Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Part C: Development Management Policies

(1) CHAPTER 9: Development Management Policies

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

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

• the clear government guidance that development management policies should not just repeat what is already contained within national policy (and in some cases legislation) - i.e. policies should be distinctive to Ipswich;
• the policies set out within the Ipswich Local Plan 2017; and
• the comments received during the previous round of consultation.

SUSTAINABLE DEVELOPMENT

9.1.1 New development in Ipswich has the potential to increase carbon dioxide emissions in the borough. If we are to achieve national carbon dioxide reduction targets, it is crucial that planning policy limits carbon dioxide emissions from new development and supports sensitive energy efficiency improvements to existing buildings. In an effort to further reduce the need to travel the introduction of a communications network infrastructure, capable of delivering at least superfast broadband, is supported as part of the build process.

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

9.1.3 The National Planning Policy Framework sets out how local planning can best support the achievement of sustainable development. Specifically it requires that local planning authorities plan with a presumption in favour of sustainable development. The aim of local planning authorities should be to adopt proactive strategies to mitigate and adapt to climate change and a move towards a low carbon future.

9.1.4 Under the 2008 Planning and Energy Act local planning authorities may require development in their area to comply with energy efficiency standards that exceed the energy requirements of building regulations. In accordance with the provisions of the March 2015 Ministerial Statement^[6], the Council will expect new build residential development to achieve a 19% improvement in energy efficiency over the 2013 Target Emission Rate.

9.1.5 The East Anglian area is identified as an area of 'severe water stress'. Lowering water demand is identified as one of a range of measures to balance supply and demand in the Anglian Water Resources Management Plan 2015. In light of this the Council will require new residential development to meet water efficiency standards of 110 litres/person/day (as provided for in the Requirement G2 and Reg36 from Part G of Schedule 1 and regulation 36 to the Building Regulations 2010, as amended - rather than the Building Regulations requirements of 125 litres/person/day.) This conforms to the Anglian Water standard which Anglian Water is currently extending to local authorities as a supply target.

9.1.6 Climate change predictions suggest that Ipswich may experience increased instances of flooding risks, during hotter drier summers and warmer wetter winters. Green and blue roofs* are key measures in the delivery of effective sustainable drainage systems. They help to reduce the amounts of storm water run-off and attenuate the peak flow during a storm. Living roofs can also reduce the negative effects of climate change, for example by improving a building's energy balance and reducing carbon emissions. Further benefits of green roofs include supporting biodiversity and town centre habitat and they should be considered an important part of a well-designed scheme. [*please see glossary.]

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

9.1.8 In relation to the achievement of BREEAM standards, developers will be encouraged to submit Design Stage Assessments and Post Construction Reviews, carried out by a qualified BREEAM assessor (as appropriate), for all planning applications for qualifying development. It will be expected that planning applications also be accompanied by a sustainability statement that explains and illustrates how sustainability considerations have influenced scheme design.

9.1.9 The Building Research Establishment is introducing a Home Quality Mark which is five star rating demonstrating a home's performance in terms of a number of factors including energy use, running costs, air quality, noise, accessibility to amenities, fast and secure internet access and the ease of use of the home by the occupants. The Council encourages applicants to consider achieving a high rating under the Housing Quality Mark (five star).

9.1.10 As part of sustainable construction adoption, developers should meet the highest standards of internal insulation to assist in minimising energy consumption. This is particularly important for applications involving the sub-division of dwellings.

9.2.1 This policy gives effect to Core Strategy policy CS1. It builds on national policy in the National Planning Policy Framework which states that planning plays a key role in supporting the delivery of renewable and low carbon energy.

9.2.2 Given the acknowledged vulnerability of the region to the effects of climate change and the projected levels of development Ipswich will be required to accommodate, the Council considers it reasonable to require new developments above the given threshold to provide a minimum of 15% of energy demand from renewable or low carbon sources. The Planning and Energy Act 2008 allows planning authorities to require a proportion of energy used in development in their area to be energy from renewable or low carbon sources in the locality of the development.

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

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

9.2.5 The Council will support proposals for low and zero carbon technologies where they are complementary to the existing environment without causing any significant adverse impacts, particularly relating to the residential amenity, landscape and visual impact, transport, flora and fauna, noise and air quality, unless those impacts can be appropriately mitigated.

9.3.1 The focus of Policy DM3 is to mitigate the impact of development on air quality and to ensure exposure to poor air quality is reduced in the Borough.

9.3.2 Ipswich has 5 Air Quality Management Areas (AQMAs) and therefore developers must give careful consideration to the air quality impacts of their proposed development. Plan 7 identifies the 5 AQMAs in Ipswich.

9.3.3 The Council produces an Air Quality Action Plan every 5 years identifying actions and mitigation measures to be implemented by the Council and partners to reduce emissions. The Annual Status Report (ASR) which monitors progress on actions is produced annually and is regularly monitored through a Steering Group of officers across the Council. The Council is also preparing a Low Emissions Strategy Supplementary Planning Document (SPD) which will be a material planning consideration in taking decisions on planning applications.

9.3.4 The Council will require Air Quality Assessments (AQA) where the development would:

• Significantly affect traffic in the immediate vicinity of the proposed development site or further afield. This could be by generating or increasing traffic congestion; significantly changing traffic volumes, vehicle speed or both; or significantly altering the traffic composition on local roads.
• Introduce new point sources of air pollution;
• Expose people to existing sources of air pollutants. This could be by building new homes, workplaces or other development in existing designated or proposed AQMA's
• Give rise to potentially unacceptable impact (such as dust) during construction for nearby sensitive locations;
• Affect biodiversity. In particular, is it likely to result in deposition or concentration of pollutants that significantly affect a European-designated wildlife site, and is not directly connected with or necessary to the management of the site, or does it otherwise affect biodiversity, particularly designated wildlife sites.
  5. The AQA must outline the baseline predicted and forecast pollutant concentrations at the proposed development and the planned mitigation measures. The AQA should also consider wider cumulative impacts on air quality arising from a number of smaller developments.
  6. Where an AQA shows that development would cause harm to air quality, planning permission will be refused unless mitigation measures are adopted to reduce the impact to acceptable levels. Mitigation measures should be provided on-site, however where this is impractical the AQA should demonstrate that it is possible to include measures in the local area which have equivalent air quality benefits. Mitigation measures may be secured either by planning condition or legal agreement where appropriate.
  7. Examples of mitigation include:

• the design and layout of development to increase separation distances from sources of air pollution;
• using green infrastructure, in particular trees, to absorb dust and other pollutants;
• means of ventilation;
• promoting infrastructure to promote modes of transport with low impact on air quality
• controlling dust and emissions from construction, operation and demolition; and
• contributing funding to measures, including those identified in air quality action plan, designed to offset the impact on air quality arising from new development.

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

9.4.2 The Council will apply the NPPF hierarchy for managing flood risk i.e.:

TABLE 7

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

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

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

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

9.4.6 The preferred method of surface water disposal is through the use of SuDS. In new development and redevelopment, surface water connections to the foul system and to the combined or surface water system should only be made in exceptional circumstances where it can be adequately demonstrated that there are no feasible alternatives. It is also important that there is existing sewage treatment capacity and foul drainage exists or that it is capable of being included in time to serve standards where practicable. This will be agreed in consultation with the relevant water and sewerage undertakers

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

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

9.4.9 SuDS standards and policies are currently set out in the Council's Drainage and Flood Defence Policy as referred to in the Development and Flood Risk SPD. In terms of surface water flooding and drainage, the adopted standards specified in criterion b are the minimum standards set out in the Suffolk Flood Risk Management Strategy (Appendix A). The adopted standards for fluvial and tidal flooding as set out in the Development and Flood Risk SPD will also need to be met. In the future it is expected that National Standards will be followed.

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

9.4.11 FRAs for proposals in Zones 2 and 3 need to clearly state the frequency of flooding in and around the site and will need to ensure that they include the impact of the implementation of the EA's flood defence barrier.

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

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

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

9.4.15 The Anglian River Basin Management Plan sets a requirement for Local Government to consider the impact on hydromorphology when preparing spatial plans. Ipswich also has sites of International and National Importance wholly or partly within its boundary. Consequently, it is imperative that development does not have any adverse effect on European and Nationally designated sites in terms of how surface water is disposed of.

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

9.5.2 The Council will therefore protect them from development unless the particular circumstances set out in the policy apply. This accords with the National Planning Policy Framework (NPPF), which states that existing sites and facilities should not be built on unless an up to date assessment has clearly shown them to be surplus to requirements. Developers would be expected to engage with Sport England to ensure that the loss of the open space, sports or recreation facility will be acceptable, and this evidence would be expected to be presented at pre-application discussions and as part of any eventual application.

9.5.3 Developments involving the loss of open space, sports or recreation facilities that have been purposefully neglected to artificially lower their demand could, if otherwise well-maintained, be capable of meeting local need. In these circumstances, applications will need to demonstrate that there is no longer a local demand for this type of provision or other form of related use. The local demand catchment will depend on the amount and quality of alternative provision available in the wider area.

