(3)CHAPTER 8: The Spatial Strategy

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

8.2 This chapter is divided into seven sections. The first provides the sub-regional context for the planning of Ipswich, based on an approach across the Ipswich Strategic Planning Area. Following this is a strategic spatial approach to the development of the town; the next four relate to the components of 'live, work, learn and play', and the final section relates to infrastructure to support growth and development.

The Ipswich Strategic Planning Area

8.3 Through this Local Plan, the ambition for Ipswich is to boost economic growth and housing delivery, to meet needs, unlock potential and support cohesive communities. However, Ipswich as the county town sits within a wider area, which demonstrates strong functional relationships. This wider area includes Mid Suffolk and Babergh Districts and the former Suffolk Coastal District element of East Suffolk Council, which all border Ipswich. Evidence produced as part of the production of the Local Plan demonstrates that the four authorities together form the Ipswich Housing Market Area and the Ipswich Functional Economic Area. The area has strong connections in terms of travel to work patterns and housing and commercial markets. The area is shown on the map below.

8.4 The four authorities, along with Suffolk County Council, have a history of working together on strategic planning issues through the former Ipswich Policy Area Board (now the Ipswich Strategic Planning Area Board or ISPA Board). The ISPA Board provides a mechanism for the five authorities to develop, promote and deliver a vision for the Ipswich Strategic Planning Area and to co-operate on the preparation and monitoring of Local Plans and to share relevant evidence. This joint working is a fundamental part of planning in the area.

Map 2 Ipswich Strategic Planning Area

8.5 The Councils have worked together on evidence relating to housing and employment needs and landscape sensitivity and all authorities have recently published evidence relating to retail and commercial leisure needs.

8.6 Under the 2011 Localism Act, local planning authorities are required to co-operate on strategic planning matters. The strategic planning matters within the Ipswich Strategic Planning Area cover a range of issues including housing need and distribution, provision of land to support economic growth and delivering green infrastructure. In recognition of these interdependencies, the authorities have closely aligned their timetables for the production of Local Plans. The policies in this section are based upon the recognised common strategic matters, and establish Ipswich Borough Council's commitment to joint working.

8.7 Joint or aligned approaches are also necessary to help Ipswich Borough meet future development needs, as the Borough is under-bounded. This means that choices about directions for growth at the edge of the town within the Borough boundary are limited. A cross boundary approach is the starting point to ensure that development required to meet local needs is provided in a planned and coordinated way, in the right locations, and creates successful places.

8.8 The five ISPA authorities, in reflection of the changes to the National Planning Policy Framework, are working together on the production of a Statement of Common Ground to document the joint working and agreements in relation to strategic matters, which will evolve over the course of production of Local Plans.

Scale and location of growth

8.9 On 24^th July 2018, the Government published the revised National Planning Policy Framework. It introduces a standard method for calculating housing need based on the latest published household projections and applying an uplift based upon published ratios of median house prices to median workplace earnings (the 'affordability ratio'). This has since been updated in the February 2019 NPPF and the subsequent Planning Practice Guidance (PPG), 'Housing and Economic Needs Assessment (22 July 2019) which provides detailed workings of the Government preferred method. However, using the current standard method and based on the household projections published by the Government in September 2019 and the affordability ratio published by the Office for National Statistics in April 2019, the current figures equate to a need for 35,334 dwellings across the Housing Market Area to reflect the housing figures as calculated using the 2014-based household projections and the 2018 affordability ratio published in March 2019. Table 8.1 below shows the figures and, for comparison purposes, the housing need as identified through the Government's Right Homes, Right Places consultation in 2017.

8.10 The National Planning Policy Framework expects strategic policy-making authorities to follow the standard method in this guidance for assessing local housing need. The standard method uses a formula to identify the minimum number of homes expected to be planned for, in a way which addresses projected household growth and historic under-

Table 8.1 – Objectively Assessed Housing Need across the Ipswich Housing Market Area based on the standard method

	SHMA annual	SHMA total (2014-2036)	Standard method annual (Sept 2017)	Standard method total (2016 – 2036)	Standard method annual (2016-based)	Standard method total (2016-based) (2018-2036)	Standard method annual (2014-based)	Standard method total (2014-based) (2018-2036)	Standard method annual (2014 based, 2018 ratios)	Standard method total (2014 based, 2018 ratios, 2018 – 36)
Babergh	355	7,820	439	8,780	420	7,560	420	7,560	420	7,560
Ipswich	519	11,420	442	8,840	479	8,622	445	8,010	445	8,010
Mid Suffolk	452	9,951	573	11,460	590	10,620	585	10,530	556	10,008
Suffolk Coastal	460	10,111	495	9,900	582	10,476	515	9,270	542	9,756
Total	1,786	39,302	1,949	38,980	2,071	37,278	1,965	35,370	1,963	35,334

Note: the Babergh figure of 420 p.a. includes the application of a cap on the uplift, as allowed for by the methodology.

8.11 The standard method forms an appropriate starting point for identifying a housing requirement. The starting point for each authority will be to meet their own needs within their own boundary. Policy CS7 sets out the housing requirement identified for Ipswich Borough and how it will be met. The ISPA Statement of Common Ground identifies circumstances that would trigger a Local Plan review in relation to any ISPA authority's ability to meets its own housing need.

8.12 The authorities also jointly commissioned a Gypsy, Traveller, Travelling Showpeople and Boat Dwellers Accommodation Needs Assessment (2017) which identified needs for Gypsy and Traveller provision as follows:

Table 8.2 – Needs for Gypsy and Traveller accommodation in the IHMA

	Needs for permanent Gypsy and Traveller pitches[3] (2016 – 2036)
Babergh	1
Ipswich	27
Mid Suffolk	9 – 30
Suffolk Coastal	15
IHMA	52 – 73

8.13 The starting point for each authority will be to meet the needs within their own areas.

8.14 The authorities jointly commissioned the production of the Employment Land Needs Assessment, and the subsequent Economic Area Sector Needs Assessment, to identify the needs of the different employment sectors and the associated land requirements. This evidence demonstrates that the area functions as one Functional Economic Area and that there are distinct economic geographies within the area namely:

• Felixstowe / A14 corridor
• Wider Ipswich Market Area
• A140 corridor
• Rural and agricultural

8.15 The baseline jobs growth and employment land requirements are as shown in Table 8.3 below. They have been adjusted from the study figures to update to a 2018 baseline for the Local Plan Review. It should be noted that the baseline jobs growth for Ipswich has been re-adjusted to reflect the 2017 East of England Forecasting Model (EEFM), contrary to the 2016 EEFM used in the Preferred Options Local Plan and as adopted by the other IFEA authorities. This is because the 2017 EEFM identified a forecast jobs requirement of 9,318 jobs between 2018 – 2036, equivalent to a 40% reduction compared to the 2016 EEFM jobs forecast of 15,577 jobs. In contrast, the forecast jobs growth for the other authorities in the IFEA are not significantly affected by this update to the evidence base.

Table 8.3 – Baseline jobs growth and employment land requirements in the ISPA

	Baseline jobs growth (2018-2036)	Minimum employment land requirements (B1, B2 and B8 uses) (2018 – 2036)
Babergh	2,970	2.3ha
Ipswich	9,500	23.2ha
Mid Suffolk	5,270	7.7ha
Suffolk Coastal	6,500	11.7ha
IFEA	24,060	44.9ha

8.16 Evidence of needs for retail and commercial leisure has been produced for Ipswich and Suffolk Coastal, and for Babergh and Mid Suffolk. This evidence supports the continuing role of Ipswich as the county town and provides quantitative requirements for comparison shopping (non-food) and convenience shopping (food) over the plan period. Ipswich Borough Council has commissioned an update of the retail element of this evidence base, the results of which will inform Policy CS14.

Infrastructure

8.17 Within the Ipswich Strategic Planning Area there are aspirations towards the delivery of a number of key infrastructure projects, and in addition, there will be cross boundary infrastructure that is required as a result of growth planned within Local Plans.

8.18 The provision of new and improved infrastructure is essential to ensure that the growth planned across the area is sustainable. Planning for infrastructure across the area will include schools, sustainable transport measures, improvements to the A12 and A14, improvements to other parts of the road networks and the railways. In addition to infrastructure requirements directly linked to planned growth, there are other cross-boundary projects that would help to grow and improve the economy and quality of life for the area.

8.19 In addition to the integrated transport solutions, including bus network improvements within the town and increased capacity of the local rail offering, a northern route around Ipswich is expected to be needed to enable growth in the longer term. The route would improve connectivity between the A14 and A12, reducing pressure on the A14 and improving network resilience, especially near the Orwell Bridge and Copdock interchange. Suffolk County Council consulted on Ipswich Northern Route Options between July to September 2019, which assessed three indicative broad routes. Ipswich Borough Council resolved at the Executive Committee meeting of 3 September 2019 to indicate a general support to the project from the Borough Council and to suggest a strong preference for the inner route. The Council fully supports the ongoing work of Suffolk County Council in considering potential options for routes, and it is expected that the next review of the Ipswich Local Plan (along with other Local Plans in the Ipswich Strategic Planning Area) will consider the implications of any decisions made about routes in more detail, including the extent to which the options might support potential future scenarios for housing and employment growth beyond that which is being planned for within this Local Plan.

Protection of the environment

8.20 Suffolk contains extensive areas of nationally and internationally protected landscapes and habitats. A particular issue is the need to ensure that new development does not result in harm to the integrity of internationally designated Special Protection Areas, Special Areas of Conservation, Ramsar sites and the Suffolk Coasts and Heaths AONB. Strategic projects may require joint working by public bodies to ensure the requirements of the Birds and Habitats Directive are met.

8.21 Local authorities in the ISPA have been working collectively on the Recreational Avoidance and Mitigation Strategy (RAMS) to mitigate the pressure caused by new developments on these designated sites. The partnership work, supported by Natural England, has established a strategy to mitigate the impacts and is due to be supported by a Supplementary Planning Document that will provide further details in respect of cost implications and subsequent implementation.

8.22 Many of the European designated sites cross administrative boundaries and experience visitor pressure from residents and visitors. The collaborative approach is therefore required to ensure that green infrastructure requirements are considered across the wider area in a consistent manner.

Delivering development at the Borough boundary

8.23 The under-bounded nature of Ipswich Borough means that there is little open countryside remaining on the edge of the town. The Council has reviewed these areas in order to comply with the NPPF and the commitment above to meet its own development needs as far as possible. A Strategic Housing and Employment Land Availability Assessment is available alongside this draft revised Local Plan which identifies all land the Council has reviewed for potential development.

8.24 One area where a cross-border allocation for future development has been identified is the northern end of Humber Doucy Lane adjacent to Tuddenham Road, where land was promoted through the previous Local Plan Review and again through the call for sites process in 2017. The indicative development capacity of the land within the boundary of Ipswich Borough Council is 496 dwellings. The site sheet ISPA4.1 in Appendix 3 of the Site Allocations DPD provides further information on this indicative capacity. In addition, the Suffolk Coastal Local Plan has allocated a site on the East Suffolk side of the Ipswich boundary. It is essential that the two authorities work together to provide a comprehensive approach to the land as planned development. Policy ISPA 4 identifies the likely impacts of the development which would have to be mitigated in relation to demand arising from potential residents such as transport infrastructure and sustainable transport initiatives to create potential for a substantial modal shift change and green infrastructure. As part of the master plan work, mitigation measures required that arise from demand created by the development will be reconsidered, including possibly the need for healthcare facilities.

8.25 The site is in close proximity to the Ipswich Garden Suburb (Policy CS10), a strategic allocation which is anticipated to deliver approximately 3,500 dwellings and other uses, including three new primary schools, largely over the course of the Local Plan period. Primary school capacity is a current constraint on development at Humber Doucy Lane coming forward, and it is anticipated that additional capacity can be provided through the planned new provision at the Ipswich Garden Suburb to ensure there is adequate provision for this development. This is anticipated to affect the timing of development coming forward.

8.26 Development in this allocation for future development will be required to deliver high quality design, which sensitively addresses adjacent countryside, biodiversity and existing dwellings. The development should also seek to preserve the significance of the Listed Buildings to the north and east of the site. These are Allens House, Laceys Farmhouse, and the Garden Store north of Villa Farmhouse. Where possible existing hedges onto Humber Doucy Lane shall be preserved and protected during the development process as applicable.

8.27 A concentration of housing in this location is likely to require a bespoke Suitable Accessible Natural Greenspace (SANG) in addition to contributions towards the Recreation Avoidance Mitigation Strategy, to function as an alternative to the coast. As proposals for the site progress, consideration should be given to how the nearby SANG being delivered as part of the Ipswich Garden Suburb and wider footpath network, may be linked to any new SANG provision.'

8.28 The site allocation at the northern end of Humber Doucy Lane is located at the edge of Ipswich approximately 3.5km from the town centre. Sustainable transport connections will be key to providing linkage to employment and other opportunities. In addition, it is acknowledged that the transport mitigation measures required for the development of the site are challenging and it is essential that significant modal shift is delivered through strong travel plans and other sustainable measures.

8.29 The Council will outline expected infrastructure provision of both green infrastructure and built infrastructure required as part of the joint agreed master- planning process to the cross-border Humber Doucy Lane sites. The Whole Plan Viability Assessment for the Local Plan identifies that this area of land falls within a high value zone and indicates that approximately 30% affordable housing could be achieved on a greenfield development. This level of affordable housing also broadly aligns with the Suffolk Coastal Local Plan affordable housing requirement of 33%.

8.30 The above policies ISPA1 to ISPA4 replace the previous policy CS6 The Ipswich Policy Area.

A STRATEGIC SPATIAL APPROACH TO THE DEVELOPMENT OF THE TOWN

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

8.32 Five issues are addressed below. They are:

POLICY CS1:

Sustainable Development

POLICY CS2:

The Location and Nature of Development

POLICY CS3:

IP-One Area Action Plan

POLICY CS4:

Protecting our Assets

POLICY CS5:

Improving Accessibility

POLICY CS6:

The Ipswich Policy Area (policy deleted)

8.33 Sustainable Development

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

8.35 In the following policies, policy CS1 Sustainable Development covers the key areas of climate change and the presumption in favour of sustainable development; and policy CS4 Protecting our Assets covers the conservation of the built and natural environment and the use of natural resources.

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

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

POLICY CS1:
Sustainable Development

8.38 Achieving sustainable development is the fundamental purpose of the planning system as defined through the National Planning Policy Framework and lies at the heart of the vision and objectives set out earlier in this plan. Sustainable development means meeting economic, social and environmental objectives in mutually supportive ways. The starting point for considering sustainable development is tackling climate change, because of the scale of the threat and the potential severity of its effects on ecosystems and human existence. It is required by national policy and it is also in the direct interests of a town with a central area situated on low-lying land on an estuary subject to tidal flooding.

8.39 The Council will plan positively for growth to meet objectively assessed needs and provide a flexible framework which can respond to rapid change.

8.40 The NPPF sets out the Government's approach to achieving sustainable development. Within it, paragraph 11 sets out the presumption in favour of sustainable development. The plan complies with the NPPF by setting out a framework of policies and proposals which plan positively for growth to meet the town's objectively assessed needs, whilst protecting areas and assets of particular importance. When considering development proposals, the Council will take a positive approach, supporting the presumption in favour of sustainable development except where proposals would compromise that presumption, as contained within the policies of the Local Plan and the National Planning Policy Framework.

8.41 The Local Plan needs to plan positively for development within the context of a changing climate. The NPPF requires the planning system to support the transition to a low carbon future and take a proactive approach to mitigating and adapting to climate change. There are many ways in which the Ipswich Local Plan can help to tackle climate change and ensure that Ipswich in 2036 will be more resilient to its effects. The current UK Climate Projections (UKCP18) forecast that the UK will continue to warm in future and more so in the summer than winter. The modelling shows an increased chance of milder, wetter winters and hotter, drier summers, along with an increase in the frequency and intensity of extremes. Sea level rise in London by 2100 is predicted to be 0.29-0.70m under a low emission scenario, and 0.53-1.15m under a high emission scenario. Planning responses include reducing greenhouse emissions from travel and buildings, addressing flood risk in locating and designing development, supporting the development of renewable and low carbon energy capacity, requiring sustainable drainage where appropriate and greening the town to provide shade and intercept heavy rainfall.

8.42 Policy DM1 in Part C of this document provides more detail as to how sustainable buildings can be delivered in Ipswich through the standards for energy and water use for residential development, and BREEAM ratings for non-residential development. The Plan is not prescriptive about how developers should achieve these targets. There is a significant amount of existing advice available about sustainable construction^[4].

8.43 The Planning and Energy Act 2008 allows local planning authorities to adopt policies which require developers to meet a proportion of their energy requirements from renewable or low carbon sources, and this is taken forward through policy DM2. The National Planning Policy Framework requires local planning authorities to support the move to a low carbon future and when setting any local requirements for a building's sustainability, to do so in a way consistent with the Government's zero carbon buildings policy and adopted nationally described standards.

8.44 Many buildings in Ipswich are at risk of flooding, some from tidal surges and many from heavy rain. This risk will continue to grow as a result of rising sea levels and increasingly heavy rainstorms that can overwhelm drainage systems and cause localised flooding unless mitigation measures are implemented. At the strategic scale, tidal flood risk has been addressed through the effective completion of the Ipswich Flood Defence scheme. However, developments located within the flood plain will still need to address residual risk in accordance with the National Planning Policy Framework (e.g. the risk of defences failing). Managing surface water run-off is also important. SuDS, rainwater harvesting, storage and where appropriate the use of green roofs or water from local land drainage will be required wherever practical. Such approaches shall be particularly mindful of relevant ecological networks. New buildings need to be more adaptable and resilient to climate change effects in future. This is taken forward through policy DM4.

8.45 Ipswich Borough Council and Suffolk Coastal District Council (now East Suffolk Council) published a cross boundary Water Cycle Study in January 2019. The study provides a high level assessment of water resources and supply infrastructure; waste water treatment, water quality and sewage; and flood risk. Ipswich is within an area of serious water stress and water companies will need to address a forecast deficit in the supply demand balance in the long term. In the medium to long term, Anglian Water has accounted for sufficient growth so as not to constrain development. In the short term, the phasing of new development needs to be appropriate so that it can be accommodated within the forecast supply demand balance and ties in with infrastructure upgrade timescales. Local Plans also need to support water efficient design. The study does not identify a need for additional wastewater recycling centre capacity in Ipswich. On flood risk, it concludes that an updated Strategic Flood Risk Assessment is needed to model the boundaries of Flood Zones 3a and b; drainage strategies should be prepared for all sites; and the sequential and exception tests need to be applied to all sites in flood zones 2 and 3. The Council's Strategic Flood Risk Assessment 2011 has been updated. The approach to flood risk and water infrastructure is addressed through policies CS17 and CS18, and DM4. Further guidance is contained in the Development and Flood Risk Supplementary Planning Document 2016.

8.46 The Ipswich Surface Water Management Plan was produced in 2012 and is currently under review. The action plan includes measures to reduce flooding, manage the consequences of flooding, or prevent increased flooding – e.g. by preventing obstruction of flood paths. It focuses on four catchments: London Road to Lavenham Road and Hadleigh Road, Ancaster Road/ Burrell Road, Lovetofts Drive to Lagonda Drive, and Worsley Close/ Ellenbrook Green. The resulting action plan proposes measures for alleviating flooding in these four areas and suggests ways to reduce the effects of 'urban creep' (paving of gardens, small extensions, etc.). Actions included the implementation of retrofit sustainable drainage systems, and maintenance such as gully clearing. Policy DM4 addresses drainage within new developments and includes a requirement not to increase the risk of all forms of flooding.

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

8.48 There can be a multitude of benefits: for the climate, for people and for wildlife. Wood is a smart choice - timber is renewable and can replace other materials that require much larger fossil fuel inputs for their production. It can also replace fossil fuels directly in the form of renewable energy, or wood fuel. Trees can help Ipswich to adapt to a changing climate by intercepting rain in heavy rainstorms and to help alleviate flooding, moderate local microclimates – urban areas with trees are cooler in summer and warmer in winter, and help tackle the urban heat island effect, as well as creating a valuable wildlife habitat. Ipswich's canopy cover and health care needs is changing. The Council aims to help the Borough's canopy cover to adapt and become resilient to the changing climate. Canopy cover and arboriculture can be an important and attractive part of the solution in Ipswich and this is taken forward through policy DM9.

8.49 Trees are important in helping to keep rivers cool and therefore improving the state of the river for biodiversity. By providing shade, trees are able to moderate the extremes in water temperature which can be detrimental to fish spawning. Their underwater root systems provide valuable habitat to fish and invertebrates whilst stabilising the banks. Shading can also be helpful in the control of aquatic vegetation and well as bringing benefits for people. This is taken forward through policy DM10 Green Corridors.

8.50 Green spaces and functioning ecosystems help in adapting to the extremes of climate change. Green areas in the Borough have less of a heat island effect than built-up areas providing opportunities for people to keep cool in hot weather. Green spaces also improve air quality contributing to reduced ground-level ozone, fine particulates and respiratory irritants. Functional ecosystem can also mitigate the risks associated with downstream flooding from extreme rainfall events. In recent years there is also an upsurge in 'growing your own' food on allotments that helps reduce the miles food travels. From mitigating the effects of climate change to improving health, parks and green spaces play a vital part in Ipswich. Blue corridors in Ipswich, such as the River Gipping corridor, also support climate change resilience. Setting back urban development from watercourses, overland flow paths and ponding areas can create a mosaic of urban corridors designed to facilitate natural hydrological processes whilst minimising urban flooding, enhancing biodiversity and improving access to recreation. Open space protection and provision is taken forward through policies CS16, DM5 and DM6.

8.51 It is also inherently sustainable to keep historic buildings in use. Policy DM13 sets out the policy for proposals affecting built heritage.

8.52 This policy implements plan objectives 1 and 2.

POLICY CS2:
The Location and Nature of Development

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

8.54 This approach to the location of development is centred on the town centre (which includes the Portman Quarter – formerly called Ipswich Village - and the Waterfront), Ipswich Garden Suburb, the northern part of Humber Doucy Lane in the longer term and on the town's district centres. The strategy is illustrated in the key diagram. The exact boundaries of these areas will be defined on the policies map through the policies of this plan and the Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document. The town centre, Portman Quarter and Waterfront will receive the highest densities of development in the town - including high-density housing developments. Medium-density and locally focused facilities would then be provided elsewhere in IP-One and within and around district centres, with lower density development elsewhere. Developments at higher densities will require special attention being paid to their urban design and greening qualities. Residential densities are defined in policy DM23.

8.55 This approach to the location of development enables multiple objectives to be achieved.

 It will maximise opportunities to re-use previously developed land within central Ipswich.

 It will ensure that new housing is provided close to local shops and facilities that can be accessed by non-car modes, which contributes to reducing carbon emissions and supporting communities.

 It will support the ongoing regeneration of central Ipswich and particularly of the Waterfront and town centre.

 It will help to ensure the effective and efficient use of land through developing at appropriate densities according to the accessibility of the location.

 It will create a sustainable Garden Suburb to help meet the housing needs of the Borough.

 As development draws to a conclusion at Ipswich Garden Suburb, it will enable lower density housing development to be master planned jointly with East Suffolk Council at the northern end of Humber Doucy Lane, which will maintain and ensure separation between Ipswich and surrounding settlements.

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

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

8.58 Later in the plan period after 2031, the Council's housing land supply opportunities within the Borough boundary become more limited and, therefore, there will be a need to consider future development opportunities beyond the boundaries with the neighbouring local authorities, in association with the provision of significant infrastructure. Policy CS7 sets out the Borough's objectively assessed housing need.

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

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

8.61 The district centres referred to in the policy and identified in the key diagram are as follows (with reference numbers for cross reference to the policies map):

 Meredith Road (3)

 Norwich Road (1-91, 2-110) / Bramford Road (7)

 Hawthorn Drive (9)

 Stoke Park (11)

 Wherstead Road (13)

 Cauldwell Hall Road / Woodbridge Road (418-785) (18)

 Felixstowe Road (55-201, 120-190) (23)

 Nacton Road (270-374) (28)

 Ravenswood (47)

 Woodbridge Road East (27-53) / Heath Road (17)

 Sproughton Road / (to be developed)

 Duke Street (48)

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

8.63 Within a 400m straight line distance from district centres, the Council would support the provision of identified community facilities (see Appendix 2). Within a wider zone of 800m, the Council would support in principle medium density housing provision to try to increase the proportion of people living near to shops and community facilities.

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

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

8.66 Delivering high quality change, which safeguards the best of the town's urban character and neighbourhoods and secures positive improvements, is not just confined to the IP-One Area and Conservation Areas. The NPPF advises that sustainable development 'involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people's quality of life'. To facilitate this, an Urban Character Study supplementary planning document has been adopted to define the environmental characteristics of the Borough as a whole. Policy DM12 Design and Character addresses character and other key aspects of design and public realm, including urban greening, designing out crime, sustainable movement and accessible homes.

8.67 In expecting high quality architecture and urban design, it is important that new development ensures the impacts of climate change are mitigated and that, where appropriate, Secured by Design principles are adopted. Where deemed necessary, anti-terrorism measures for strategic sites should be incorporated.

POLICY CS3:
IP-One Area Action Plan

8.68 The spatial strategy for Ipswich continues to focus development to a significant degree on central Ipswich and particularly on the areas that ring the historic core and this is where many sites which need redevelopment are located. Therefore, the Council is retaining the area action plan for the area - known as IP-One - to guide its delivery. The Area Action Plan is incorporated into the Site Allocations and Policies Development Plan Document (DPD). The IP-One area has been defined by the Council. It is slightly larger than the town centre and includes the central shopping area, Portman Quarter (formerly Ipswich Village), the Waterfront and the Education Quarter. The IP-One area is indicated broadly on the key diagram. It is defined on the policies map.

Area action plans are intended as a tool to guide development in areas where change is expected and/or conservation policies apply. IP-One includes both types of area, encompassing as it does the medieval core of the town, which now forms the focus for the Central Shopping Area; the Waterfront and Portman Quarter where regeneration activities are focused at present; and the Education Quarter where the University of Suffolk is located. The IP-One Area Action Plan builds on earlier work that resulted in the publication of a non-statutory area action plan in 2003. The Opportunity Area development principles are identified through Chapter 6 of the Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document.

POLICY CS4:
Protecting our Assets

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

 Over 600 listed buildings and structures;

 15 conservation areas;

 A Ramsar Site and Special Protection Area for Birds (part of the Stour and Orwell Estuaries site);

 4 Sites of Special Scientific Interest – three for wildlife (two are different parts of the same area) and one for geology;

 20 County Wildlife Sites;

 8 scheduled monuments;

 3 County Geodiversity Sites

 2 Regionally Important Geological Sites

 An ancient woodland;

 An area of archaeological importance for remains of all periods in the historic core, particularly Anglo-Saxon deposits; and

 3 registered parks and gardens and 518 hectares of parks and open spaces.

8.70 There is also a list of Suffolk Priority Species and Habitats, which identifies species and habitats of particular importance to the county and Ipswich. A small part of the south-east of the Borough lies within the Suffolk Coast and Heaths Area of Outstanding Natural Beauty.

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

8.72 The Ipswich asset base also includes all the finite natural resources that the Borough depends on, such as minerals used in construction, land and soil itself. The National Planning Policy Framework recognises the prudent use of natural resources as a core objective of sustainable development. We therefore need to take opportunities to use natural resources more sparingly and efficiently, to re-use and recycle materials and to source materials locally where possible.

8.73 Most of the built, heritage and natural assets are protected by one or more pieces of legislation, policy documents or circulars, including:

 EU Habitats Directive;

 EU Birds Directive 2009;

 Conservation of Habitats and Species Regulations 2017, as amended;

 Wildlife and Countryside Act 1981;

 National Parks and Access to the Countryside Act 1949;

 Countryside and Rights of Way Act 2000;

 Ramsar Convention on Wetlands;

 Hedgerows Regulation 1997;

 Plant Health Act 1967 and orders;

 Forestry Act 1981;

 Natural Environment and Rural Communities Act 2006;

 The Town and Country Planning Act 1990;

 Planning (Listed Buildings and Conservation Areas) Act 1990;

 Ancient Monuments and Archaeological Areas Act 1979;

 National Heritage Act 1983;

 The National Planning Policy Framework (2019) and Planning Practice Guidance (2014 and as updated);

 The Localism Act 2011; and

 Water Framework Directive.

8.74 This framework of legislation, guidance and policy currently provides comprehensive protection for the assets. The Council will take the following approach to heritage assets:

 Conserve and enhance the significance of the Borough's heritage assets, their setting and wider townscape in accordance with policy DM13;

 Require new development to contribute to local distinctiveness, built form and scale of heritage assets through the use of appropriate design and materials;

 Require regeneration proposals to demonstrate a clear understanding of the significance of the asset and its wider context, and the potential impact of the development on the heritage asset and its context;

 Keep under review potential buildings and structures for statutory protection; and

 Prepare and review entries for the joint Suffolk LPA Buildings at Risk register.

8.75 Local policy is also provided through policy DM13 Heritage Assets and Conservation. The National Planning Policy Framework sets out the Government's planning policies for England. This is supported by the National Planning Practice Guidance which is a web based resource published by Government, and also by the Good Practice Advice Notes (GPA) produced by Historic England in collaboration with the Historic Environment Forum. Historic England also publish Historic England Advice Notes on specific topic matters providing advice to those engaged in planning matters. The Council is preparing a supplementary planning document to protect the special local distinctiveness of Ipswich heritage assets (the Urban Character Supplementary Planning Document).

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

8.77 All conservation areas have been the subject of detailed Conservation Area Character Appraisals. Those for areas designated by 1994 were the subject of public consultation and Council approval during 1994-95. Subsequently four additional conservation areas were declared in 1995, 2003, 2005 and 2015, for which appraisals were also prepared. Periodic reviews of all conservation areas are required by heritage legislation and these have been undertaken at approximately five yearly intervals since 1994 involving a review of boundaries, the descriptive content of the appraisals and the area specific policies and proposals. The Local Plan anticipates major change in or adjacent to parts of the Central Conservation Area but this is not expected or proposed to the same extent for the remainder of conservation areas. Promoting heritage assets through development could, for example, include provision of heritage information around a site whilst archaeological assessments are underway.

8.78 The Orwell Estuary provides an important ecological network and landscape setting for Ipswich and helps define its history. It is characterised by its broad expanse of water and its gently rolling, wooded banks. Outside Ipswich Borough, much of the land on the banks of the river falls within the Suffolk Coast and Heaths Area of Outstanding Natural Beauty. The transition between the built-up character of Ipswich and open countryside is quite sharply defined around most of the present Borough boundary, with the transition from urban to rural appearance and uses being clearly appreciable. The Orwell Estuary will be covered by the South East Inshore Marine Plan when it is completed (consultation took place early in 2018). This will set out priorities and directions for future development within the plan area, inform sustainable use of marine resources, and help marine users understand the best locations for their activities, including where new developments may be appropriate. An South East Inshore and South East Offshore Marine Plan was adopted on 2^nd April 2014 which covers an area adjacent to the Suffolk Coast north of the River Orwell. Early consultation with the Marine Management Organisation will be required where any work requiring consideration under the Marine Works (Environmental Impact Assessment) Regulations 2007 is to be undertaken. Proposals for development at the edge of the urban area should be informed by the Settlement Sensitivity Assessment (2018) which analyses the sensitivity of settlement fringes, their capacity to accommodate future development and priorities for the enhancement, protection, management and conservation of landscape areas.

8.79 For wildlife habitats, an ecological network approach has been adopted in accordance with the National Planning Policy Framework. Ecological networks are an effective way to conserve wildlife and biodiversity where habitats have become fragmented. They support its resilience to pressures such as urban development and climate change. The network includes internationally, nationally and local designated sites which are protected in accordance with the National Planning Policy Framework. Development in the vicinity of areas with nature / wildlife and geological designations must take into account the wider effects on those sites. The Council also recognises its biodiversity responsibility under the Natural Environment and Rural Communities Act 2006. This Act introduced the requirement for public bodies, in exercising their functions, 'to have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity'. The Anglian River Basin Management Plan sets out measures which aim to achieve the water body status objectives and wider objectives of the European Water Framework Directive no deterioration of waterbodies and ultimately improving all water bodies to a good standard by 2027. The Water Environment (Water Framework Directive) (England and Wales) Regulations 2017 require all public bodies, in exercising their functions so far as affecting a river basin district, have regard to the river basin management plan for that district.

8.80 Ipswich will see significant new building over the plan period. It is therefore essential that opportunities be taken through development to provide net gains in biodiversity and green infrastructure. Proposals should demonstrate how the development would contribute towards new green infrastructure opportunities or enhance the existing green infrastructure network as part of the development. New development must also secure ecological enhancements as part of its design and implementation, and should provide a biodiversity net gain that is proportionate to the scale and nature of the proposal. This could include green roofs or walls for insects and birds, wood piles for beetles, integrated nest boxes for birds, and in ecological networks can increase permeability of wildlife in new development through biodiversity enhancements. Therefore the policy will apply to all new developments in the Borough. Development at the Ipswich Garden Suburb will provide an opportunity to contribute to biodiversity. 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.

8.81 The Stour and Orwell Estuary Special Protection Area is protected under the Birds Directive due its importance for bird populations. The plan has been subject to an Appropriate Assessment under the Habitats Directive. This concluded that visitor numbers to the Orwell Estuary will increase as a result of growth in the Ipswich Strategic Planning Area and could adversely affect the Estuary's Special Protection Area for birds. Measures to avoid and mitigate any such potential impacts are included in the plan. There are also large areas of Inshore Marine Special Protection Area extending eastwards from the Suffolk and Essex Coast, which form part of the marine protected area identified in the South East Inshore and South East Offshore Marine Plan.

8.82 Scheduled Monuments are designated by the Secretary of State for Digital, Culture, Media and Sport under the Ancient Monuments and Archaeological Areas Act, 1979. Historic England administers and manages the scheduling and Scheduled Monument Consent process and advises the Secretary of State in making decisions. Scheduled monuments can be found on the National Heritage List for England, which is searchable online. Proposals affecting designated and non-designated Ipswich heritage assets should be informed by the Historic Environment Record for Suffolk maintained by the County Council which is also consulted on planning applications that could affect archaeology. Ipswich's archaeological legacy is important in helping to tell the town's story and will therefore be protected and managed in accordance with the NPPF and policies CS4 and DM14. Central Ipswich is an Area of Archaeological Importance, for which a development management approach is set out in policy DM14. An Urban Archaeological Database for Ipswich has been prepared and the Council has prepared a Development and Archaeology supplementary planning document to summarise information from the Ipswich Urban Archaeological Database and set out archaeological considerations for new developments.

8.83 Living ancient monuments such as veteran and near veteran trees in the ancient stage of their life are of interest biologically, aesthetically and culturally because of their age. Ancient and semi-natural woodlands and veteran trees are irreplaceable habitats of high biodiversity value and must be protected from development that would result in damage to or loss of any of these features.

8.84 Historic England also has a role registering historic parks and gardens. Whilst registration offers no additional statutory protection, they are designated heritage assets of considerable significance and an important material consideration in development management. Decisions about proposed development which would harm the significance of a designated heritage asset will be taken having regard to the NPPF.

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

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

8.87 The Council acknowledges the important social and economic role that the historic environment can play, both for existing communities through heritage led regeneration and as part of new development proposals. It is important that the significance of the Borough's heritage assets is taken into account as part of any future regeneration and opportunities are sought, wherever possible to enhance the heritage assets.

8.88 Soils play an important role in both urban and rural areas. In line with the National Planning Policy Framework, the Council will protect and enhance valued soils because soil is an essential finite resource that provides important ecosystem services.

8.89 The Council will encourage the conservation and efficient use of natural resources in order to work towards sustainable 'one planet' living in Ipswich. This will be implemented through the development management policy DM1 in Part C of this document. Historic England publishes advice on the application of Part L of the Building Regulations to historic and traditionally constructed buildings. In addition, new development will be required to minimise waste generated.

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

8.91 This policy supports plan objective 1.

POLICY CS5:
Improving Accessibility

8.92 Ipswich is planning for growth and ways therefore need to be found to optimise the accessibility of new developments without increasing congestion. The town benefits from being relatively compact, which lends itself to cycling and walking and the provision of full fibre (to the premises) broadband (FTTP).

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

8.94 If people are to be encouraged to walk, cycle and use public transport, to help the town achieve environmental and health objectives, then developments must be located and designed such that these modes rival the car for cost and convenience. It is also important to ensure that routes are more pleasant in their surroundings such as along avenues or ecological networks, and that cycle and pedestrian routes are safe. Policy CS2 sets out the strategy for the location of development and refers to mixed uses in larger development proposals.

8.95 A package of sustainable travel measures known as Travel Ipswich has been completed in Ipswich, delivering the expansion and improvement of bus facilities; an Urban Traffic Management and Control system; a Real Time Passenger Information system; and a detailed programme of improvements to walk/cycle routes and crossings in and around the town centre. However, air quality, congestion and obesity continue to be issues within Ipswich and therefore efforts to increase and support sustainable travel choices, and reduce the need to travel, for example by home working, need to be sustained.

8.96 The Local Transport Plan is under review and provides the opportunity for the next package of sustainable travel measures to be identified and implemented. This will occur through the Ipswich Transport Strategy, the preparation of which has been identified by the County Council as a priority. Traffic modelling undertaken to inform the Local Plan Review has supported the identification of measures needed across the Ipswich Strategic Planning Area to mitigate the traffic and air quality impacts of planned growth. These measures are included as appropriate in policy CS20. The development management policies in Part C of the plan ensure that accessibility is considered, and measures incorporated, in the context of new developments.

8.97 The Council is also developing a parking strategy which will address the quantity and quality of car and cycle parking provision in the town. The National Planning Policy Framework requires Councils to prioritise full fibre broadband connections to new and existing developments.

8.98 This policy is also aimed at ensuring the accessibility of the town centre and individual buildings and developments by everyone, including older people, people whose mobility is impaired and people with dementia. Planning can have a significant impact on the accessibility and inclusiveness of the built environment through the design of buildings and the public realm. The Planning Practice Guidance states that inclusive design can help older and disabled people live more independently, and benefit people with dementia (Inclusive Design section, June 2019). Policy DM12 provides the detailed policy for inclusive and accessible buildings and public spaces.

Live

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

8.100 It is divided into the following five policies:

POLICY CS7:

The Amount of New Housing Required

POLICY CS8

Housing Type and Tenure

POLICY CS9

(policy deleted)

POLICY CS10

Ipswich Garden Suburb (formerly Ipswich Northern Fringe)

POLICY CS11

Gypsy and Traveller Accommodation

POLICY CS12

Affordable Housing

8.101 These are addressed in turn below:

POLICY CS7:
The Amount of Housing Required

8.102 The Inspector's Report published in January 2017 after the examination of the last Ipswich Local Plan required the Council to undertake an urgent review, with neighbouring local planning authorities, of the amount of housing needed. The Council committed to this through the adopted 2017 Ipswich Local Plan, and the authorities jointly undertook a Strategic Housing Market Assessment. However, the Government has subsequently published a standard methodology for calculating housing need.

8.103 Joint working is taking place through the production of aligned local plans by Ipswich Borough Council, Babergh/ Mid Suffolk District Councils and East Suffolk Council for the Suffolk Coastal Local Plan area. This joint working has the support of the Ipswich Strategic Planning Area Board. A Statement of Common Ground has been published alongside this formal draft of the Ipswich Local Plan Review. Work is also ongoing on a Suffolk Framework for Growth, which the Council resolved on 6th March 2018 (report reference E/17/74) future versions of the Ipswich Local Plan would have regard to.

8.104 In July 2018, the Government published the revised National Planning Policy Framework (NPPF), which requires local planning authorities to use a standard method to quantify local housing need. The NPPF was further revised in February 2019 along with updated planning practice guidance. This advised that local planning authorities use the 2014-based household projections in their housing need assessments. The effect of this has been to reduce the housing need figure to 445 dwellings per annum 2018 to 2036, or 8,010 dwellings for the eighteen year period, as a starting point. Table 3 below sets out the housing land supply and minimum requirement figures as at April 2019, looking forward to 2036.

TABLE 3 HOUSING LAND SUPPLY AND MINIMUM REQUIREMENT AT 1^st APRIL 2019

		Number of dwellings	Discounted Numbers	Cumulative Numbers
1	Completions 1st April 2018 to 31st March 2019	223	-	223
2	Dwellings under construction	544	-	767
3	Dwellings with planning permission	846	761	1,528
4	Dwellings with a resolution to grant planning permission (subject to the prior completion of a Section 106 agreement)	424	382	1,910
5	Number of dwellings required on new site allocations and on windfall sites to 2036	6,100		8,010

TABLE NOTES

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

Line 2: Dwellings under construction at 31^st March 2019 - assumed that all will be completed over the plan period.

Line 3: Other dwellings with planning permission at 31^stMarch 2019 - assumed that 10% of these will not be completed.

Line 4: Dwellings with a resolution to grant planningpermission from the Council's Planning and Development Committee but which are awaiting completion of a Section 106 Agreement before planning permission is issued, at 31^st March 2019 - assumed that 10% of these will not be completed.

Line 5: To reach the minimum requirement of 8,010 dwellings by 2036, together with windfall sites, further land will need to be allocatedwithin the Borough for at least 6,100 new homes.

8.105 The revised Planning Practice Guidance is clear that the need figure generated by the standard method should be considered as the minimum starting point in establishing a need figure for the purposes of plan production. There could be circumstances in which it is appropriate to consider whether actual housing need is higher than the standard method indicates, for example, where growth strategies are in place or strategic level infrastructure improvements are planned which could drive an increase in housing need.

8.106 The Council does not consider that it should plan for a higher level of housing need than the standard method suggests.

8.107 National guidance in the NPPF is that Local Planning Authorities should set out their policies and strategies for delivering the amount and variety of housing land, to support the Government's objective of significantly boosting the supply of homes, and address the needs of groups with specific housing requirements.

8.108 This should include identifying a supply of specific, deliverable sites for years 1-5 from adoption with an appropriate buffer, and specific, developable sites or broad locations for growth for years 6-10 and where possible, for years 11-15. Where it is not possible to identify specific sites for years 6-10 and 11-15, broad locations for future growth should be indicated. Windfall sites will also contribute to the housing supply and these are defined in the National Planning Policy Framework as sites not specifically identified in the Local Plan. They normally comprise previously-developed sites that have unexpectedly become available.

8.109 Due to the constrained nature of the Borough boundary, the Council has a limited capacity for future development. The Council is actively working with neighbouring authorities to identify housing need across the Ipswich Housing Market Area and prepare aligned Local Plans to deliver it. The Council considers that the Ipswich housing need identified above can be met within the Borough. Housing delivery will be closely monitored across the Ipswich Strategic Planning Area. Ipswich Borough Council has published a Housing Delivery Action Plan to support delivery within the Borough.

8.110 Within the Borough, sites are allocated through the Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document, having regard to the strategy set out within this document, in CS10 and CS2. The Council has undertaken an update to the 2010 Strategic Housing Land Availability Assessment, which now includes employment land also as a Strategic Housing and Employment Land Availability Assessment (SHELAA) and is satisfied that sites within the Borough are capable of being delivered. The SHELAA will be periodically updated.

8.111 The phasing of housing sites will be informed by the findings of the SHELAA, infrastructure delivery and the preparation of master plans. The SHELAA informs the Council's housing trajectory. It is based on recent contact with developers and landowners. It is from this potential supply that site allocations are drawn. Within the tightly drawn boundary of Ipswich, options for the housing land supply are inevitably limited. Table 4 below provides a breakdown of the housing land supply. Delivery will be monitored closely through the Council's Authority Monitoring Report.

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

TABLE 4 ESTIMATED HOUSING DELIVERY FOR 2019-2036 EXCLUDING CURRENT PERMISSIONS AS AT 1^ST APRIL 2019

Area of Ipswich	%age (dwellings) Previously developed land	Total Additional dwellings 2019-2036
IP-One	100%	2,034
Rest of built up area	83%	716 (PDL:594)
Ipswich Garden Suburb (see policy CS10)	0%	3,268
Northern end of Humber Doucy Lane (see Policy ISPA4)	0%	496
Total 2019-2036 (excluding windfall)	40.3%	6,514 (PDL: 2,628)
Windfall sites 2022 – 2036	90%	700 (PDL: 630)
Total 2019-2036	45.2%	7,214 (PDL: 3,258)

POLICY CS8:
Housing Type and Tenure

8.113 National policy in the National Planning Policy Framework calls for a range of homes to be provided in terms of tenure, type and size in order to support the creation of strong, vibrant and healthy communities. The size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies. This demands an understanding of the existing dwelling stock, and the nature and needs of existing and projected future households. It also requires some understanding of the Ipswich housing market. A Strategic Housing Market Assessment (SHMA) Part 2 report of the Ipswich housing market area (HMA) was published in May 2017 (updated September 2017 and January 2019) and provides evidence to support policy preparation on this matter.

8.114 A range of types, sizes and tenures of properties is needed across the plan period, rather than a significant majority of one type at one time. The approach set out in this policy will help to ensure a variety of provision. The Strategic Housing Market Assessment (SHMA) is reviewed approximately every three years. It analyses forecast household growth by characteristics such as age and size, and considers the existing housing stock. Whether it is up to date will be considered in relation to when it was prepared and any significant changes in the market since its preparation.

8.115 The NPPF (paragraph 61) requires Councils to plan for the size, type and tenure of housing needed for different groups in the community. The policy above addresses the needs of households of different sizes, including families with children and single person households, and those wishing to build their own homes. Policy DM12 addresses the need for homes suitable for people with disabilities. Affordable housing is addressed through policy CS12 (and CS10 at Ipswich Garden Suburb) and the needs of Gypsies and travellers are addressed through policy CS11.

8.116 Ipswich has a higher than average student population. Between 2001 and 2011, this population grew more quickly than in the Eastern Region or England. The SHMA reports over 4,500 full and part-time students studying at the University of Suffolk, equating to a full-time equivalent of 3,200 students. Just over 15% of students require accommodation, with 573 resident in on-campus halls of residence, 137 living in off-campus halls of residence and 37 in the local private rented sector. Some 70% of the student population are from the local area and the majority of these are thought to be living at their parents' home whilst studying. The private rented accommodation occupied by students is located within one mile of the waterfront campus and there are no notable problems with students in relation to housing currently. The influence on the local housing market of the student population is not expected to alter over the plan period with any growth in numbers likely to be accommodated by the private rent sector.

8.117 The proportion of older person households, in which everyone is aged over 65 is lower in Ipswich at 19.1% than in the HMA as a whole (24.5%), the Eastern Region (22.3%) and England (20.5%). However, the SHMA forecasts that, over the plan period, this population will increase by 57.8% across the HMA. In terms of specialist dwellings for older persons (Class C3b), the SHMA identifies that there is likely to be a surplus of 185 sheltered and extra care housing units by 2036 in Ipswich, such that it may be necessary to convert some of this housing into mainstream accommodation. Therefore, policy CS8 does not include specific provision for specialist homes for older persons. Where applications are made for assisted living and residential care provision, early discussion will be required between the applicant and the National Health Service (NHS) to ensure that impacts of residential care provision on the NHS are considered appropriately.

8.118 The mix of new housing that would best address the needs of the local population by tenure for Ipswich by 2036 is: 20.5% of housing to be affordable rented, 63.5% market housing including private rent, and 16.1% affordable home ownership (including shared ownership and Starter Homes). However, these figures do not take into account the funding that will be available to help provide subsidised housing and viability and therefore this profile is set out as a guide to the overall mix of accommodation needed.

8.119 Table 5 below uses data from the Ipswich SHMA Part 2 Update January 2019 (Appendix 4) to prioritise the size of additional homes needed across the Local Plan period, by tenure. The Council will have regard to this table in determining the appropriate mix of dwelling sizes in major residential developments. Whilst there will be a need for dwellings of all the sizes shown, the Council will expect proposals to include some dwellings that meet the high priorities, where practicable.

Table 5 - Size Priorities by Tenure for the Provision of New Dwellings

	1-bedroom	2-bedroom	3-bedroom	4 or more bedrooms
Market homes	lower	medium	high	high
Affordable home ownership	medium	high	high	lower
Private rent	medium	high	high	high
Affordable/social rent	medium	high	medium	high

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

8.121 This policy links closely with policy CS2, which sets out a locational approach to development density, policy CS7 in setting out the housing requirement, and policy DM23 which covers housing density. Density is inextricably linked with the dwelling types and sizes that a development can incorporate together with the amount of land needed to meet the housing requirement. Central sites should be high-density developments (containing a higher proportion of flats); sites in or close to district centres should be medium-density developments (a mix of flats and houses or town houses); and sites elsewhere should be low-density developments (containing a higher proportion of houses).

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

8.123 Self Build or Custom Build is defined through the National Planning Policy Framework as housing built by an individual, a group of individuals, or persons working with or for them, to be occupied by that individual. Such housing can be either market or affordable housing. It is seen to support the individual self-builder, or community group for the delivery of low cost sustainable housing on small scale infill or windfall sites, or as part of large-scale planned development, for example at the Ipswich Garden Suburb, and will help in the delivery of a wide choice of high quality homes. Under section 1 of the Self Build and Custom Housebuilding Act 2015, local authorities are required to keep a register of those seeking to acquire serviced plots in the area for their own self-build and custom house building (which may or may not be meeting affordable housing need). They are also subject to duties under sections 2 and 2A of the Act to have regard to this and to give enough suitable development permissions to meet the identified demand. At September 2018, the Ipswich self build register contains 70 names.

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

8.125 This policy supports plan objectives 3 and 4.

POLICY CS10:
Ipswich Garden Suburb

8.126 The presumption in favour of sustainable development requires that strategic policies should, as a minimum, provide for objectively assessed needs for housing. Paragraph 72 of the National Planning Policy Framework states that the supply of large number of new homes can often be best achieved through planning for larger scale development, such as extensions to existing towns, provided they are well located and designed and supported by the necessary infrastructure and facilities.

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

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

Land use	Approximate area in hectares
Public Open space, sport and recreation facilities including dual use playing fields	40
A Country Park (additional to the public open space above)	24.5
Residential development of approximately 3,500 dwellings	100
A District Centre located within Fonnereau Neighbourhood, providing: i. A maximum of 2,000 sq m net of convenience shopping, to include a medium/large supermarket between 1,000 and 1,700 sq m net; ii. Up to 1,220 sq m net of comparison shopping; iii. Up to 1,320 sq m net of services uses including non-retail Use Class A1, plus A2 to A5 uses; iv. Healthcare provision; v. A library; vi. A police office; vii. A multi-use community centre; and viii. Residential accommodation in the form of appropriately designed and located upper floor apartments.	3.5
Two Local Centres located in Henley Gate and Red House neighbourhoods, together providing: i. Up to 500 sq m net of convenience retail floorspace ii. Up to 600 sq m net of comparison retail floorspace; and iii. Up to 500 sq m net of service uses including non-retail Use Class A1, plus Classes A2 to A5; and iv. Community Centre use (which could include Country Park Visitor Centre use) located in Henley Gate	1.5 including 0.5ha per local centre in the Henley Gate and Red House neighbourhoods and 0.5ha within the Henley Gate neighbourhood for the country park visitor centre and community centre.
A secondary school within the Red House neighbourhood with access from Westerfield Road	9
Three primary schools (one in each neighbourhood)	6

8.129 The indicative capacity at the Northern Fringe (Ipswich Garden Suburb) identified in the Strategic Housing Land Availability Assessment: has been reduced to 3,500 dwellings following early capacity work on the Ipswich Garden Suburb supplementary planning document. The Council has identified a need for 8,010 dwellings between 2018 and 2036, and the Garden Suburb forms a key component of meeting this need. The Council will work with Babergh, Mid Suffolk and Suffolk Coastal District Councils to ensure optimum sustainable distribution of housing within the Ipswich Strategic Planning Area, bearing in mind the amenity and ecological value of the countryside outside the Borough boundary as well as within it, and the increased congestion effects of any development outside the Borough boundary.

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

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

8.132 The infrastructure requirements at the Garden Suburb will be significant and include new roads ecological networks and green corridors, new public transport routes and services, green infrastructure such as allotments and sports facilities, new schools, new recreation provision, healthcare provision and local shopping facilities. This infrastructure can also deliver benefits to the existing communities in the area and help to sustain them. A comprehensive and coordinated approach to the development of the Garden Suburb is required to ensure the proper planning and delivery of this infrastructure. The Council will consider using its compulsory purchase powers, where necessary, to enable comprehensive development and infrastructure delivery to take place.

8.133 The detailed infrastructure requirements of the development of approximately 3,500 dwellings at the Garden Suburb are identified in Table 8B in Chapter 10 of the Core Strategy. All infrastructure items identified through this policy and Table 8B have been identified by the Council and relevant providers as necessary to make the development acceptable in planning terms for various reasons related to ensuring sustainable development, mitigating transport impacts, meeting Habitat Regulations 2017 (as amended) requirements and ensuring future residents are well served by the necessary educational and social facilities essential to any successful residential development of this nature and scale. Each Ipswich Garden Suburb planning application will comply with the Community Infrastructure Levy Regulations tests. Table 8B divides the infrastructure into two categories:

1. Strategic Infrastructure, which is required to mitigate the cumulative impact of, and serve the whole of, the Garden Suburb development.
2. Neighbourhood Infrastructure, which refers to local infrastructure required primarily to serve the needs of the residents of the neighbourhood in which it is located.

8.134 The purpose of Table 8B is to set a clear steer on what infrastructure should be provided. The trigger points for the delivery of the infrastructure items identified through Table 8B will be determined as part of the preparation of the Infrastructure Delivery Plan. This is intended to provide assurance as to how the development of the Ipswich Garden Suburb will be appropriately sequenced and supported by the necessary infrastructure. The triggers will be guided by:

 Advice from key stakeholders in light of available evidence concerning existing capacity, likely impact and mitigation required, for example through the Transport Assessment;

 The likely sequencing and management of development identified through Strategic Phasing Plan documents;

 The desire to create cohesive neighbourhoods in the interest of securing a sustainable development pattern and consideration of what is necessary at various stages of the development in order to deliver a sustainable form of development;

 Ensuring that the development is viable and deliverable; and

 The availability of appropriate land.

8.135 Prior to development on the Ipswich School Playing Fields site, replacement sports facilities will be required to be first provided in accordance with policy DM5. The site for replacement playing fields is allocated to the west of Tuddenham Road and north of the railway line.

8.136 The total number of dwellings likely to be accommodated within the Garden Suburb is approximately 3,500. In order to ensure that any development proposed for this area conforms to a coherent plan, work on the supplementary planning document commenced in early 2012 following the adoption of the Core Strategy in December 2011. Any planning application for the development of the area will be required to have regard to the content of the Supplementary Planning Document, which was adopted in March 2017. This is to ensure the proper long term planning of the Ipswich Garden Suburb area to deliver sustainable, integrated development. Key conclusions about infrastructure provision at the Garden Suburb from the Secretary of State's dismissal of the appeal by Mersea Homes in September 2010 are reflected in the policy above.

8.137 The Council has undertaken extensive viability work with input from the various development promoters at Ipswich Garden Suburb. This concludes that 31% affordable housing calculated as a percentage of dwellings is deliverable across the whole scheme. The Council will seek to secure 31% affordable housing across the scheme which would equate to 1,085 affordable houses in a total scheme of 3,500 homes. It is further recognised that the investment needed in infrastructure during the early phases of development may necessitate a lower percentage of affordable housing, but the viable percentage will increase as the need for infrastructure investment decreases in the later phases to allow the overall target of 31% across the Ipswich Garden Suburb. The Council recognises that the levels of affordable housing will be subject to more detailed viability work as part of the planning application process, and for those proposals which include a significant scale of development, then pre-implementation re-testing of viability will be expected for individual applications within a proposal. In recognition of the investment and risk certain development promoters will be making in the early phases of their developments, a 35% cap on the percentage of affordable housing for each phase will be applied (i.e. phases N1(a), N1(b), N2(a), N2(b), N3(a) and N3(b) as set out in the Ipswich Garden Suburb Viability Assessment by Gerald Eve, June 2016). It may be appropriate for certain components of each phase to deliver more that 35% affordable housing in order to deliver the overall target of 31%. These provisions would be secured through the relevant planning obligations. The development phases are illustrated on the map below.

8.138 This policy supports plan objective 3.

Map IGS1 Phases of development at Ipswich Garden Suburb as defined through the Infrastructure Delivery Plan adopted February 2017

POLICY CS11:
Gypsy and Traveller Accommodation

8.139 Local housing authorities will continue to decide how best to undertake their duties to assess the needs of all their residents and those who resort in their area. This will be in accordance with the legal obligations in the Equality Act 2010. National planning policy for Gypsies and Travellers is set out in Planning Policy for Traveller Sites (2015) and requires planning authorities to use their evidence to plan positively to meet the needs of Gypsies & Travellers and Travelling Show People and Boat People.

8.140 Ipswich has 43 permanent pitches for Gypsies and Travellers at present, and the Gypsy, Traveller, Travelling Showpeople and Boat Dwellers Accommodation Needs Assessment (ANA) 2017 identifies the Borough's needs to 2036. In addition, national guidance requires the Core Strategy to include a criteria based policy to guide the siting and location of sites for Gypsies and Travellers. The accommodation needs of Gypsies and Travellers need to be considered alongside those of the 'settled' population. The revised national Planning Policy for Traveller Sites, published in August 2015, amends the definition of Gypsies and Travellers for planning purposes to exclude those who have ceased travelling permanently.

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

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

8.143 Sites will be sought to meet the joint needs of Ipswich and neighbouring authorities for permanent pitches within the Ipswich Strategic Planning Area. Need for Ipswich and its neighbouring authorities was identified through the Gypsy, Traveller, Travelling Showpeople and Boat Dwellers Accommodation Needs Assessment (ANA) carried out in 2017 by RRR Consultancy Ltd. The 2017 ANA identified a need for 27 pitches in Ipswich Borough to 2036, out of a need for 52 pitches across the five local authority areas included in the assessment (Ipswich, Babergh, Mid-Suffolk, Suffolk Coastal and Waveney). Of the 27 pitches needed in Ipswich, 13 are needed between 2016 and 2021, 4 between 2021 and 2026, 5 between 2026 and 2031 and 5 between 2031 and 2036.No need was identified in Ipswich for the other types of provision.

8.144 The Council will work with Suffolk authorities to meet the joint transit (short stay) and permanent needs and the needs of travelling showpeople. The ANA identifies a need for three short stay sites across the study area.

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

8.146 The Council will work with the Gypsy and Traveller communities to ascertain need in particular locations, prior to the identification or allocation of sites. Pitch demand will be kept under review.

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

8.148 Caravans, mobile homes and park homes intended for permanent residential use are classed as 'Highly Vulnerable' for flood risk as defined in Table 2: Flood Risk Vulnerability Classification of the Planning Practice Guidance, are not permitted in Flood Zone 3 and require the exception test in Flood Zone 2. This is because, these developments are very difficult to make safe through raised flood levels.

8.149 This policy supports plan objectives 3 and 10.

POLICY CS12:
Affordable Housing

8.150 Affordable housing is defined through the National Planning Policy Framework (NPPF) glossary as housing for sale or rent, for those whose needs are not met by the market, including housing that provides a subsidised route to home ownership or is for essential local workers. The definition continues with a detailed breakdown of four types of provision:

• affordable housing for rent, which includes Social Rent and Affordable Rent.
• Starter Homes, which are new build homes for young, first-time buyers (below 40 years) to buy with a minimum 20% discount off the market price;
• Discounted market sales housing which is sold at a discount of at least 20% below local market value; and
• Other affordable routes to home ownership including shared ownership, equity loans, other low cost homes for sale, and rent to buy.

8.151 The NPPF requires planning policies to reflect the type and tenure of affordable housing needed. The Ipswich Strategic Housing Market Assessment (SHMA) 2017 Part 2 Report identifies that the total annual affordable housing need in Ipswich is 239 households per year, which represents 47.9% of the annual projected household growth in the Borough between 2014 and 2036 identified through the SHMA and around 50% of the need identified using the standard method. Development Viability remains challenging in Ipswich and this will need to be reflected in the policy requirements.

8.152 The SHMA identifies the housing tenure mix that would best address the needs of the local population. It suggests an overall requirement for 19.5% of housing to be Affordable Rented and 14.8% affordable home ownership. This does not take into account the funding that will be available to help provide subsidised housing.

8.153 The Ipswich Strategic Housing Market Assessment Part 2 Report 2017 and updated 2019 indicates that the mix of housing that would best address the needs of the local population would be an overall requirement for 20.5% of new homes to be affordable housing for rent (including social rent) and 16.1% affordable home ownership (including Shared Ownership and Starter Homes). Thus, affordable housing need represents approximately 36% of overall housing need. However, in setting the appropriate affordable housing requirement for the plan, the Council needs to take into account the funding available to help provide subsidised housing and the viability of delivery in Ipswich. The Ipswich Whole Plan Viability Report indicates that for most types of site (greenfield or brownfield and large or small), at least 15% affordable housing provision is a realistic and deliverable requirement other than in wholly or mainly flatted developments in the lower value area. Expressing the requirement as a minimum reflects the level of need in Ipswich and provides a starting point for negotiation where development values may support higher provision.

8.154 The National Planning Policy Framework 2019 indicates that at least 10% of homes should be available for affordable home ownership, unless this would significantly prejudice the ability to meet the identified affordable housing needs of specific groups. Paragraph 61 indicates that different groups can include those who require affordable housing. The SHMA shows that the affordable housing need in Ipswich is primarily for affordable housing for rent. Therefore, the tenure mix set out in the policy is considered to best meet local needs.

8.155 The Council will aim to supplement affordable housing provision through private developments by developing its own sites and providing in excess of 15% affordable housing by number of dwellings. This will contribute to meeting the policy requirement for affordable housing on sites outside the Ipswich Garden Suburb to comprise at least 15% of new homes over the Plan period.

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

8.157 The Ipswich 2005 Key Worker Study recognised the need for appropriate housing for key workers, but also found that key workers' wage rates compared well with other pay levels in the local economy. More recently, the 2017 Ipswich Strategic Housing Market Assessment (SHMA) Part 1 Report found that Ipswich has better affordability (house prices in relation to workplace earnings) than both the rest of the Ipswich Housing Market Area and the England benchmark (SHMA Chapter 6). For this reason, we believe that current affordable home ownership arrangements (e.g. through Help to Buy) meet the needs of key workers locally. Therefore, whilst the policy does not provide specifically for key workers, their needs would be met through the affordable housing provision this policy requires.

8.158 Policy CS17 sets out the approach to delivering infrastructure in the Borough and re-iterates the legislation governing the Community Infrastructure Levy that affordable housing will remain outside the standard charge system.

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

8.160 The policy implements plan objective 3.

WORK

8.161 It is equally important that the Council plans for employment issues as well as for new housing. This section addresses the strategic issues for jobs growth within Ipswich and the Ipswich Strategic Planning Area to 2036.

8.162 It is divided into the following two Policies:

Policy CS13:

Planning for Jobs Growth

Policy CS14:

Retail Development and Main Town Centre Uses

8.163 These are addressed in turn below.

POLICY CS13:
Planning for Jobs Growth

8.164 Whilst the focus of monitoring and meeting delivery targets is generally on residential development at a national level, it is essential that housing growth in Ipswich is supported by employment growth.

8.165 Ipswich is a key economic driver of the Ipswich Strategic Planning Area within the Suffolk Economy. Jobs are defined as the Total Employment Jobs (000s) as set out in the EEFM (August 2017).

8.166 The Council has updated its economic evidence through joint studies for the Ipswich Economic Area. The Economic Sector Needs Assessment (ESNA) 2017 identifies the amount of land needed for B class employment development in the Borough, and the Employment Land Supply Assessment 2018 assesses the quality of employment land within the Borough. The Employment Land Supply Assessment has informed the Strategic Housing and Employment Land Availability Assessment. As a result, some land previously allocated or protected for employment uses has been re-allocated to residential or mixed uses through the Local Plan Review. The Employment Sector Needs Assessment identifies a need for 28.3ha of employment land in Ipswich 2014 to 2036. A pro rata adjustment to update the baseline date to 2018 results in a calculation of 23.2ha.

8.167 The allocation and protection of employment land through the Local Plan complements the Borough's updated Economic Development Strategy 2018, which has the overarching goal to improve the economic competitiveness of Ipswich and all it has to offer. This aligns with the Industrial Strategy 'Building a Britain Fit for the Future' which aims to create an economy that boosts productivity and earning power throughout the UK. The Ipswich Economic Development Strategy is based around four Strategic Priorities. These are;

• Strategic Priority 1: Promote Ipswich as a prominent and sustainable place to invest and grow businesses.
• Strategic Priority 2: Stimulate a successful town centre and retail experience.
• Strategic Priority 3: Inspire Ipswich to be the best place to live, work, learn and visit.
• Strategic Priority 4: Prioritise Ipswich's strategic Infrastructure.

8.168 The ESNA (2017) anticipated that between 2014-2036 Ipswich Borough Council would experience a jobs growth of 19,040 jobs. When re-calculated on an annual basis to cover the emerging Local Plan period (2018-2036) this equated to a total jobs forecast of 15,577 jobs. The above results were arrived at using the 2016 East of England Forecasting Model (EEFM) dataset. However, since the 2016 EEFM dataset was used in the 2017 ESNA, the 2017 EEFM dataset has been released. The jobs forecast for Ipswich over the Plan Period when using the 2017 EEFM dataset shows a significant reduction to 9,318 jobs (-40%) when compared to the 2016 EEFM output of 15,577 jobs. Paragraph 16 of the NPPF (2019) states that plans should be prepared positively in a way that is aspirational but deliverable and the standardised methodology for housing has shown a reduction in the amount of housing required over the plan period compared to previously identified objectively assessed needs. The effect of the 2017 EEFM dataset release on the jobs forecast for the other ISPA authorities results in a decrease as well although less significant in terms of the proportion of job changes than Ipswich. In addition, the other authorities have also allocated amounts of land for employment that are considerably higher than the baseline level established through the 2017 ESNA. Overall, due to the lower levels of housing growth set out in the standardised methodology and the significant reduction in jobs forecast in the 2017 EEFM, the Council has selected an aspirational but deliverable jobs target of approximately 9,500 jobs.

8.169 The Economic Strategy for Norfolk and Suffolk has been developed by the New Anglia Local Enterprise Partnership (LEP) and endorsed by the Council. The overall objective of the LEP's strategy is to generate growth across all sectors, focusing on creating high value, highly skilled jobs and industries, whilst also providing the technical skills, access to innovative techniques and support that all businesses and the wider workforce needs to succeed. Ipswich has been identified as one of six 'Priority Places' in the Economic Strategy for Norfolk and Suffolk, as evidence shows there are significant opportunities and commitment for continued growth within the town. The plan sets out key development and investment targets for Ipswich. The high level ambitions set out in the Economic Strategy for Norfolk and Suffolk are supported by the Ipswich Borough Council Economic Development Strategy. The Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document will translate the overall land requirement into sites. The Council will ensure that enough land is available, including a variety of site sizes and locations to suit different employment-generating activities. Appropriate employment-generating sui generis uses are defined through policy DM33.

8.170 It should be noted that the jobs growth aspiration covers all sectors and not just the employment use classes of B1 business, B2 general industry and B8 warehousing and distribution.

8.171 In allocating sites for employment development, the Council will take account of the sectors projected to have the highest jobs growth over the plan period as identified in the Suffolk Growth Strategy and those growth sectors identified in the New Anglia Local Enterprise Partnership Economic Strategy for Norfolk and Suffolk (2017). These include:

 advanced manufacturing and engineering;

 energy;

 information and communication technology, tech and digital creative;

 financial services and insurance;

 Advanced agriculture food and drink;

 transport, freight and logistics;

 life sciences and biotech;

 visitor economy – tourism and culture; and

 construction and development.

8.172 The sectors which are particularly well represented in Ipswich are: information and communication technology, tech and digital creative; financial services and insurance; and transport, freight and logistics.

8.173 Office uses are directed to the town centre through the approach to the location of development set out in policy CS2. This will further be reflected in site allocations to be made in the Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document Review and is in accordance with the National Planning Policy Framework, which defines offices as a town centre land use. Economic growth and home working are also supported through policy CS5 which supports the provision of full fibre broadband to new development within the Borough.

8.174 The tourism sector, education sector and Ipswich Port are significant sectors in Ipswich. New development should be sensitive to existing uses including those at the Port of Ipswich and avoid potential impacts which may prejudice the continued operation of the Port. Policies elsewhere in this plan and/or the Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document set out the approach to arts, cultural and tourism provision in the town, the Education Quarter and employment areas including the Port. The Council will support the University of Suffolk by safeguarding the campus for uses related to its operation.

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

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

POLICY CS14:
Retail Development and Main Town Centre Uses

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

8.178 Within the Ipswich Strategic Planning Area the population is forecast to grow over the plan period, which will generate new retail expenditure. However, neighbouring centres such as Colchester and Bury St Edmunds have both enjoyed more recent investment in town centre retailing. In addition, there are other pressures on the centre such as the general decline in the performance of the high street, forecast business rate increases and store closures in the near future, nearby out of town retail parks largely outside the Borough, and internet shopping. Recent evidence and government policy encourages town centres to create environments that successfully complement shopping with other uses, such as food and leisure uses, in a way that sets them apart from online shopping or out-of-town retail parks. Therefore there is no room for complacency in planning to maintain and enhance Ipswich's role as a regional centre.

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

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

8.181 The Ipswich Retail and Commercial Leisure Study 2017 identified the following needs for the Borough in 2036:

 There is no need for comparison goods (non-food) retailing floorspace in the short-term up to 2021.

 in the medium-long term there is significant capacity of at least 34,800sqm net for new town centre comparison goods (non-food) retailing to 2036;

 additional capacity of at least 1,600 sq. m net convenience goods retail floorspace;

 a need for improvements to the existing retail stock;

 limited capacity for additional convenience (food) retailing;

 town centre environmental improvements, enhancements to the linkage between the town centre and the Waterfront, and, implementation of a marketing strategy;

 limited capacity for higher brand national multiple comparison retailing;

 a need for an additional department store to anchor the town's retail offer;

 a need for improved food and drink uses within the town centre, prioritised outside the primary shopping zone;

 a need to promote existing arts and cultural activities and improving the marketing of this;

 provision of a five star hotel with a conference venue;

 boost the evening economy through considering more leisure activity within the centre; and

 a need for large and modern shop units to satisfy the needs of major retail and leisure operators.

8.182 An amended Central Shopping Area with additional retail site allocations will go some way to addressing these gaps in the offer, subject to general market conditions. Sites will be allocated through the Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document (policy SP10). In addition to the allocation of sites, the amount of net comparison floorspace proposed takes into account the scale of housing growth set out through policy CS7 and vacant units present in the Central Shopping Area, such as the former British Home Stores building (3,316 sq. m net). Clearly delivery will be the key to success, and the Council will work with others and through its own land holdings and as local planning authority to achieve it. In addition the Council will evaluate the practicalities of improving evening access in the principal pedestrianised streets after normal trading hours, to encourage the use of facilities in the evening.

8.183 The Council will work with Ipswich Central, landowners and other partners to develop an active strategy to bring vacant premises in the town centre back into active use or, at a minimum, to introduce a scheme to make vacant premises look more visually attractive. Environmental enhancements and urban greening in the town centre are supported but must have consideration as to the impact on CCTV provision throughout the town.

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

8.185 The Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document amends the Central Shopping Area south-western boundary from that shown in the 2017 Local Plan to include parts of Princes Street, and exclude the former police station site at Elm Street. Enhancing the town centre and planning for it to be multi-functional forms an important part of the strategy for urban renaissance in Ipswich over the plan period.

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

8.187 This policy implements plan objective 5.

LEARN

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

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

POLICY CS15:
Education Provision

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

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

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

8.192 Ipswich Borough Council has worked with Suffolk County Council to identify where new or extended primary and secondary school provision, and early years provision, will be needed over the plan period, in accordance with paragraph 94 of the National Planning Policy Framework. The Council has taken a positive approach to identifying sites for such provision through policy CS10 of the Core Strategy and Policies Development Plan Document Review and policy SP7 of the Site Allocations and Policies (incorporating IP-One Area Action Plan) development Plan Document.

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

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

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

8.196 Measures identified to mitigate the impact of traffic on congestion and air quality could assist in ensuring sustainable travel to educational establishments and new education development will be expected to encourage sustainable means of transport. This policy supports objectives 5 and 9.

PLAY

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

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

POLICY CS16:
Green Infrastructure, Sport and Recreation

8.199 Ipswich contains a variety of public and private open spaces, sport and recreation facilities that serve a range of different functions. The strategic spaces, ecological networks, green corridors and facilities contribute fundamentally to the character and appearance of the town, and to quality of life. Examples include: the River Gipping corridor, the importance of which is recognised through the River Strategy; Belstead Brook Park; Orwell Country Park; and the large town parks such as Christchurch Park, Holywells Park, Chantry Park and Bourne Park. There are also smaller local spaces and facilities, which are essential for sustaining communities. The Ipswich Open Space, Sport and Recreation Study 2009 (as updated in 2017) identifies all the different types of open space, sport and recreation facility. Open space provision is generally lowest in the north of the Borough, with an under-provision of parks and gardens in the North West and North East Area Forum areas, amenity green space in the North East area, and natural and semi-natural green space in the North West, Central and North East areas. Other deficits affect more of the Borough, for example there is a significant shortfall in provision for young people across the Borough (such as skateparks, kickabout areas and youth shelters).

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

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

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

8.203 A development management policy in Section C of this document and Appendix 4 set out the local standards of provision of open spaces, sport and recreation facilities, based on the Ipswich PPG17 Study, which has been updated by the Council's Parks and Open Spaces team. The infrastructure plan in Section D of this document sets out the strategic green infrastructure needs. The Council recognises that it will need to work with neighbouring local authorities to implement this, as realistically parts of any such network will be outside the Borough boundary. Strategic needs were identified by the Haven Gateway Green Infrastructure Strategy and the Council will consider the recommendations in planning future provision. In relation to the proposed 'green trail', the Council will work with neighbouring local authorities to address cross boundary green infrastructure provision and identify sites or routes later in the plan period.

8.204 Open spaces can perform more than one function. An important role for some open spaces will be to act as flood water storage areas or flood paths. Flood risk assessments should where possible and appropriate, identify areas in valley bottoms at risk of flooding as flood management assets and keep them open. Natural flood management can help to reduce flooding by working with natural process, reconnecting watercourses with flood plains to enhance flood storage in times of need and taking opportunities to restore watercourses to a naturalised state. This should be considered and incorporated into developments whenever opportunities arise. Such measures can provide benefits in terms of biodiversity, amenity, health and wellbeing and should be incorporate into the scheme design from the outset.

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

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

8.207 The Council, working jointly with the other local authorities in the ISPA, have been working on the Recreational Avoidance and Mitigation Strategy (RAMS) to mitigate the pressure caused by new developments on the internationally designated Special Protection Areas, Special Areas of Conservation and Ramsar sites. The partnership work, supported by Natural England, has established a strategy to mitigate the impacts and is due to be supported by a Supplementary Planning Document (SPD) that will provide further details in respect of cost implications and subsequent implementation. It should be noted that there will be instances where on-site mitigation is required in addition to a financial contribution towards the RAMS, in consultation with Natural England, for example the Ipswich Garden Suburb Country Park.

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

8.209 This policy implements plan objective 8.

INFRASTRUCTURE

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

Policy CS17:

Delivering Infrastructure

Policy CS18:

Strategic Flood Defence

Policy CS19:

Provision of Health Services

Policy CS20:

Key Transport Proposals

POLICY CS17:
Delivering Infrastructure

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

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

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

8.214 Infrastructure can take many different forms. Appendix 3 to this plan lists the types of infrastructure referred to in this policy.

8.215 Growth requirements across the Borough will place additional pressure on existing infrastructure and will therefore require improvements to be made to existing infrastructure, and the provision of new infrastructure. A number of pressures can be relieved through site-specific provision such as open space, children's play areas and the provision of affordable housing. However, there are other infrastructure improvements and requirements that cannot always be accommodated on-site, or that relate to strategic off-site facilities serving the whole neighbourhood or Borough. It is therefore considered appropriate to pool developer contributions towards off-site provision to help ensure its delivery. Table 8A in Chapter 10 identifies the infrastructure proposals required to support growth. Development may need to be phased to ensure the provision of infrastructure in a timely manner. Conditions or a planning obligation may be used to secure this phasing arrangement.

8.216 Responsibility for the delivery of infrastructure will be shared between developers, Ipswich Borough Council and key partners such as the New Anglia Local Enterprise Partnership, utilities companies, Highways England, Suffolk County Council, neighbouring local authorities, the Environment Agency, Homes England, Natural England and local community groups. Transport mitigation measures are identified through the Ipswich Strategic Planning Area (ISPA) Local Plan Transport Mitigation Strategy and policy CS20. They may be secured in different ways: the provision of site-specific physical transport infrastructure and sustainable travel measures, secured through section 106 and section 278 agreements as appropriate, and financial contributions towards strategic transport measures secured through section 106. A section 278 agreement is an agreement made between a developer and the highway authority under the provisions of the Highways Act 1980, which enables works to a public highway.

8.217 The Council is committed to securing a high quality communications infrastructure. Developers of all new sites (residential and non-residential) should engage with broadband providers to ensure new development is capable of delivering at least ultrafast broadband as part of the build process.

8.218 The Habitats Regulations Assessment identifies a range of measures to ensure that potential impacts of increased recreational disturbance within Special Protection Areas and Special Areas of Conservation within and outside of Ipswich Borough are mitigated. This relates to mitigating the cumulative effect of housing growth across Ipswich Borough, in combination with housing growth in Suffolk Coastal district. The measures include the provision of the Country Park or similar high quality provision to the north of Ipswich, delivering parts b, d, e, g and h of policy CS16, production and implementation of visitor management plans at key sites and a monitoring programme to assess visitor impact over time. The Council has, with neighbouring authorities, prepared a Recreational Avoidance and Mitigation Strategy, which specifies the measures required and how these will be delivered. The strategy will be supported by a supplementary planning document setting out the charges to be applied to development.

8.219 The Council has identified through its Housing Delivery Action Plan that delays in completing S106 legal agreements is hampering housing delivery in the Borough. The Council has committed to reviewing its S106 procedures and will refuse applications where the legal agreement is not actively pursued through to completion.

POLICY CS18:
Strategic Flood Defence

8.220 Much of central Ipswich lies within the tidal floodplain of the River Orwell. Existing flood defences are subject to a continuing schedule of improvements to make the defences fit to resist rising sea levels in the future.

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

1. raising the lock gates at the entrance to the Wet Dock - this was done in December 2008;

2. raising the river walls on the east and west banks to the south of the Island Site - completed July 2014; and

3. installing a tidal flood barrier in the New Cut at the southern end of the Island Site – completed February 2019.

8.222 The Strategic Flood Defence Management Plan for Ipswich is part of a long term (100 year) plan and will include repairs to existing tidal and fluvial defences upstream of the barrier. The strategy is being planned to avoid the need to raise the level of these defences.

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

8.224 The Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document will need to have particular regard to the flooding issues. The DPD will identify those sites at risk and the Ipswich Strategic Flood Risk Assessment (SFRA) Level 2 will inform allocations in this area and identify any residual risks following completion of the flood barrier.

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

8.226 The Council will continue to work with the partner organisations to ensure the remaining elements of the Strategic Flood Defence Management Plan for Ipswich are completed. In the interim period it is recognised that the Council needs to work with its partners to put in place better arrangements to cope with emergency planning scenarios associated with flooding.

8.227 This policy implements objective 7.

POLICY CS19:
Provision of Health Services

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

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

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

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

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

8.233 This policy supports plan objectives 9 and 10.

POLICY CS20:
Key Transport Proposals

8.234 Strategic and local transport measures are important in enhancing the connectivity of Ipswich to other places and enabling people to move around within the town. An Integrated Transport Strategy for Norfolk and Suffolk was adopted by the New Anglia LEP board and partners in summer 2018 and sets out high level goals for transport. At a county level, the Suffolk Local Transport Plan is currently under review.

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

8.236 Public transport is an important part of the current and future transport packages. More details on these proposals will be included in the Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document.

8.237 The Council supports the thrust of current national and local policy on transport which is on travel demand management and offering a genuine choice of transport modes. It also supports the key transport improvements identified through the policy. Strategic transport proposals, which extend beyond the Borough boundary and the ISPA area but form the context for this Local Plan, are set out through policy ISPA2.

8.238 To understand the cumulative impact on the highway network of the combined growth proposed through the draft updated Local Plans for Ipswich, Suffolk Coastal Area, Babergh and Mid Suffolk to 2036, assessments have been undertaken using the Suffolk County Transport Model (SCTM). A modelling report published in January 2019 identified that '… the built up area of the Ipswich network comes under particular strain, [and] that in a number of locations the ability to deliver road capacity improvements is highly constrained by available space and could also move the problem 'further down the road'^[5].

8.239 In response, Suffolk County Council has drafted a Transport Mitigation Strategy for the Ipswich Strategic Planning Area. It recognises that the impacts on Ipswich are cumulative and consequently apportions costs for the mitigation measures according to the trips in and out of Ipswich by district and borough. Table 6 below shows that 45% of all journeys in Ipswich begin and end in Ipswich. Mitigation measures may consist of town-wide measures or improvements to junctions within Ipswich.

Table 6 – Ipswich Strategic Planning Area – Trip Destinations in Ipswich

LPA	% trips
Ipswich Borough Council	45
Suffolk Coastal Local Plan area	28
Babergh District Council	14
Mid Suffolk District Council	13

8.240 Detailed measures, costings and a mechanism for collecting the contributions from the planned growth will be determined through the ISPA Board.

8.241 There are particular concerns about highway capacity within the Star Lane area of Ipswich Town Centre, as this impacts on east-west vehicle movements and pedestrian connectivity between the central shopping area and the Waterfront. These capacity implications are closely linked to issues associated with the wider transport network – including the A14 and the Orwell Bridge. There are, in addition, five Air Quality Management Areas (AQMAs) within the central area of Ipswich, as a result of pollutants from road traffic. Air Quality Management Areas are designated in areas where poor air quality may have an effect on people's health.

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

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

1. enable improvements to pedestrian and cycle routes between the Waterfront and the historic core of the town by subsequently reducing capacity on the Star Lane gyratory;

2. enable the development of the Island Site for which access improvements, but not necessarily a Wet Dock Crossing, would be a prerequisite;

3. enable the linking of high quality walking and cycling routes around the entire Waterfront area; and

4. provide an alternative route for east-west movements which, along with appropriate traffic management schemes, would help to relieve congestion and air quality issues in the Gyratory, which in turn will support the town's economy and health.

8.244 Detailed proposals, including those for additional infrastructure for pedestrians and cyclists, are included in the Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document. A Cycling Strategy Supplementary Planning Document has been adopted by the Council. The Council is also producing a Low Emission Strategy Supplementary Planning Document and an Air Quality Action Plan.

8.245 The delivery of a Wet Dock crossing (i.e. a new road linking Holywells Road/Duke Street with Hawes Street the subject of ongoing work. In March 2015 the New Anglia Local Enterprise Partnership obtained funding in order to carry out a feasibility study for the Wet Dock Crossing. The feasibility work was done for a scheme consisting of three potential crossings entitled the 'Upper Orwell Crossings' and funding towards its delivery was secured from the Government. The County Council cancelled the Upper Orwell Crossings project in January 2019, because of a financial shortfall. It has made a commitment 'to work with partners to deliver crossings B and C in the Waterfront area' and continues to underwrite a maximum of £10.8 million to enable the project to go ahead.

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

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

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

8.249 This alternative capacity could also be provided via a northern bypass or a link road to the north of the town. The Council supports the work of key partners to investigate the possibility of a northern bypass, to address the issue of:

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

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

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

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

8.253 This policy supports objective 6 of the plan.

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