Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Part A: The Context
CHAPTER 2: The Planning System
2.1 The current development planning system was established through the Planning and Compulsory Purchase Act 2004 and subsequent amendments, such as the Localism Act 2011 which introduced neighbourhood plans. The national approach to planning policy is explained in the new National Planning Policy Framework (NPPF 2019), Planning Practice Guidance and other documents covering specific topics such as the Marine Policy Statement and Planning Policy for Travellers Sites. The NPPF 2019 maintained the presumption in favour of sustainable development. For plan making, this means that local planning authorities should plan positively to meet the development needs of their area, and meet objectively assessed needs unless the adverse impacts of doing so would 'significantly and demonstrably outweigh the benefits', or specific policies of the NPPF indicate that development should be restricted. The NPPF also contains national land use policy on matters such as the economy, town centres, transport, housing and good design. Policies in the NPPF are supplemented by the National Planning Practice Guidance (NPPG), an online set of guidance on implementing the policies in the NPPF.
2.2 Section 38(6) of the Planning and Compulsory Purchase Act states that:
"... for the purpose of any determination to be made under the planning Acts the determination must be made in accordance with the (development) plan unless material considerations indicate otherwise."
2.3 The development plan for Ipswich will comprise various development plan documents, which will be adopted by the Borough Council as part of the Local Plan.
2.4 The Local Development Scheme for Ipswich sets out the documents, processes and timescales involved with the Local Plan.
2.5 The components of the Ipswich Local Plan are illustrated in Diagram 2. The adopted Local Plan Proposals Map will remain extant until replaced through other development plan documents (DPDs) to be prepared as part of the Ipswich Local Plan.
Notes to diagram
The Statement of Community Involvement Review, adopted in March 2018, sets out how people will be involved within the planning process;
The Core Strategy and Policies Development Plan Document (i.e. this document) sets out the strategy for the development of the town and also includes policies that will seek to guide and manage development;
The Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document and policies map will highlight land that is the subject of designations that means it will be protected, and identify allocations of land for specific types of development. It will also set out the vision for an urban renaissance for a large part of central Ipswich and provide design guidelines;
Supplementary Planning Documents can be theme-based documents providing additional detail to support the implementation of policies in the development plan documents, or site development briefs.
2.6 A key element of the planning system is the requirement to undertake Sustainability Appraisal and Strategic Environmental Assessment as documents are produced. The Sustainability Appraisal involves assessing strategic alternatives, policies and proposals against social, economic and environmental objectives to identify possible negative impacts. Policies are modified in response to the results, to ensure that harmful impacts are avoided or mitigated. Strategic Environmental Assessment focuses solely on environmental impacts. The baseline assessment helps to identify the issues facing the Borough in terms of economic, social and environmental objectives through document review. The sustainability appraisal is revisited at each stage of plan-making. A Sustainability Appraisal Report setting out the Council's work in both areas will be published for consultation alongside this document.
2.7 Another requirement is an Appropriate Assessment of the plan under the Habitats Directive. This is an assessment of the potential effects of a proposed plan on sites of European importance for nature conservation. These include sites, often known as Natura 2000 sites, designated as Special Areas of Conservation (for habitats, and species except birds) or Special Protection Areas (for birds). Government policy in the National Planning Policy Framework applies the same protection to Ramsar sites also. The Orwell and Stour Estuaries are designated as a Special Protection Area and Ramsar Site.
2.8 A plan may only be approved if it can be shown that it will not adversely affect the integrity of a European designated habitat. A report published alongside this document explains the findings of the Appropriate Assessment. Where policies or proposals have been included in order to address the findings of the Appropriate Assessment, it is explained in the reasoned justification.
2.9 The Government first published the National Planning Policy Framework (NPPF) in March 2012. The NPPF was further updated in 2018 and 2019. In response, the Council introduced and maintains a presumption in favour of sustainable development, which is set out in policy CS1 of this document. The NPPF requires that local planning authorities ensure that their Local Plan provides a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period in this case to 2036.
2.10 Section 110 of the Localism Act sets out the Duty to Cooperate. The duty applies to all Local Planning Authorities, National Park Authorities and County Councils in England and to a number of other prescribed public bodies. The Duty to Co-operate requires these bodies to engage constructively, actively and on an ongoing basis in relation to strategic cross boundary planning issues. Local Planning Authorities have to demonstrate how they have met the requirements of the duty. This is dealt with in more detail in Chapter 4.
2.11 The NPPF advises that each local planning authority (LPA) should produce an aspirational but realistic plan for its area. LPAs invest significantly in the preparation of these plans, including engaging with all sections of the community in their development.
2.12 The essential test for the Local Plan is whether it meets the tests of 'soundness'. These are clearly defined in the NPPF. NPPF (paragraph 35) makes clear that a sound plan is one which is positively prepared, justified, effective and consistent with national policy.
2.13 To meet the test of being 'justified', the Local Plan needs to set out 'an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.' The plan strategy has been developed as a result of reviewing the adopted plan strategy and the updated evidence base, and testing the emerging plan at each stage through the sustainability appraisal process. The issues and options consultation in 2017 explored alternative growth scenarios jointly with Suffolk Coastal District Council (now East Suffolk Council) and ways in which growth could be delivered. The preferred options draft Local Plan published in January 2019 set out the proposed strategy for meeting development needs in the Borough which is largely carried through to the Final Draft Local Plan.
2.14 Ipswich Borough has a tightly drawn administrative boundary, which constrains the practical options for meeting needs for development, taking as the starting point the national policy requirement for the Borough should meet its own needs if possible. However, the plan seeks to address the objectively assessed needs both for employment and housing and is informed by agreements from other neighbouring authorities through the Ipswich Strategic Planning Area (ISPA) Board. A Statement of Common Ground has been agreed by the members representing the constituent authorities who sit on the ISPA Board.
2.15 The spatial strategy is for continued urban regeneration in central Ipswich. This continues a well established approach that has seen a transformation of the Waterfront, and the beginnings of change to a more vibrant mixed use area in the Portman Quarter (formerly Ipswich Village). Alongside the focus on the central area, a sustainable urban extension is allocated on greenfield land at the Ipswich Garden Suburb and a cross-boundary allocation for future development for housing, appropriately phased with the delivery of the Ipswich Garden Suburb and its associated infrastructure, is also identified in north-east Ipswich at the northern end of Humber Doucy Lane.
 National Planning Policy Framework, paragraph 23, p. 9