9.5.4 The Council has carried out an open space, sport and recreation facility audit and needs assessment, as required by the NPPF. This identifies the typology of open spaces, sport and recreation facilities, assesses the quantity and quality of provision in Ipswich and sets out standards for the quantity, quality and accessibility of provision. The typology, together with the quantity and accessibility standards, is reproduced in Appendix 4. Quality standards can be found in the Ipswich Open Space, Sport and Recreation Facilities Study 2009 (as updated in 2017) and subsequent update as a result of the Council's Open Space and Biodiversity policy. The need for formal sports provision is identified through the 2009 Open Space, Sport and Recreation Study, and is being updated by the production of the Indoor Sports Facility Strategy and the Playing Pitch Strategy. This will inform consideration of whether a facility is surplus and where/what alternative provision may be appropriate.

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

9.6.1 Access to high quality open space, sport and recreation facilities and public open space provision is important for the health and wellbeing of individuals and communities. The Council will seek provision of on-site open space and sports and recreational facilities where possible, however the policy makes provision for instances where it is not practicable to include a type of open space or facility on-site. This will include factors where its provision would compromise other standards in this Plan, such as meeting the density requirements of Policy DM23 or the minimum garden sizes of Policy DM7.

9.6.2 At least 10% of the site area of all qualifying developments must consist of public green space, which shall include soft landscaping and tree planting to facilitate sustainable urban drainage and enhance the climate change resilience, appearance and biodiversity value of the development. In high density residential developments (defined in Policy DM23), the green space requirement will be a minimum of 15% of the site area, to compensate for the more limited amenity space in these developments and to provide an attractive setting for the buildings. The 10%/15% requirement will also contribute to the amenity green space and/or natural and semi natural green space standards as outlined in Appendix 4.

9.6.3 Where the provision for a type of space or facility would not meet the minimum size threshold described in the Ipswich Open Space, Sport and Recreation Facilities Supplementary Planning Document 2017, a qualitative assessment of existing provision should be made to determine whether an enhancement opportunity exists. Such provision should be achieved within the standard accessible distance from the site set out in Appendix 4. Where a reasonable improvement can be identified, a contribution should be secured by a planning agreement, where this would be necessary to make the development acceptable. Standards for children's and young people's facilities will be not be applied to elderly persons' accommodation and nursing homes. It is expected that amenity green spaces in particular would be located on generally flat land in order to maximise their use. Where provision is distributed throughout large-scale developments, it is important that it adequately meets the intended use.

9.6.4 The costs of on-site provision and/or off-site enhancements will be material when considering a scheme's viability. However, where an under provision of open space, new facilities or other contributions is required to achieve scheme viability – that results in a poor environment for new residents will be deemed unacceptable.

9.6.5 The Council's Public Open Space Supplementary Planning Document (SPD) provides guidance on population forecasts from new developments and outlines the minimum size standard for each Appendix 4 typology. The surpluses and deficits of open spaces and facilities by area is set out in chapter 3 of the SPD. The document will also indicate per square metre capital and maintenance costs for each typology where these are to be provided and/or maintained by the Council, and to guide in lieu contributions for new off-site provision. Where a contribution is secured to enhance an existing area of open space or facility, this sum will be based on the works required and in proportion to the scale of the development.

9.6.6 The quality standards for the various typologies are identified by the Ipswich Open Space, Sport and Recreation Study, Play Strategy, Allotment Strategy and Open Space and Biodiversity Policy/Strategy, and any subsequent updates to these. Furthermore, the need for formal sports provision is currently being updated by the production of the Indoor Sports Facility Strategy and the Playing Pitch Strategy.

9.6.7 The provision of new open space should take account of the relevant Secured By Design guidance, in particular:

• Having clear boundaries between public and private spaces;
• Not to immediately abut residential properties;
• To avoid locating such facilities at the rear of dwellings;
• To ensure that small children's play areas can be made secure at night; and
• To ensure that the provision of any informal spaces aimed at young people considers comments made by the Designing Out Crime Officer.

9.6.8 Where possible, green spaces should provide for wildlife habitats designed and located so as to create a link with existing ecological networks and/or green corridors, which may include the proposed green trail around Ipswich for sites on the edge of the Borough. All planting proposals should be accompanied by an appropriate management plan. Within IP-One, the provision of a public civic space may be considered in lieu of green space where this makes a positive contribution to the townscape.

9.6.9 Accessible natural greenspace is defined by Natural England as places where human control and activities are not intensive so that a feeling of naturalness is allowed to predominate. There is no local standard for the provision of strategic accessible natural green space ('ANG') per person or dwelling. However, the mapping of existing provision against the 'Nature Nearby' standards has identified areas of deficit, particularly across north west Ipswich. The Council will aim to address these deficits where it can be achieved through also meeting the local standards for natural and semi-natural greenspace.

9.6.10 The Local Plan does not stipulate a minimum requirement for open space provision for non-residential development, due to the potential needs of workers being different from the needs of residents. However, where appropriate, open space over and above site landscaping should be provided for the health and wellbeing of employees. Standards in Appendix 4 are applied on the basis of the total number of full-time equivalent employees.

9.7.1 The Council considers that, in addition to the provision of well-planned public spaces, the provision of high quality private outdoor amenity space for all types of new residential development is an essential component of high quality design. Such space is needed for sitting out socialising, play, drying washing, and gardening (flowers and food) and is key to the creation of a sustainable residential environment in terms of:

• its contribution to liveability and to urban greening

• the preservation and/or enhancement of local biodiversity and

• ecological networks.

9.7.2 In most developments of houses and bungalows, the Council will expect private garden space to be provided to the rear of the dwelling. Exceptions may be made for corner and infill plots.

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

9.7.4 A suitably designed 75 sq.m private garden should be capable of achieving the above requirements for a three-bedroom or larger house.

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

9.7.6 Key characteristics of well-designed private amenity space include: (i) a well shaped (rectangular), useable area having good accessibility and a well planned relationship to the internal living spaces within the dwelling; (ii) provision for a private sitting out area not directly overlooked by any window of a neighbouring property either at ground or first floor; (iii) high standards of security and privacy with clear delineation of public and private space and rear gardens typically bounded by fencing and hedging; (iv) a reasonable outlook; and (v) access to direct sunlight for part of the space for at least part of the day.

9.7.7 The Council's Development Control Policies and Space and Design Guidelines supplementary planning document, which addresses matters such as spacing between dwellings, will apply. The garden standards set out in the policy will equally apply to existing gardens remaining after garden severance.

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

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

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

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

9.7.11 Residential extensions or other types of development which causes private outdoor amenity space to fall below the expected standard will be refused. However, the Council will consider cases on their merits where an applicant is able to demonstrate that there are appropriate and usable alternative provisions available, close at hand.

9.8.1 The overall aim of this policy is to contribute to the international and national objective to halt the overall decline in and to improve biodiversity, by the protection and creation of key habitats; and the maintenance of linked, coherent ecological networks, so that populations of species are not isolated.

9.8.2 European sites include Special Areas of Conservation (SACs) and Special Protection Areas (SPAs). These sites are protected under the Birds and Habitats Directive (92/43/EEC). The Stour and Orwell Estuaries SPA and Ramsar site lies partly within Ipswich Borough. Policy ISPA3 (Cross-boundary mitigation of effects on Protected Habitats and Species) sets out the Council's approach to working with other authorities and stakeholders to address the requirement of the Recreational Avoidance and Mitigation Strategy and implementation of mitigation measures across the Ipswich Strategic Planning Area. Listed or proposed Ramsar sites, potential SPAs and possible SACs and sites required in relation to compensatory measures for adverse effects on European sites are afforded the same level of protection as SACs and SPAs through the NPPF. The Conservation of Habitats and Species Regulations 2017 (as amended) set out requirements in relation to assessing projects that could potentially affect a European site. Where a significant effect on a European site cannot be ruled out proposals will need to be accompanied by an Appropriate Assessment. The assessment should be carried out in accordance with the requirements of the Conservation of Habitats and Species Regulations 2017 (as amended). Where the assessment concludes negative effects on a site's integrity permission should only be granted where there are no alternative solutions and where the project must proceed due to imperative reasons of over-riding public interest. The source-pathway-receptor model will be used to assess the effects of proposed development on European sites. Assessments under the Habitats Directive have been undertaken in relation to the production of the Core Strategy and Policies DPD Review and the Site Allocations and Policies (Incorporating IP-One Area Action Plan) DPD. Mitigation measures have been identified and in some instances developer contributions may be sought in relation to these and/or additional mitigation measures identified through assessments at planning application stage.

9.8.3 The Stour and Orwell Estuaries are a Site of Special Scientific Interest (SSSI) as well as a Special Protection Area and Ramsar site. Bixley Heath and Stoke Tunnel Cutting SSSIs are nationally important heathland and geological sites respectively. In addition, there are 20 County Wildlife Sites and 9 Local Nature Reserves that are wholly or partly inside the Borough boundary. Many species are protected through specific legislation including the Wildlife and Countryside Act 1981 (as amended). England's priority species and habitats are those which are included on the list produced under Section 41 of the Natural Environment and Rural Communities Act 2006. Suffolk's priority species and habitats are identified in the Suffolk Biodiversity Action Plan.

9.8.4 As part of the overall package of securing measurable net gains for biodiversity, development will be required to include measures to support the protection and recovery of protected and priority species. Measures to enhance protected and priority species for minor and major development may include habitat creation, restoration or connection of fragmented habitats. For householder developments measures may include integrated swift boxes, bat boxes, hedgehog highways or other measures that are found to protect and recover protected and priority species. The Government guidance 'Protected species: how to review planning applications' provides standing advice and measures for protected species.

9.8.5 The mitigation hierarchy requires consideration firstly to be given to avoiding any harm to biodiversity. Where harm cannot be avoided consideration should be given to mitigating any effects and, finally, if sufficient mitigation cannot be achieved compensation measures should be undertaken. Net loss will be considered in terms of population size or loss of extent of BAP habitat or other feature for which the site was designated. In some instances it will be necessary to relocate species to an alternative location. Where this is the case the receptor location will need to be suitable for the type and number of species to be relocated and monitoring will need to ensure that the receptor location remains suitable. The British Standard Guidance 'Biodiversity: Code of Practice for Planning and Development (BS42020)' provides an approach to dealing with biodiversity issues in development.

9.8.6 The NPPF promotes the identification of local coherent ecological networks. Plans need to distinguish between the hierarchy of international, national and locally designated sites and take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries. Valued landscapes need to be protected and enhanced along with sites of biological or geological value and soils in a manner commensurate with their statutory status. The original NPPF (2012) included a requirement to provide net gains in biodiversity 'where possible'. However, 'where possible' was removed in the revised NPPF (2019) and therefore there is now a requirement in national policy to provide net gains for biodiversity. The Government's 25 Year Environmental Plan (2018) and Environmental Bill (2019) have also reaffirmed this as a mandatory requirement.

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

9.8.8 The links may consist of roadside verges, railway lines or even areas covered by private gardens. Planning control does not extend to the management of such spaces, but there is advice available, for example on how to improve the attractiveness of gardens to wildlife and the Council's Parks and Open Spaces Team provide activities which support and encourage this. The policy reflects national strategic priorities in the 25 Year Environmental Plan (2018) and the NPPF, and local strategic priorities in terms of developing ecological networks. Reference should be made to the information and recommendations of the Wildlife Audit in relation to any proposals on, or that may affect, sites identified within it.

The Ipswich ecological network consists of:

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

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

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

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

9.8.12 It is important that planning decision are based on up to date ecological reports and survey data. In some instances, there will be national or species specific guidance on this, however in circumstances where such advice does not exist CIEEM advise that ecological reports and data which is more than three years old is unlikely to be valid. Reports conducted between eighteen months to three years previous, will require a clear statement from a professional ecologist on the validity of the report, which, if any, surveys need to be updated and the appropriate scope, timing and methods for the survey update(s).

9.9.1 Trees are important elements of green infrastructure, contributing to urban cooling through evapotranspiration and providing micro-climatic effects that can reduce energy demands in buildings. They therefore represent a key resource that can significantly contribute to climate change adaptation. Whether viewed individually or collectively from a distance trees make an important contribution to the environmental quality of Ipswich. They contribute to the townscape, biodiversity, climatic river management and air quality. They also provide an important role in helping to keep rivers cool. This helps moderate extremes in water temperature which can be detrimental to fish spawning. Shading can also be helpful in the control of aquatic vegetation. The Council has signed the Charter for Trees in conjunction with the Woodland Trust. The Charter's ambition is "to place trees and woods at the centre of national decision making, and back at the heart of our lives and communities.             

Ancient woodlands, Ancient or Veteran Trees and Tree Preservation Orders.

9.9.2 Ancient woodland and Ancient or Veteran Trees are identified as irreplaceable habitats in the NPPF (2018). Paragraph 175 of the NPPF explains that development resulting in the loss or deterioration of these habitats should be refused. This development will only be acceptable where there are wholly exceptional reasons, the basis of which is justified in footnote 58 of the NPPF.

9.9.3 Tree Preservation Orders (TPOs) are used by the Council to legally protect specific trees or groups of trees that provide public amenity. Cutting, lopping or removing any part of a tree subject to a TPO other than the removal of deadwood requires the Council's consent. Where a planning application relates to trees in conservation areas, the Council will pay special attention to the desirability of preserving or enhancing the character of that area. Where a tree in a conservation area is already protected by a TPO, we will apply the normal procedures and controls associated with a TPO. In other cases, a notification procedure exists (Section 211) unless an exception applies allowing the opportunity to consider whether to make a TPO on the tree. The felling of protected trees will only be permitted in exceptional circumstances and in accordance with relevant legislation, policy and guidance.

Replacement and additional planting

9.9.4 Where loss of trees or vegetation of value cannot be avoided, the Council will require suitable replacements capable of providing at least equal amenity and ecological value. This may not always be possible or appropriate on the development site in question, and in such cases off site provision will be expected as an alternative. The Council will also expect development to incorporate additional trees and vegetation wherever possible. This should include large species trees where opportunities allow.

9.9.4 Tree planting and landscaping schemes on development sites should not be an afterthought. BS5837: 2012 provides guidance in respect of development sites, on tree retention, protection during development and incorporating trees into design of the development. The level of detail expected with a planning application should be appropriate to the scale of the proposal. We will take a right tree/ plant for the right site approach which takes account of:

• the amenity value of any trees to be removed,
• ecology,
• opportunities to retain existing and plant new appropriate native species or riparian trees where possible,
• historic context,
• availability of space,
• soil conditions including hydrogeology,
• potential improvements to air and soil quality,
• reducing the effects of and adapting to climate change; and
• the guidance provided in BS 8545 Trees: from nursery to independence in the landscape – Recommendations'.

Community woodlands

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

9.9.6 Ipswich is signed up to the Urban Buzz Project and is committed to creating pollinator rich habitats to improve local open spaces and parks.

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

9.10.5 The Council's Open Space Study 2009^[7] (as updated in 2017) describes green corridors as linear features mostly open in character e.g. footpaths, riverside paths and bridleways, which act as wildlife corridors and attractive, safe, off-road links between residential areas or open spaces or other destinations. Their value is increased if they link up to form a network and, for Ipswich, they may also link to the open countryside in neighbouring authority areas. They help to create urban environments that are attractive, clean and safe.

9.10.6 Ipswich benefits from an important and continuous green corridor in the form of the river path which follows the river from the Waterfront westwards through to Sproughton. Enhancing the river path is a key aim of the Ipswich River Strategy. The Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document proposes pedestrian and cycle bridges across the river to link up communities and facilities north and south of the river in the vicinity of Elton park, and east of Stoke Bridge. In order to maintain an appropriate ecological buffer along the river, no development should take place within 10m of the river. Development taking place within this buffer zone will only be permitted if it can be clearly demonstrated that it would maintain or enhance the ecological quality of the river corridor.

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

9.10.8 The Haven Gateway Green Infrastructure Strategy^[8] recognised their value but also identified gaps, particularly to the north and east of Ipswich. Thus the Core Strategy, through policy CS16, seeks to link radial green corridors with a publicly accessible 'green trail' around Ipswich. The Council will take opportunities through development, such as at the Ipswich Garden Suburb, which is addressed through policy CS10, to provide links in the green trail where currently there are gaps. Where the green trail traverses development sites, the Council will work with developers and other stakeholders to agree a route.

9.10.9 Green corridors can provide safe and pleasant cycling and walking routes that offer an alternative means of accessing parts of the town. This benefits air quality in general and the health of cyclists and walkers in particular.

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

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

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

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

9.11.2 The National Planning Policy Framework (NPPF) recognises the intrinsic character and beauty of the countryside. Together with peripheral designated open spaces, the countryside around the Ipswich urban area, including in neighbouring districts, provides an attractive setting for the town and links into its ecological and green corridor networks. The NPPF requires planning to take account of the different roles and character of different areas and, therefore, it is appropriate to maintain separation between Ipswich and surrounding settlements.

9.11.3 Ipswich also contains a small area of the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB) on the southern boundary of the Borough. The NPPF sets out the approach to considering major development applications within the AONB in paragraph 172. The definition of major development in respect of development within the AONB is defined by footnote 55 of the NPPF and is matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined.

9.11.4 The NPPF supports rural tourism and leisure developments which respect the character of the countryside. However, isolated development in the countryside should be avoided unless justified under paragraph 79 of the NPPF

9.11.5 Subject to infrastructure and highways constraints, there are some areas of countryside within the Borough boundary which have been assessed as having 'in principle' acceptability for housing through the Strategic Housing Land Availability Assessment. In the event that the infrastructure constraints can be addressed satisfactorily, any development would be required to meet the criteria in the policy.

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

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

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

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

9.12.3 In 2015, the Government introduced new 'optional' Building Regulations standards relating to accessible and adaptable dwellings and wheelchair user or wheelchair adaptable dwellings. These optional standards can only be required through a planning policy requirement. The national Planning Practice Guidance states that 'Where a local planning authority adopts a policy to provide enhanced accessibility or adaptability they should do so only by reference to Requirement M4(2) and / or M4(3) of the optional requirements in the Building Regulations. They should clearly state in their Local Plan what proportion of new dwellings should comply with the requirements.'

9.12.4 The 2014 Suffolk Housing Survey indicates that 10% of Ipswich residents live in a home which has been adapted in some way for accessibility purposes. The results indicate that a further 3% of Ipswich residents currently require adaptations to their dwellings. Since 2007 almost 1,600 adaptations have been carried out on the Council's housing stock. The number and proportion of elderly residents in the Borough is predicted to increase over future years, potentially further increasing the need for dwellings to be accessible and adaptable. Therefore, 25% of dwellings on sites of 10 dwellings or more should be M4(2) compliant. Should the evidence show this requirement to be, in practice, readily viable, the policy will be revised accordingly as part of the envisaged future review of plans. However, the Council's housing register currently indicates that a relatively small number of wheelchair accessible homes built to Building Regulations Standard M4(3) are needed and, therefore, whilst this type of provision is encouraged within affordable housing developments, it is not a requirement.

9.12.5 Development should seek to adopt the principles of dementia-friendly design:

• Familiar environments – functions of places and buildings are obvious, any changes are small scale and incremental;
• Legible environment – a hierarchy of street types, which are short and fairly narrow.
• Clear signs at decision points;
• Distinctive environment – A variety of landmarks, with architectural features in a variety of styles and materials. There is a variety of practical features (e.g. trees and street furniture); and
• Accessible environment – Land uses are mixed with shops and services within a 5-10 minute walk from housing. Entrances to places are obvious and easy to use and conform to disabled access regulations.

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

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

9.12.8 Developments must be sustainable and adhere to the relevant Secured By Design guide where appropriate to do so. Proposals for large developments must be subject to consultation with the local Design Out Crime Officer at Suffolk Constabulary. This applies to all development types, whether residential, commercial or public sector. These guides will require particular consideration to be given to the layout of the development to increase natural surveillance, the use of appropriate boundary treatments and access control systems to deter unauthorised access, appropriate planting, the appropriate use and location of open space and taking every opportunity to minimise the potential for Anti-Social Behaviour (ASB).

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

9.12.10 The wooded skyline that provides the backdrop to much of central Ipswich is a key part of the centre's character and setting and will be protected and sustainably enhanced. The Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document and the Ipswich Urban Character Study supplementary planning document identify key viewpoints and key strategic views in relation to the wooded skyline around central Ipswich. Relevant policy guidance in respect of tall buildings can be found in policy DM15.

9.12.11 The character and distinctiveness of Ipswich is the product of a combination of Ipswich's geographical setting, history and communities. The character of different areas of Ipswich is analysed through the conservation area character appraisals (covering the conservation areas only) and the Ipswich Urban Character supplementary planning document. Decisions about proposed development which would harm the significance of a designated heritage asset will be taken having regard to the NPPF and DM13 Built Heritage and Conservation and DM14 Archaeology.

9.12.12 In order to support Ipswich residents in adopting sustainable and healthy lifestyles, the Council will ensure that new developments offer opportunities to be naturally active and promote physical activity, walking and cycling in accordance with Sport England's Active Design guidance.

9.12.13 Criterion f. of the policy seeks to secure well-designed, adaptable and resilient places in accordance with the Planning Practice Guidance paragraphs 015 and 019 (Reference ID: 26-019-20140306). Assessment of design quality for major applications for residential development will be made using the Building for Life 12 criteria (CABE at the Design Council / Design for Homes / HBF) and applicants will be expected to demonstrate that scheme designs can achieve a 'green' score in each category enabling schemes to be eligible for 'Building for Life Diamond' status. However it is recognised that not every development proposal will meet this criteria and in these circumstances developers will be expected to justify why this is not possible. The Building for Life criteria are reflected in policy DM12 and therefore addressing the specific requirements of Building for Life will contribute towards meeting the requirements of policy DM12. The criteria in policy DM12 also contribute towards the creation of safe, functional and well-designed communities as aspired to by the Government's Lifetime Neighbourhoods ambitions.

9.12.14 The design quality of smaller residential developments will be assessed against the various Building for Life criteria as may be considered reasonably applicable to the type and scale of development under consideration. The Council's Space and Design Guidelines SPD, which address matters such as spacing between dwellings, will apply to all residential developments.

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

9.12.16 Applicants for planning permission will be required to clearly demonstrate how the submitted development proposal achieves urban design quality through the design and access statement accompanying their application, where required by the Council's Local Validation List.

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

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

9.12.19 Urban greening is important, to enhance the townscape, tackle and help adapt for climate change and enhance biodiversity. It could include the incorporation of canopy cover, green walls and green roofs and the creation of urban greenspace, as part of soft landscaping considerations. Opportunities for greening should be maximised in all developments, where appropriate. Provision to support biodiversity net gain should include measures such as nestboxes for birds (swifts, house sparrows, starlings) and bat boxes integrated into the fabric of the building. The Council will also refer to its Open Space and Biodiversity Policy.

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

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

9.13.1 The Borough of Ipswich benefits from a rich history, with the settlement of the town developing from the Saxon period. Like much of the East Anglian region, Ipswich benefitted from the prosperity of the wool and cloth trade throughout the medieval period, whilst its location opposite the mouth of the Rhine allowed the town to establish itself as an important trading port. The wealth of this period is evident in the historic core of the town, with fine timber framed buildings contributing to much of the town centre's building stock. The economic downturn following the decline of the wool trade preserved many of these medieval buildings, as in contrast to other parts of the country in the Georgian era, many building owners in Ipswich were not prosperous enough to rebuild their homes to the latest fashion. The growth of industry and population in the Victorian period led to the redevelopment and expansion of the town providing distinctive suburbs of 19th century development, which are an important part of the town's character.

9.13.2 The rich history of Ipswich is recognised by the volume of heritage assets across the town. The borough benefits from over 600 listed buildings, 15 Conservation Areas, 8 Scheduled Ancient Monuments, 3 Registered Parks and Gardens, an area of archaeological importance, and hundreds of undesignated heritage assets.

Listed buildings

9.13.3 The Borough benefits from a high volume of listed buildings, which contribute to the character of the town, illustrate the town's history, encourage visitors and tourism, as well as make the town a distinctive place to live and work.

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

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

9.13.6 In order to protect listed buildings, the Council will control external and internal works that affect their special architectural or historic interest. Consent is required for any alterations, including some repairs, which would affect the special interest of a listed building.

Conservation Areas

9.13.7 There are fifteen designated conservation areas in Ipswich, which protect distinctive areas of the town's built heritage, including the medieval core, the Victorian wet dock, the historic hamlets of Stoke and Whitton, and numerous 19th century suburbs.

9.13.8 The Council will protect and enhance the character and special interest of the town's conservation areas. Conservation Area Appraisals and Management Plans have been prepared which provide further guidance on the character of these areas. The Council will take these documents into account as material considerations when we assess applications for planning permission which have the potential to affect these areas.

9.13.9 Due to the urban nature of Ipswich, the character and appearance of a conservation area can be affected by development outside of the conservation area boundary. The Council will therefore not permit development in locations outside conservation areas that it considers would cause harm to the character, appearance or setting of such an area, and will consider the impact of cumulative harm in this regard.

9.13.10 The character of conservation areas derives from the combination of a number of factors including building patterns, land form, historical development and key views. These elements should be identified and responded to in the design of new development. Design and Access Statements should include an assessment of local context and character and set out how the development will respond to the existing urban grain of development.

Demolition in a conservation area

9.13.11 The Council has a general presumption in favour of retaining buildings that make a positive contribution to the character or appearance of a conservation area, whether they are listed or not, so as to preserve the character and appearance of the area. The Council will resist the total or substantial demolition of buildings which make a positive contribution to a conservation area unless circumstances are shown that outweigh the case for retention. Applicants will be required to justify the demolition of a building that makes a positive contribution to a conservation area, having regard to the National Planning Policy Framework, Ipswich's Conservation Area Appraisals and management strategies and any other relevant supplementary guidance produced by the Council.

9.13.12 When considering applications for demolition, the Council will take account of group value, context and the setting of buildings, as well as their quality as individual structures and any contribution to the setting of listed buildings. Applications must clearly show which buildings or parts of buildings are to be demolished.

Use

9.13.13 Changes in patterns of use can also erode the character of an area. It is therefore important that, whenever possible, uses which contribute to the character of a conservation area are not displaced by redevelopment.

Details

9.13.14 The character and appearance of a conservation area can be eroded through the loss of traditional architectural details such as historic windows and doors, characteristic rooftops, garden settings and boundary treatments. Where alterations are proposed they should be undertaken in a material of a similar appearance to the original. Traditional features should be retained or reinstated where they have been lost, using examples on neighbouring houses and streets to inform the restoration.

Landscape

9.13.15 The value of existing gardens, trees and landscape can make a particular contribution to conservation areas. Development will not be permitted which causes the loss of trees or garden space where this is important to the character and appearance of a conservation area.

Setting of heritage assets

9.13.16 The setting of a heritage asset, although not forming part of any statutory designation, can contribute to the significance of the heritage asset. The value of a heritage asset can be greatly diminished if unsympathetic development elsewhere harms its appearance or its harmonious relationship with its surroundings. While the setting of a heritage asset may be limited to its immediate surroundings, it can often extend some distance from it, and is defined by the NPPF as the surroundings in which a heritage asset is experienced. Views of/to a heritage asset may contribute to the setting of a heritage asset, but setting can also be influenced by other environmental factors, and does not depend on visual links and intervisibility alone, nor does it depend on there being public rights of access to the experience of the setting of the heritage asset.

9.13.17 Historic England have produced The Setting of Heritage Assets: Historic Environment Good Practice Advice in Planning Note 3 which applicants are encouraged to read where their proposals will be in the setting of heritage assets.

Vacant Heritage Assets

9.13.18 Ipswich has a number of prominent vacant buildings of heritage value. The Council will support proposals that bring these premises back into use, particularly where they form part of a wider proposal for regeneration. This will help to meet the objectives of policy CS4 Protecting our Assets.

Sustainable design and retrofitting

9.13.19 Historic buildings, including those in conservation areas, can be sensitively adapted to meet the needs of climate change and energy saving while preserving their special interest and ensuring their long-term survival.

9.13.20 In assessing applications for retrofitting sustainability measures to historic buildings the Council will take into consideration the public benefits gained from the improved energy efficiency of these buildings, including reduction of fuel poverty. These considerations will be weighed against the degree to which proposals will affect the significance and special interest of the building/area.

9.13.21 Historic England publishes advice on the application of Part L of the Building Regulations to historic and traditionally constructed buildings.

Registered Parks and Gardens

9.13.22 In addition to conservation areas, listed buildings and archaeological remains, Ipswich benefits from three registered parks and gardens (Chantry, Cemetery and Christchurch), as designated by Historic England. The Council will encourage the management of registered parks and gardens and where appropriate, enhance their value and protect their setting. The Council will consult with Historic England over proposals affecting these parks and gardens.

Non-designated heritage assets

9.13.23 The Borough also has many attractive, historic, locally significant buildings and features which contribute to the distinctiveness of local areas, but which are not formally designated. Non-designated heritage assets may either be identified as part of the planning process or included on the adopted Local List (Buildings of Townscape Interest) SPD. When planning permission is required for any proposal that directly or indirectly affects the significance of a non-designated heritage asset (either on the Local List or not) then the Council will treat the significance of that asset as a material consideration when determining the application.

Requirements for Heritage Statements

9.13.24 A Heritage Assessment is an assessment of the significance of heritage assets and/or their settings affected by a development and of the impacts of that development upon them. Quite apart from the need to comply with the NPPF, the Heritage Statement is an important practical tool to guide an applicant in developing their proposals. As good practice, it should therefore be one of the first things that an applicant considers when beginning to formulate their development proposals. In other words, the needs and constraints of the identified heritage asset(s) should influence the evolution of the proposal from the outset and a Heritage Statement should explain how an applicant /agent has arrived at a certain proposal. Good understanding of heritage asset(s) is essential before that process can take place.

9.13.25 There is no prescribed format for a Heritage Statement and it does not have to be a freestanding document. Sometimes a Heritage Statement will be amalgamated with other documents such as a schedule of works, a design and access statement, or drawn details that may expand on the content of submitted drawings. It is for the applicant or agent to decide whether it is appropriate, in the circumstances, to amalgamate the documents or keep them separate. So long as the content of the document is made clear in the title, it makes no difference to the validation of an application by the Authority.

9.13.26 A Heritage Statement needs to be relevant and appropriate, but also proportionate, depending on the scale and nature of the proposal and the heritage asset(s) affected. Small works, of small impact, require only simple heritage statements that can easily be produced without the need for special expertise. Appendix 8 includes guidance on what is required in a Heritage Statement submitted to the Council. Essentially, it needs to identify and describe the heritage assets affected; assess the impact of the proposed development on the heritage asset and mitigate the impact.

9.14.1 Historic towns and cities are highly sensitive archaeological sites, where buried features, finds and standing monuments form a unique and irreplaceable record of a settlement's unwritten history.

9.14.2 As a historic port, aspects of the archaeological record in Ipswich are nationally important. However, Ipswich is particularly special in that it has origins as one of only four international ports in the Middle Saxon period. As a major Anglo-Saxon centre engaged in long-distance trade, it has an internationally important archaeological record from this time. The town's early fortunes were linked to the developing Anglo-Saxon kingdom of East Anglia, and Gipeswic was likely a trading settlement founded by the Royal house, notably associated with the burial ground at Sutton Hoo. Remains at several locations in Ipswich are statutorily protected through designation as scheduled monuments. There are currently eight scheduled monuments in Ipswich.

9.14.3 To ensure that this invaluable and irreplaceable historical, cultural and educational resource is not lost or damaged, the planning process must ensure that development proposals respect archaeologically important sites

9.14.4 The NPPF sets out specific requirements for assets with archaeological interest. Where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, developers will be required to submit an appropriate desk based assessment and, where necessary, a field evaluation (which could include geophysical survey, building survey and trenched evaluation) at an appropriate stage prior to determination of an application.

9.14.5 Suffolk County Council Archaeology Service holds the Urban Archaeological Database for Ipswich and is consulted on planning applications that could affect archaeology. Historic England administers the Scheduled Monument Consent process and should be consulted on any proposed works. Early consultation with relevant agencies is encouraged well in advance of seeking relevant permissions and consents, in order that appropriate consideration is given to heritage assets. This makes the application process simpler and reduces the risk for proposed schemes. Understanding the significance of affected assets is important to the process. The ability to document an asset is not a factor in determining a planning application. However, where permission is granted subject to conditions relating to archaeological remains, an appropriate programme of work to record and promote understanding of remains which would be affected by development could include some or all of the following: further evaluation, upfront excavation, and/or monitoring and control of contractor's groundworks, with appropriate curation and publication of results. The Development and Archaeology Supplementary Planning Document (SPD) is intended to help applicants make successful applications and provides further detail on procedures and best practice.

9.14.6 Attention is drawn to the policies maps, which show the Area of Archaeological Importance of the Anglo-Saxon and Medieval town, aspects of which are internationally recognised. Beyond this area, the Borough includes parts of the wider landscape of the Gipping Valley and Orwell Estuary, and there are Prehistoric, Roman, Anglo-Saxon and other period archaeological sites within its boundaries. For information, the Area of Archaeological Importance is also shown on Plan 4. The Area of Archaeological Importance is defined from evidence of buried archaeology, historic maps and information, standing structures and visual elements of the historic landscape and it highlights the area known or likely to have the most complex and sensitive archaeological deposits. This helps to alert applicants and planning officers to the likely requirements for archaeological investigation, protection and recording to be placed on development, on potentially even the smallest scale below-ground works. The Development and Archaeology SPD adds another layer of detail to the Area of Archaeological Importance by providing Archaeological Character Zones, more detailed geographical characterisation of 'archaeological potential'.

9.15.1 The boundaries of the arc of land to which this policy applies are illustrated on the IP-One Area Inset Policies Map.

9.15.2 Tall buildings may be defined as 'buildings which are substantially taller than their neighbours or which significantly change the skyline'. The definition is taken from 'Guidance on Tall Buildings' EH /CABE 2007. Proposals should consider and comply with the Historic England Tall Buildings Advice Note (4) 2015 as appropriate.

9.15.3 Tall buildings can only be considered appropriate in certain limited locations in Ipswich and various special considerations, over and above standard urban design considerations, should apply to their planning and design, particularly in listed building and conservation area terms. Decisions about proposed development which would harm the significance of a designated heritage asset will be taken having regard to the NPPF.

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

9.15.5 Central Ipswich is circled by a wooded skyline, which is particularly important to the setting of the central area including Ipswich Village and the Waterfront. Developments will only be permitted where they do not seriously disrupt this setting, especially when viewed from key viewpoints. Strategic views in and across central Ipswich have been identified through the Ipswich Urban Character Study supplementary planning document and in Conservation Area Statements and Management Plans.

9.15.6 The NPPF states that planning policies should promote public safety by ensuring appropriate and proportionate steps are taken to reduce vulnerability, increase resilience and ensure public safety and security. Although the subject of fire safety is covered by part B of the Building Regulations, it is important that proposals for tall buildings achieve the highest standards of fire safety, reducing risk to life, providing acceptable means of escape and ensuring that risk to life is as low as possible. To achieve this, applicants should consider whether the building materials (e.g. cladding) is suitable from the outset and that built-in emergency responses to fire, such as sprinkler systems, are accounted for.

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

9.16.1 Extensions should be subordinate to the original building in terms of scale and situation. A harmonious contrast with the existing property and surroundings may be appropriate for some new work to distinguish it from the existing building; in other cases, closely matching materials and design details are more appropriate so as to ensure the new work blends with the old.

9.16.2 Extensions to the side of houses are particularly visible. In these cases, it is important to reflect the character of the street and ensure than an extension is not visually dominant in a way that detracts from its surroundings. Extensions should be set back from the building line by four metres. They should also ensure that, where gaps between dwellings are a key part of the character of the street, they are retained.

9.16.3 In many streets in the borough houses have mature rear gardens that can often be seen through gaps between buildings, softening the urban scene and providing visual interest. Care should be taken to ensure that two storey and first floor side extensions to semi-detached or detached houses do not reduce the width or close the gaps between houses and create a 'terracing effect'. Such extensions would normally have to be set back behind the main front wall of the house by 4 metres. However, where schemes include recesses, these must be designed to avoid providing the opportunity for anti-social behaviour or crime. Further information on designing safer environments is set out in Secured by Design Homes 2019. Such development should also maintain external access to rear gardens. The Space and Design Guidelines supplementary planning document adopted in November 2015 provides more guidance.

9.16.4 The construction of structures in rear gardens and other undeveloped areas can often have a significant impact upon the amenity, biodiversity and character of an area. They may detract from the generally soft and green nature of gardens and other open space, contributing to the loss of amenity for existing and future residents of the property. As such an extension or self-contained annex should not result in the loss of more than 50% of the useable private garden area.

9.16.5 The Council has seen a rise in residential annexes in recent years. Development which assists households to adapt to changing circumstances should be supported so long as it forms a physical link to an existing dwellinghouse and retains a functional relationship involving some shared facilities. To qualify as an annex the accommodation should have a degree of dependency on the main dwelling house to ensure a single planning unit is retained and a separate residential dwelling is not created. When the use has ceased the annex should continue to be used ancillary to the main dwellinghouse and not separately used, occupied or let.

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

9.17.2 The potential exists for quality design approached which contrast positively with the surrounding architectural character, and this will be encouraged where there is no conflict in terms of scale, density, vehicle use or other considerations.

9.17.3 In the case of severance plots, it is important that the original dwelling(s) shall retain sufficient garden space to meet the Council's minimum standards. The Council's Space and Design Guidelines supplementary planning document will also apply.

Visual Privacy and overlooking

9.18.1 Interior and exterior spaces that are overlooked lack privacy, which can affect the quality of life of occupants. The Council will therefore expect development to be designed to protect the privacy of the occupants of both new and existing dwellings to a reasonable degree. New buildings, extensions, roof terraces, balconies and the location of new windows should be carefully designed to avoid overlooking. The extent of overlooking will be assessed on a case-by-case basis. The places most sensitive to overlooking are typically habitable rooms and gardens at the rear of residential buildings. Habitable rooms are considered to be residential living spaces including dining and siting rooms, bedrooms and kitchens. The area of garden nearest to the window of a habitable room is most sensitive to overlooking.

Sunlight, daylight, overshadowing and artificial light levels

9.18.2 Loss of daylight and sunlight can be caused if spaces are overshadowed by development. To assess whether acceptable levels of daylight and sunlight are available to habitable spaces, the council will take into account the most recent guidance published by the building research establishment (currently the Building Research Establishment's Site Layout for Planning for Daylight and Sunlight – A Guide to Good Practice 2011).

9.18.3 Lighting creates a sense of safety and can enable activities in the evenings and at night. Lighting can increase the potential for natural surveillance and, where used correctly, can reduce the opportunity for criminal activity. However, poorly designed internal and external lighting or lighting that operates for an excessive period of time is a form of pollution that can harm the quality of life for those living nearby, affect wildlife and waste energy.

9.18.4 For example, lighting from conservatories can affect neighbours to the sides and rear, and the lighting of advertisements can affect people living nearby. Glare and light spillage from poorly designed lighting can make it less easy to see things at night and effect wildlife as well as people. Lighting should only illuminate the intended area and not affect or impact on its surroundings. Smart lighting systems and controls on the strength of light bulbs for external lights should be considered.

9.18.5 Schemes involving floodlighting and developments in sensitive areas, such as adjacent to sites of nature conservation importance, should employ a specialist lighting engineer accredited by the Institute of Lighting Engineers to ensure that artificial lighting causes minimal disturbance to occupiers and wildlife.

Noise and vibration levels

9.18.6 Where uses sensitive to noise are proposed close to an existing source of noise or when development that is likely to generate noise is proposed, the Council will require an acoustic report to accompany the application.

9.18.7 The planning process can assist by ensuring that as far as possible noise sensitive developments such as dwellings, schools, hospitals and nursing homes, are located away from existing sources of noise and that potentially noisy developments are located in areas where noise will not be such an important consideration.

9.18.8 Measures can be required to control exposure to noise through planning conditions. For example developers may be required to insulate buildings, erect screens or natural barriers or limit operating times.

Odour, fumes, dust and ventilation

9.18.9 There are a number of factors which contribute to the quality of new development including ventilation. New buildings should have good ventilation and extraction systems to help expel pollutants, bacteria and moisture.

9.18.10 Odours, fumes and dust can be generated from commercial cooking, industrial processes, construction or demolition.              

9.18.11 We will require all development likely to generate odour, fumes or dust to install appropriate extraction equipment and other mitigation measures.

Contaminated land

9.18.12 Development on contaminated land can expose people to a wide range of potential health risks and can mobilise contaminants. Applicants who wish to develop suspected contaminated land will be required to undertake a thorough investigation of the site to determine any risk to human health and controlled waters (including groundwater). Relevant remediation and mitigation measures will need to be built into development proposals to ensure safe, sustainable development of the site.

9.19.1 In order to maintain the variety of housing stock in the Ipswich to meet future needs, in particular the needs for family housing, Policy DM19 states that only existing dwellings with 4 or more bedrooms will be considered suitable for subdivision. It is also to ensure that the new units created provide an acceptable standard of accommodation in terms of internal arrangement and room sizes. Whilst the creation of self-contained flats and the subdivision of large properties can help to meet housing need, in some instances their provision can be detrimental to the amenity of existing residential areas.

9.19.2 Any future growth of the University of Suffolk and Suffolk New College and the likely increase in demand for flats, bedsits and houses in multiple occupation provide a further justification for a policy specific to Ipswich in order to ensure that conversions are appropriate. The Council requires applicants to consider the amenity of residents in adjacent dwellings, and within the building itself. The latter will be assisted through careful internal layout, which for example avoids positioning living rooms next to bedrooms in adjacent dwellings and within the building itself. The Council will also require all developments to incorporate appropriate secure by design principles to help reduce opportunities for crime, the fear of crime and to create a more safe and secure environment. Further information on designing safer environments is set out in Secured by Design Homes 2019'.

9.19.3 There are potential adverse effects from such conversions, particularly where there are concentrations. The significant loss of family housing can erode the character of an area through insensitive individual conversions and the cumulative impacts of physical changes to properties as a result of such use. Such streets are suffering from impacts such as significant car parking problems; clutter and untidiness; unsightly accumulation of satellite dishes; poor building maintenance; increased activity, noise and nuisance, etc. The quality of conversions, particularly where unregulated, can also be poor, with poor standards of accommodation and health and safety concerns.

9.19.4 Conversions, either individually or cumulatively, can also have a harmful impact on the character of the area through unduly diluting mixed and sustainable communities. In certain parts of the Borough, there are high concentrations of flat conversions and houses in multiple occupation, in part reflecting the very high student population which is especially prevalent around the University. Given that students are predominantly present during term time only, it can leave some roads and areas feeling quite dormant at other times, failing to achieve a mixed and sustainable community. In locations with already high numbers of flats or houses in multiple occupation, conversions to single family housing could help create a more mixed and sustainable community.

9.19.5 Where the proposal for sub-dividing family dwellings results in a house of multiple occupation, this will be subject to the requirements of policy DM20.

9.19.1 According to the Housing Act 2004, a House in Multiple Occupation, or HMO, is a building, or part of a building, that is occupied by persons who do not form a single household - in other words, are not family members. For example:

• A house converted into three or more bedsits;
• A house converted into self-contained flats where fewer than two thirds of the flats are owner occupied and the flats were not converted in accordance with the 1991 Building Regulations;
• A house occupied by three friends who rent from a private landlord;
• A house let to a group of four students;
• A flat with three or more bedsits (even if the flats were converted in accordance with the 1991 Building Regulations and more than two thirds of the flats in the building are owner occupied); and
• A house occupied by a married couple and a friend.

9.19.2 Since April 2010, all landlords must apply for planning permission when converting a property into a House in Multiple Occupation (HMO). An application for planning permission will not be required where there are not more than six person living together as a single household.

9.19.3 For the purposes of 'living together as a single household' all amenities should be shared and individual rooms and spaces should be accessible to the general household, including bedrooms, bathrooms and kitchens including kitchen space i.e cupboards etc.

9.19.4 It is recognised that the provision of HMOs is needed to provide an affordable form of housing, particularly for young people, those on lower incomes and students, however, it is important that in approving an HMO, this does not have a significant negative impact on the residential amenity of neighbouring residents.

9.19.5 High concentrations of HMOs can have a detrimental effect on communities, through higher levels of general activity compared to what would normally be associated with a single dwelling house. This includes more intensive use of gardens for amenity purposes; noise and disturbance; additional waste and cycle storage; additional car parking in the vicinity of the building (either off-street or on-street); and more recently, the impact on neighbour amenity from building works associated with the conversions. Furthermore, additional occupancy levels can increase pressure on local services and potentially impact on social cohesion, given the likely higher turnover of occupants and generally more transient population associated with HMOs.

9.19.6 There continues to be a growth in the number of HMOs in Ipswich, with around 800 HMOs currently identified. HMOs need to be licenced when there are 5 or more people. Of these 800 HMOs in Ipswich, 78 are currently licenced.

9.19.7 From 1st October 2018, landlords of Houses in Multiple Occupation (HMOs) that have five or more people forming more than one household will need to have applied for a Mandatory HMO licence. Although licensing allows a degree of control to be exercised on the premises (e.g. fire standards), it does not cover the principle of such development or the manner in which the increased occupancy may affect the amenity of neighbouring properties.

9.19.8 The Council is in the process of implementing a Borough-wide Article 4 direction which removes the permitted development right for the change of use from C3 (dwellinghouse) to C4 (house in multiple occupation) for three to six unrelated persons. Therefore, once this comes under force, planning permission is required for all development and changes of use that create a HMO. This is not designed to prevent HMO's as a form of housing, rather to maintain an element of control so that high concentrations of HMO's do not arise negatively impacting on the residential amenities of surrounding residents.

9.19.9 Proposals will need to demonstrate that the building is large enough to accommodate the number of occupants proposed and provide an adequate living environment for its future occupants.

9.19.10 Applicants will be required to demonstrate that there will not be an over-concentration of HMOs in the local area. Exemptions to the above guidelines for defining over-concentration will only be considered where it can be adequately demonstrated that the change of use to a HMO will not harm the amenity of the local area.

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

9.21.2 Ipswich is a regional transport node and a compact town and therefore it should be possible to access the town centre and other parts of the town by sustainable means. In accordance with the Ipswich Strategic Planning Area (ISPA) Transport Mitigation Strategy, the Council is keen to ensure that a modal shift away from the car can occur within the Borough. The main elements of the ISPA Transport Mitigation Strategy are listed in policy CS20. This policy should also be considered alongside the growth aims of the Local Plan Strategy, principally policy CS2.

9.21.3 The Council will need to be satisfied that the impacts can be managed in a satisfactory way and that suitable additional infrastructure provision is made where necessary. Where relevant, development should take opportunities for providing new infrastructure through well-designed cycle and pedestrian routes. It should also link with public transport facilities and services and seek to improve existing rights of way to reduce journey times to employment, schools and services and support active travel.

9.21.4 The Suffolk Rights of Way Improvement Plan is under review. The 'Suffolk Green Access Strategy' will replace 'In Step With Suffolk' and set out the aims, objectives and delivery plans for a further 10 years. This Council also expects development on sites which abut or relate closely to the town's rivers to provide for the improvement of public access alongside these. The Public Rights of Way network is more than just a means of reducing vehicular traffic. In addition to connecting areas and providing opportunities for physical recreation and social interaction, it provides vital access to services, facilities and the natural environment. In this sense it is a major recreational resource, economic asset and means of promoting mental and physical health. These benefits must be taken into account in the design of development along with the contributions it might make to sustainable routes and open space provision. Development which may affect Rights of Way will not be permitted unless it can demonstrate how it protects or enhances the network. Where development cannot avoid detriment to the Rights of Way Network, it should demonstrate how suitable alternative provision will be made. This Council also expects development on sites which abut or relate closely to the town's rivers to provide for the improvement of public access alongside them.

9.21.5 Necessary mitigating measures to improve public transport infrastructure and services may be secured where this would reasonably relate to a development, whilst the introduction of car club schemes or pool cars in larger developments may also contribute to reducing levels of private car ownership in the town (the need for car club provision in new developments will generally be informed by the agreed findings of a Travel Plan). Criterion e. of the policy would not be applied unreasonably if limited parts of a development were unavoidably slightly further than 400m from public transport. The inclusion of electric vehicle charging points in residential plots, employment and retail developments and commercial car parks are also considered a sustainable measure that can help to reduce greenhouse gas emissions in line with the aims of the National Planning Policy Framework. The provision of charging points for electric vehicles within new developments should be made in accordance with the Suffolk Guidance for Parking (November 2015, amended May 2019).

9.21.6 The Council promotes the provision of car club spaces due to their proven ability to reduce car ownership and, in particular, second car ownership. Similarly, the Council will seek low emission vehicle infrastructure in the form of active electric vehicle (EV) charging points.

9.21.7 Additionally, new developments containing communal residential parking facilities, retail development and employment development should aim to deliver active charging capacity in accordance with the Suffolk Guidance for Parking. The proportion of rapid charging points will be specified through the Low Emissions Supplementary Planning Document, taking into account viability considerations. In terms of car club spaces, 100 per cent of such spaces should have the passive capacity for eventual EV charging. Further details of the Council's EV and car club approach are to be outlined in the emerging Low Emissions Strategy Supplementary Planning Document.

9.21.8 In proposals for the development of 30 to 49 dwellings, 1,500 – 2,499 sq. m B1, 2,500 – 3,999 sq. m B2/B8, or 800 – 1,499 sq. m retail a transport statement will generally be required with a planning application. For development of or exceeding 50 dwellings, 2,500 sq m B1, 4,000 sq m B2/B8, or 1,500 sq m retail, a transport assessment will generally be required. Some smaller sites, in very sensitive locations, may require a transport assessment due to significant traffic impacts. Conversely, some larger sites may not give rise to significant impacts if they are in parts of the network that are not likely to be under pressure. A long term management strategy (Travel Plan) to increase sustainable patterns of travel to a site will also be secured in some instances. The degree of negative impact of a development will be determined by the Council in conjunction with the Highways Authority on a case by case basis, as this will also depend on the spatial context of the individual planning application under consideration.

9.21.9 Where a development is likely to have an impact on an Air Quality Management Area or other sensitive area, an assessment of the air quality impacts of the development will be needed with appropriate mitigation measures proposed as necessary. Policy DM3 sets out the requirements in relation to air quality. Confirmation on the level and extent of transport and highways reports that would be required to support development proposals can be found within the Council's Validation Checklist.

9.22.1 Ipswich has a strategic objective to improve accessibility (CS5). This policy provides further requirements in terms of the quality and quantity of car and cycle parking provision. Standards for provision outside IP-One will be as set out in the Suffolk Guidance for Parking (2019) and any subsequent document.

9.22.2 Cycling is an increasingly important and sustainable means of travel. The Council will therefore expect cycle parking to be safe, convenient and secure and preferably subject to natural surveillance, so that users of a development are more likely to use bicycles to travel to and from a site. Where relevant, development should take opportunities for providing high quality cycle storage with workplace shower and locker facilities. Details regarding cycle parking standards and design can be found within the Suffolk Guidance for Parking (November 2015, updated May 2019).

9.22.3 The emphasis on provision for both residential and commercial development relates to more strategic measures being taken across the town to improve cycle routes, through the Local Transport Plan and the Ipswich Cycling Strategy.

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

9.22.5 Local planning authorities are now free to apply parking standards that are appropriate and necessary to address local circumstances. In Ipswich, the standards within the Suffolk Guidance for Parking (November 2015, updated May 2019) are currently being applied. Standards for residential parking within IP-One will be identified through the Low Emissions Strategy Supplementary Planning Document, which is under preparation.

9.22.6 Whilst the emphasis of transport policy remains firmly on encouraging people to switch to more sustainable modes where possible, it is also recognised that many people still own cars. Therefore, adequate levels of residential parking should be provided that uses land efficiently and is designed in from the outset to ensure that cars do not dominate the street scene. Underground parking is also an efficient way to accommodate the car and should be considered where this is acceptable in flood risk terms as demonstrated through a Flood Risk Assessment. Car parking can be appropriate in areas subject to flooding, provided that flood warnings are available and signs are in place. When considering car parking within flood risk areas, the ability of people to move their cars within the flood warning time should be considered. Boundary treatments such as railings should ensure that if vehicles become mobilised during a flood event, they are contained within the confines of the site but still allow the free movement of flood water. Long-term and residential car parking is unlikely to be acceptable in areas which regularly flood to a significant depth due to the risk of car owners being away from the area and being unable to move their cars when a flood occurs.

9.22.7 There are a number of publications which look at the design of car parking in more detail, notably 'Car Parking: What Works Where' (English Partnerships, 2006) and 'Manual for Streets' (Department for Transport, 2007). Where communal parking is necessary, rear parking courtyards should be avoided unless they are well-designed and overlooked. Owners should preferably be able to view their vehicles from active rooms within the building. Secure By Design guidance should be followed when providing underground parking to ensure that it is safe and secure.

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

9.23.1 The NPPF states the plans should include the use of minimum density standards for town centres and other locations that are well served by public transport. It also recommends that minimum density standards should be considered for other parts of the plan area that reflect the accessibility and potential of different areas. The three minimum density standards set out in the policy provide an appropriate balance of densities for different areas of Ipswich, based on their accessibility and surroundings, and will help to make efficient use of land in the town.

9.23.2 Between 2001 and 2014 the main housing supply in Ipswich has been flats and as a result actual densities achieved residential schemes in Ipswich have been high. Housing completions in Ipswich broadly followed the trend in England growing to a peak in 2007/8, followed by decline until 2012/13 and a recovery thereafter. The 2007/08 peak included large-scale flatted development at the Ipswich Waterfront. Densities are reported in the Council's annual Authority Monitoring Report.

9.23.3 However, the density figures in the policy (especially the high density figure) were revised downwards as part of the 2017 Local Plan, to take account of the following factors:

• The effect of the economic downturn on market demand for flats;
• The need for the balance of housing delivery to swing towards houses until the market for flats recovered;
• Sustainable design such as designing for passive solar gain, which will be essential to meeting the Borough's carbon reduction obligations, can impact on the layouts and configurations that may be achievable;
• Sustainable drainage requires more space in some areas of town and impacts on achievable site density;
• Flats will still be needed, but they may need to be bigger to attract older households away from family houses, and in some cases to cater for families also; and
• The mix policy for larger sites (policy CS8) means that 100% flatted development on most major scheme sites will not be acceptable.
  4. Ipswich Borough Council has reviewed the densities outlined in the policy in relation to viability. However early viability testing indicates that higher densities are unlikely to be viable due to a combination of rising build costs and relatively low sales values for flats, particularly larger two and three-bedroom flats. The results of the Viability Assessment of the Local Plan Review will provide further information on this. Notwithstanding this, the densities set out in the policy are minimum standards and this does not prevent developments being brought forward at higher levels where appropriate.
  5. In the vicinity of the Waterfront and Civic Drive in central Ipswich, the Council will expect high density developments to exceed the minimum set out in the policy, because this is the area where tall buildings may be appropriate as identified through policy DM15. This also more closely reflects site capacities achieved through recent planning permissions. The Council will expect all new residential developments to meet the Nationally Described Space Standards set out in Technical Housing Standards – Nationally Described Space Standard (Communities and Local Government, 2015). This is in order to ensure that future occupants have acceptable living conditions and that there is enough space, including sufficient storage, for dwellings to be used flexibly by a range of residents.
  6. It is important to strike an appropriate balance between providing freedom and flexibility for the housing market to operate and ensuring that land is used efficiently by achieving higher densities in the most sustainable locations. The exceptions in the above policy allow a degree of flexibility in controlled conditions, such as for example to protect heritage assets and landscape. Sites on the urban edge of Ipswich may require lower densities in certain circumstances where development needs to respond sensitively to the adjacent countryside and surrounding character. The averages referred to will be used to calculate site capacities.

Community Facilities

9.24.1 This policy seeks to maintain a range of local community facilities across the borough to meet local needs.

9.24.2 For the purpose of this policy, community facilities include a range of social infrastructure that provides a service to the community. This may include:

• Healthcare facilities;
• places of worship;
• meeting halls;
• public houses;
• post offices;
• youth clubs;
• education facilities; and
• police facilities.

9.24.3 These facilities form a vital part of town centres and neighbourhoods and address the local community's needs. Community uses are different to Town Centre Uses in this respect (see policy CS14).

9.24.4 Open space, play provision and arts and cultural facilities are also important community facilities and are dealt with under separate policies.

9.24.5 Part A seeks to resist the loss of the borough's valuable community facilities, except in certain circumstances (see a and b).

9.24.6 In order to demonstrate that there is no demand for the continued use of the current community facility, sufficient marketing evidence should be provided which adequately illustrates that there is no longer a genuine need for its retention. Details of the marketing requirements are set out in appendix 6. In the case of health facilities, the loss or change of use of existing health facilities will be acceptable if it is shown that this forms part of a wider estate reorganisation programme to ensure the continued delivery of services. Evidence of such a programme will be accepted as a clear demonstration that the facility under consideration is neither needed nor viable and that adequate facilities are or will be made available to meet the ongoing needs of the local population. In such cases no viability or marketing information will be required.

Public Houses

9.24.7 Public houses (pubs) play an important community and cultural role. As places where members of the community meet and gather, they support social wellbeing and strengthen community cohesion. They sometimes provide important community meeting space and host local meetings, events and entertainment.

9.24.8 Like many other boroughs, Ipswich has witnessed a net loss of public houses. The policy therefore aims to afford greater protection to the boroughs public houses.

9.24.9 National planning policy recognises that public houses, along with other community facilities, enhance the sustainability of local communities and should be safeguarded and retained for the benefit of the community while allowing them to develop and modernise in a sustainable way.

9.24.10 The overall aim of the policy is to ensure that the Council is able to protect all of its public houses which provide a significant benefit or value to the local community.

9.24.11 In order to satisfy the policy a marketing strategy for the public house must be agreed with the Local Planning Authority prior to its implementation and the agreed strategy implemented for a minimum period of 12 months prior to applying for planning permission. Further information regarding the requirements of the marketing strategy are set out in appendix 6.

9.24.12 Applicants seeking to reduce or remove floor space or outdoor space must demonstrate that the remaining space is of sufficient size and quality for the needs of pub users and that the pub could continue to operate viably following any loss or reduction. The information submitted should include as a minimum viability evidence which considers the ability of the pub to continue to trade.

Protecting existing shopfronts

9.25.1 This policy gives effect to Core Strategy policy CS1. It builds on national policy in the National Planning Policy Framework which states that planning plays a key role in supporting the delivery of renewable and low carbon energy.

9.25.2 We will seek to protect existing shopfronts that make a significant contribution to the appearance and character of an area, taking into account the quality of design, historic importance and location.

Design of new shopfronts

9.25.3 The attractiveness of shopfronts can usually best be maintained by taking inspiration from the architecture of the building and neighbouring premises and reflecting the scale and pattern of shopfront widths in the area. New shopfronts should contribute towards the maintenance of a cohesive streetscape appearance. The Council will seek to repair harm caused through past unsympathetic development whether previously authorised or not.

9.25.4 As shopfronts are seen at close quarters, the detailing, type and quality of materials, execution and finishes are very important. Contemporary shopfront designs will be supported in appropriate locations. All new and altered shopfronts should be designed to be fully accessible for all.

Shop windows

9.25.5 Shop windows provide views into and from premises and can help bring activity and enhance feelings of security by providing natural surveillance. Security features associated with shop window displays should generally be internal in order to avoid harming the appearance of shop premises and creating clutter. Solid shutters are generally not considered to be acceptable as they are unsightly and can generate feelings of insecurity in those walking by, hide internal intruders, and encourage graffiti.

9.25.6 The supplementary planning document Shop Front Design Guide provides more detail on the Council's approach to the design of shopfronts.

9.26.1 Advertisements and signs should be designed to be complementary to and preserve the character of the host building and local area.

9.26.2 The supplementary planning document Shop Front Design Guide provides more detail on the Council's approach to the design of shopfronts.

9.26.3 The size, location, materials, details and illumination of signs must be carefully considered. The Council will resist advertisements where they contribute to or constitute clutter or an unsightly proliferation of signage in the area.

9.26.4 Advertisements in conservation areas and on or near listed buildings require particularly detailed consideration given the sensitivity and historic nature of these areas or buildings. Any advertisements on or near a listed building or in a conservation area must not harm their character and appearance and must not obscure or damage specific architectural features of buildings.

9.26.5 Advertisements should not become unduly dominant in the street scene, cause light pollution that disturbs residents at night, cause light pollution to wildlife habitats, or cause safety hazards to drivers. To achieve these aims, consideration should be given to the intensity of illumination, surface area to be illuminated and the positioning and colours of advertisements. The type and appearance of illuminated signs should be sympathetic to the design of the building on which it is located. The method of illumination (internal, external, lettering, neon, etc.) should be determined by the design of the building. Illuminated signs, both internal and external, should not be flashing or intermittent.

9.26.6 Advertisements will not be considered acceptable where they impact upon public safety, including when they:

• obstruct or impair sight lines to road users at junctions and corners;
• reduce the effectiveness of a traffic sign or signal;
• result in glare and dazzle or distract road users;
• distract road users because of their unusual nature;
• disrupt the free flow of pedestrian movement; or
• endanger pedestrians forcing them to step on to the road.

9.27.1 The Government recognises that the role of town centres is changing from its traditional retail high street approach. Town centres need to be dynamic and flexible in order to remain relevant and to be able to compete effectively with other retail sources such as on-line shopping as well as accommodating wider town centre uses. This is reflected in the Government NPPF and updated PPG 22 July 2019. The Government advises that Councils review the town centre and create character zones.

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

• Define a network and hierarchy of town centres and promote their long-term vitality and viability;
• