre locations as defined in the NPPF; and
• thirdly, to consider sites in out of centre locations.

AFFORDABLE HOUSING

9.148 The type and mix of affordable dwellings required across the Borough will be as set out in policy CS12 and the most up-to-date Affordable Housing Position Statement. The requirement to avoid clusters of more than 12 to 15 affordable units is a general guide, with the main objective to achieve developments in which the affordable dwellings are truly integrated into the overall scheme. However, this can be exceeded where there is a demonstrable need for management purposes or where a scheme delivering over-and-above the policy requirement set within policy CS12 is proposed.

EMPLOYMENT LAND

9.149 The established Employment Areas across the Borough represent very significant clusters of employers providing jobs and, therefore, need to be safeguarded. The jobs growth target set out in policy CS13 means that protecting against the loss of employment areas is important. The list in this policy contains the town's main existing and proposed employment areas.

9.150 Existing employment areas have been reviewed and boundaries amended where appropriate. Several employment areas formerly identified through the 1997 Local Plan have been deleted, because the uses have changed, e.g. former area 'T' Celestion/Bull Motors Foxhall Road, or the Ipswich Local Plan sets out a strategy involving alternative uses e.g. Felixstowe Road employment area where housing and community uses are preferred.

9.151 New employment areas have been designated at Ipswich Business Park north of Whitton Lane (area 1 above) and Airport Farm Kennels south of Ravenswood (area 16 above). These reflect proposed employment land allocations set out in policy SP5 of the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document, which are needed to provide an adequate employment land supply in terms of quantity and quality.

9.152 The distribution of employment areas across the Borough means that they are accessible to all the main residential neighbourhoods, providing the possibility of job opportunities close to where people live. Protecting the employment areas for employment uses also retains choice of locations across the Borough for businesses to locate in. As consolidated employment areas, operational requirements such as 24 hour working or heavy goods access are also more likely to be capable of being met without adversely affecting the amenity of residential areas.

9.153 Ipswich Port plays a significant role in the Ipswich economy, handling over 3 million tonnes of cargo a year. The extended West Bank handles primarily unitised cargo whereas the East Bank caters for bulk cargoes. Ports have been identified by the New Anglia Local Enterprise Partnership as one of the key sectors which will drive the growth of the region in coming years. The Suffolk Growth Strategy 2013 also identifies that UK container traffic is likely to grow steadily over the next 15 years, as will opportunities arising through diversifying bulk-breaking and post-processing capabilities.

9.154 Within Ipswich Port a number of consents exist under the Planning (Hazardous Substances) Act 1990 and the Dangerous Substances in Harbour Areas Regulations 1987. These consents and licences permit the handling and storage of hazardous substances. This will need to be taken into account in any development planned in the vicinity of these areas.

9.155 References to employment uses in this policy and reasoned justification refer only to B class uses unless otherwise specified, and exclude retail uses.

(1) 9.156 The loss of employment land, whether in existing employment use or allocated for employment, could affect the Council's ability to achieve its employment objectives and job targets. Land and buildings in employment use may also come under pressure from other forms of development that tend to have higher values such as retail, leisure and housing. As a general principle therefore, such land needs to be protected. Retail uses will not be permitted other than as small scale retailing ancillary to the main/B class use. To demonstrate no reasonable prospect of re-use for employment purposes (B1, B2 or B8), applicants will be required to produce evidence that the site has been marketed actively for a continuous period of at least six months from the date of the first advertisement for business (B1) general industrial (B2) or storage and distribution (B8) uses as appropriate to the site.

9.157 Ancillary uses are defined in terms of size of floorspace and there being a functional relationship with the main B class use. Ancillary retailing should be less than 10% of the floorspace or 200 sq. m net, whichever is the smaller.

9.158 The Council recognises the importance of retaining existing employment uses and allowing for their growth and development where this can be accomplished without giving rise to serious environmental problems or unacceptable increases in traffic. Where employment uses are no longer appropriate to their surroundings or cannot reasonably expand further on their existing sites they will be encouraged to relocate within Employment Areas.

9.159 Development within Employment Areas will need to comply with the requirements of policies DM31 The Natural Environment and DM33 Green Corridors where appropriate.

AMENITY

9.160 The policy is intended to ensure that the quality of life of people close to a new development, or occupying a new development, is considered and protected. Amenity is taken to mean those general aspects of the home or workplace environment that define the quality of conditions enjoyed by people in their home or workplace. These are normally taken to include such things as privacy, safety and security, access to reasonable levels of daylight and sunlight, and absence of air and noise pollution. Amenity considerations can also include litter and disturbance from general levels of activity, for example in relation to hot food takeaways.

9.161 Amenity will vary between different areas, but this policy seeks to ensure that developments do not unduly alter an area such that existing levels of amenity are significantly harmed.

9.162 New developments that could produce harmful effects, such as air, water, noise, vibration or light pollution, will therefore be directed to locations where they would minimise the harm to the environment or amenity of neighbouring uses.

9.163 Equally important is to ensure that proposals for new development that would itself be sensitive to the harmful effects of air, noise, vibration or light pollution, such as hospitals, are not located where there are or could be such problems. In locations where hazardous substances consents exits, of which there is a particular concentration around Ipswich Port, consideration should be given to these in relation to any development proposal within the vicinity.

9.164 All major construction sites will be required to provide a Construction Management Programme designed to limit adverse impacts on neighbours. On larger sites it will be necessary for the developer to submit baseline studies so that future vibration/subsidence problems can be validated.

9.165 Where appropriate, planning conditions may be imposed or planning obligations sought for the control of noise or air pollution.

9.166 Applicants who wish to develop suspected contaminated land will be required to undertake a thorough investigation of the site and determine any risks. Relevant remediation and mitigation measures will need to be built into development proposals to ensure safe, sustainable development of the site.

9.167 Some small businesses can operate in residential areas without harming residential amenity. Indeed, such uses can contribute to creating more mixed-use neighbourhoods enabling people to live closer to their workplace. The Council recognises the importance of home working and is likely to support proposals for it. Thus, subject to the criteria above and amenity considerations set out elsewhere, such uses will be permitted. The significance of benefits to the local economy will be assessed on its merits, taking into account the number of dwellings lost and the number of jobs created or supported.

OPEN SPACE, SPORT AND RECREATION

9.168 Open spaces and sports and recreation facilities are essential to the quality of life of Ipswich people and the quality of the town's environment. They can deliver social, economic and environmental values - public health and well-being, health and fitness, air quality, water flood management, help tackle climate change, regeneration, the image of the town, ecology nature and biodiversity, green transport and community cohesion, for example.

9.169 The Council will therefore protect them from development unless the particular circumstances set out in the policy apply. This accords with the National Planning Policy Framework (NPPF), which states that existing sites and facilities should not be built on unless an up to date assessment has clearly shown them to be surplus to requirements.

9.170 The Council has carried out an open space, sport and recreation facility audit and needs assessment, as required by the NPPF. This identifies the typology of open spaces, sport and recreation facilities, assesses the quantity and quality of provision in Ipswich and sets out standards for the quantity, quality and accessibility of provision. The typology, together with the quantity and accessibility standards, is reproduced in Appendix 6. Quality standards can be found in the Ipswich Open Space, Sport and Recreation Facilities Study 2009 and subsequent update as a result of the Council's Open Space and Biodiversity policy. The need for formal sports provision is identified through the 2009 Open Space, Sport and Recreation Study, and is currently being updated by the production of the Indoor Sports Facility Strategy and the Playing Pitch Strategy. This will inform consideration of whether a facility is surplus and where/what alternative provision may be appropriate.

9.171 The Study examines provision by type in each of the Area Committee areas of Ipswich. Although provision in Ipswich is generally good, there are existing deficits in some areas.

9.172 The Council's approach is to require new developments to meet their needs for public open spaces and sport and recreation facilities. Where the various types of facility are known to be in quantitative deficit in the area around the development site or do not meet the accessibility standard, additional provision will be needed.

9.173 If new provision is needed, the decision as to whether it should be on- or off-site will depend on whether the total amount of each type needed as a result of the development is above the minimum acceptable size identified in the Public Open Space SPD. If it is, provision should be on-site. Only if additional provision is not feasible will the enhancement of existing facilities through contributions be considered.

9.174 If there is a surplus of open space within the catchment of the site, additional provision will not be required but contributions may be required to enhance existing facilities. The Public Open Space is being prepared to provide details on how open space requirements will be calculated in connection with new developments. Reference should also be made to the Ipswich Open Space and Biodiversity Policy adopted in 2013, or subsequent updates.

9.175 However, notwithstanding the above, in all major developments of 10 or more dwellings or 1,000 sq. m or more non-residential floorspace the requirement is for a minimum of 10% of the site to consist of public green space or soft landscaping and tree planting, to enhance the appearance and biodiversity value of the development, and contribute to sustainable drainage and air quality. In high density developments (defined in policy DM30) this will be 15%, to compensate for the fact that private amenity space tends to be more limited and to provide an attractive setting for the buildings. This will count towards provision needed to meet the open space standards for residential development. Where possible, this provision should include wildlife habitat designed and located so as to create a network or corridor with existing green infrastructure - green corridors and/or ecological networks, where such networks exist beyond the site boundaries. All planting proposals should be accompanied by an appropriate management plan. However, within IP-One, the provision of public civic spaces may also be considered where this makes a positive contribution to the townscape.

9.176 Not all types of residential development will create the same demand for public open spaces and sports and recreation facilities. Replacement dwellings and extensions or annexes are therefore exempt from the policy. Nursing homes and elderly persons' accommodation are not exempt, but will only be required to provide certain types of public open space and not sports facilities. This is separate from any requirement for private garden space.

9.177 The need for formal sports provision is identified through the 2009 Open Space, Sport and Recreation Study, and is currently being updated by the production of the Indoor Sports Facility Strategy and the Playing Pitch Strategy.

THE DENSITY OF RESIDENTIAL DEVELOPMENT

9.178 Between 2001 and 2014 the main housing supply in Ipswich has been flats and as a result actual densities achieved in residential schemes in Ipswich have been high. Densities are reported in the Council's annual Authority Monitoring Report.

9.179 However, the density figures in the policy (especially the high density figure) have been revised downwards since 2007 to take account of the following factors:

• The economic downturn has shown that in a weaker market flats are less likely to be built, because demand for flats drops away most dramatically of all dwelling types;
• The SHMA indicates a surplus of flats at the moment therefore the balance of housing delivery needs to swing towards houses until the market recovers, and houses cannot achieve the same densities;
• Sustainable design such as designing for passive solar gain, which will be essential to meeting the Borough's carbon reduction obligations, can impact on the layouts and configurations that may be achievable;
• Sustainable drainage requires more space in some areas of town and impacts on achievable site density;
• Flats will still be needed, but they may need to be bigger to attract older households away from family houses, and in some cases to cater for families also; and
• The mix policy for larger sites (policy CS8) means that 100% flatted development on most major scheme sites will not be acceptable.

9.180 In the vicinity of the Waterfront and Civic Drive in central Ipswich, the Council will expect high density developments to exceed the minimum set out in the policy, because this is the area where tall buildings may be appropriate as identified through policy DM6. This also more closely reflects site capacities achieved through recent planning permissions.

9.181 In order to ensure that dwellings, and especially flats, provide versatile and attractive living space that appeals to a wide audience and is therefore more sustainable in changing market conditions, the Council will encourage developers to exceed minimum floorspace areas used by the former English Partnerships in its own developments (Quality Standards 2007) (gross internal floor area).

9.182 These are as follows;

• at least 51 sq m for a 1 bed/2 person dwelling
• at least 66 sq m for a 2 bed/3 person dwelling
• at least 77 sq m for a 2 bed/4 person dwelling
• at least 93 sq m for a 3 bed/5 person dwelling and
• at least 106 sq m for a 4 bed/6 person dwelling.

9.183 The Government, through the Housing Standards Review, is currently proposing a set of national space standards. In relation to the standards set out above these would generally require larger floor areas where two storey 1 or 2 bed dwellings are proposed and where three storey 3 or 4 bed dwellings are proposed and could become a requirement through the adoption of planning policy to that effect.

9.184 It is important to strike an appropriate balance between providing freedom and flexibility for the housing market to operate and ensuring that land is used efficiently by achieving higher densities in the most sustainable locations. The exceptions in the above policy allow a degree of flexibility in controlled conditions, such as for example to protect heritage assets. The densities set out in the policy are minimum requirements. The averages referred to will be used to calculate site capacities.

NATURAL ENVIRONMENT

9.185 The Government's stated aim in the NPPF (paragraphs 109 and 114) is to halt the overall decline in biodiversity. The planning system is required to minimise impacts on biodiversity and provide net gains where possible, through measures including establishing, protecting and enhancing ecological networks.

9.186 The NPPF promotes the identification of local ecological networks to include the hierarchy of internationally, nationally and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them.

9.187 European sites include Special Areas of Conservation (SACs) and Special Protection Areas (SPAs). These sites are protected under the Habitats Directive (92/43/EEC). The Stour and Orwell Estuaries SPA and Ramsar site lies partly within Ipswich Borough. Listed or proposed Ramsar sites, potential SPAs and possible SACs and sites required in relation to compensatory measures for adverse effects on European sites are afforded the same level of protection as SACs and SPAs through the NPPF. The Conservation of Habitats and Species Regulations 2010 (as amended) set out requirements in relation to assessing projects that could potentially affect a European site. Where a significant effect on a European site cannot be ruled out proposals will need to be accompanied by an Appropriate Assessment. The assessment should be carried out in accordance with the requirements of the Conservation of Habitats and Species Regulations 2010 (as amended). Where the assessment concludes negative effects on a site's integrity permission should only be granted where there are no alternative solutions and where the project must proceed due to imperative reasons of over-riding public interest. The source-pathway-receptor model will be used to assess the effects of proposed development on European sites.

9.188 The Stour and Orwell Estuaries are a Site of Special Scientific Interest (SSSI) as well as a Special Protection Area and Ramsar site. Bixley Heath and Stoke Tunnel Cutting SSSIs are nationally important heathland and geological sites respectively. In addition, there are 19 County Wildlife Sites and 9 Local Nature Reserves that are wholly or partly inside the Borough boundary.

9.189 The mitigation hierarchy requires consideration firstly to be given to avoiding any harm to biodiversity. Where harm cannot be avoided consideration should be given to mitigating any effects and, finally, if sufficient mitigation cannot be achieved compensation measures should be undertaken. Net loss will be considered in terms of population size or loss of extent of BAP habitat or other feature for which the site was designated. In some instances it will be necessary to relocate species to an alternative location. Where this is the case the receptor location will need to be suitable for the type and number of species to be relocated and monitoring will need to ensure that the receptor location remains suitable.

9.190 An ecological network is defined as a collection of high quality and biodiverse habitats linked by ecological connections between them that enable species to move. The connections may be continuous corridors or stepping stones. Enabling species to move between sites makes them more resilient to change and improves their long term viability in the face of challenges such as climate change.

9.191 The aim of this policy is not to stifle development, but rather to protect designated wildlife sites and protect, enhance or restore where possible links between them, for example through site design and layout. The links may consist of roadside verges, railway lines or even areas covered by private gardens. Planning control does not extend to the management of such spaces, but there is advice available, for example on how to improve the attractiveness of gardens to wildlife and the Council's Parks and Open Spaces Team provide activities which support and encourage this. The policy reflects national strategic priorities in the Natural Environment White Paper 'The Natural Choice' (June 2011) and the NPPF, and local strategic priorities in terms of developing ecological networks. Reference should be made to the information and recommendations of the Wildlife Audit in relation to any proposals on, or that may affect, sites identified within it.

9.192 The Ipswich ecological network consists of:

• core areas of high ecological value, which form the heart of the network - these are primarily the internationally, nationally, and sub-regionally designated biodiversity sites (ranked 1 - 2 in the Ipswich Wildlife Audit). Internationally designated biodiversity sites are protected by statute. Core areas also include sites ranked 3 - 4 through the Ipswich Wildlife Audit, some of which are also allocated for development. This is not considered incompatible with their ecological network role, as careful design and layout can retain or enhance appropriate elements of habitat. Core areas 5 and 6 currently have low or no nature value but future development may provide an opportunity to provide enhancements for biodiversity and the ecological network as a whole;
• core area buffer zones, which surround core areas and stepping stones, to protect them from adverse impacts - these vary in width from 400m around international and national sites to 100m around Biodiversity Action Plan habitats and non-designated sites. Whilst buffers around designated sites are useful to minimise direct impacts, other longer distance impacts, such as recreational disturbance, may require additional mitigation in the case of European sites and the source-pathway-receptor approach is a general model that can be applied to any potential effect to identify impact;
• corridors and stepping stones, which improve connectivity between core areas enabling species to move, feed, disperse, migrate or reproduce; and
• corridor buffer zones, many of which cover existing built up areas, where encouragement will be given to enhancing the corridor function where possible.

9.193 Ecological networks do not respect administrative boundaries and, therefore, the Council will work with partners in the Ipswich Policy Area to ensure that networks connect across and around district and borough boundaries.

9.194 Although the identified ecological network and buffer areas will be the priority for enhancement, the 'white' areas on Plan 5 are also important for wildlife. This is particularly the case for more mobile animals such as birds and flying insects. Here measures such as wildlife gardening, verge and green space management and planting street trees could greatly enhance its value to wildlife and help to extend the network identified on the map and will be encouraged where possible.

9.195 Local Geological Sites, known within Ipswich Borough as Regionally Important Geological and Geomorphological Sites (RIGS) and County Geodiversity Sites are designated on the basis of locally developed criteria. They are the most important sites for geology or geomorphology outside statutorily protected sites such as SSSIs.

9.196 Ancient woodland is an area that has been continuously wooded since at least 1600 AD and, as such, it is an irreplaceable natural resource, which once lost cannot be recreated. Ipswich has one area of ancient woodland at Brazier's Wood near Ravenswood. The finite nature of this natural resource merits its strong protection. Veteran trees are addressed through Core Strategy policy DM10.

9.197 The Council's Open Space and Biodiversity Policy includes a corporate target to increase canopy cover across the Borough. Landscaping schemes associated with new developments provide an opportunity to increase the Borough's canopy cover, including through the provision of street trees. The trees chosen will conform to the Tree Management Policy, specifically following a 'right place, right tree' approach and the planting of species appropriate to the local area. Landscaping also provides an important opportunity to include other plants which support biodiversity, particularly nectar rich plants.

COMMUNITY FACILITIES

9.198 The provision of community facilities is important to enable communities to function sustainably. Local community facilities include: doctor and dentist surgeries, health centres, chemists, places of worship, meeting halls, public houses, post offices, education facilities and police facilities. Community uses are different to Town Centre Uses in this respect (see policy CS14). An application for a new community facility that is not owned by the organisation intending to use it should be accompanied by a management plan for the facilities.

9.199 Policy CS17 identifies the need for community facilities to support planned growth in the Borough. Strategic needs are also identified in Chapter 10 of this document. In some instances a Community Management Plan may be required where there is a need for enhanced provision of community facilities or to promote opportunities for community engagement.

9.200 Shared community spaces could bring together the delivery of services such as schooling, local policing and safer neighbourhood teams, and health services. This approach would require the agreement of all the service providers.

9.201 Open spaces and play provision are dealt with in a separate policy.

COUNTRYSIDE AND ACCESS

9.203 This policy adds detail to the strategic approach set out in policy CS16, by broadly identifying green corridors (including the 'blue corridor' of the river valley) and ensuring that any development permitted within them under other policies of this plan would not compromise the corridor function.

9.204 The Council's Open Space Study 2009 ^[13] describes green corridors as linear features mostly open in character e.g. footpaths, riverside paths and bridleways, which act as wildlife corridors and attractive, safe, off-road links between residential areas or open spaces or other destinations. Their value is increased if they link up to form a network and, for Ipswich, they may also link to the open countryside in neighbouring authority areas. They help to create urban environments that are attractive, clean and safe.

9.205 Ipswich benefits from an important and continuous green corridor in the form of the river path which follows the river from the Waterfront westwards through to Sproughton. Enhancing the river path is a key aim of the Ipswich River Strategy. The Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document proposes pedestrian and cycle bridges across the river to link up communities and facilities north and south of the river in the vicinity of Elton park, and east of Stoke Bridge.

9.206 On the periphery of the Borough there are other important areas of natural and semi-natural green space which provide corridor functions, for example Belstead Brook, Orwell County Park and Rushmere Heath.

9.207 The Haven Gateway Green Infrastructure Strategy ^[14] recognised their value but also identified gaps, particularly to the north and east of Ipswich. Thus the Core Strategy, through policy CS16, seeks to link radial green corridors with a publicly accessible 'green rim' around Ipswich. The Council will take opportunities through development, such as at the Ipswich Garden Suburb, which is addressed through policy CS10, to provide links in the green rim where currently there are gaps. Where the green rim traverses development sites, the Council will work with developers and other stakeholders to agree a route.

9.208 Some of the green rim will fall outside the Borough where the boundary is very tightly drawn. Where this is the case, the Council will work with neighbouring local authorities to address the provision of green infrastructure later in the plan period. This will seek to address gaps and provide links into the strategic walking and cycling route network, for example:

• eastwards to the coast via the Sandlings Walk
• south-eastwards via the Stour and Orwell Walk
• southwards via Belstead Brook Park to Alton Water
• northwards via the Fonnereau Way to the Fynn Valley.

9.209 The Council will work to develop a more detailed map of the green corridors based on recreational open spaces and existing rights of way and permissive routes. Plan 6 illustrates the broad location of the corridors.

9.210 Ipswich is set within a high quality landscape at the convergence of three distinctive landscape character areas defined by Natural England: the South Norfolk and High Suffolk Claylands, the South Suffolk and North Essex Claylands and the Suffolk Coast and Heaths, part of which is designated as an Area of Outstanding Natural Beauty. Suffolk County Council has also developed a finer grain landscape character assessment. The Borough boundary includes small amounts of countryside to the north-west, north-east and south-east of the urban area.

9.211 One of the principles of planning set out in the National Planning Policy Framework (NPPF) is that it should recognise the intrinsic character and beauty of the countryside. Together with peripheral designated open spaces, the countryside around the Ipswich urban area provides an attractive setting for the town and links into its ecological and green corridor networks. The creation of sporadic and isolated development in the countryside that is not connected with the essential requirements of agriculture will be discouraged.

9.212 Ipswich also contains a small area of the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB) on the southern boundary of the Borough. The NPPF sets out the approach to considering major development applications within the AONB in paragraph 116.

9.213 The NPPF supports rural tourism and leisure developments which respect the character of the countryside. However, isolated homes in the countryside should be avoided unless there are special circumstances to justify them.

9.214 Ipswich has a tightly drawn Borough boundary so countryside at the periphery of the Borough is not physically remote from the urban area. However development which would be relatively isolated in terms of access to public transport and community facilities should be avoided.

9.215 Impact on the character of the Ipswich countryside will be assessed in relation to the Suffolk County Council character assessment analysis. Areas of countryside are defined on the policies map.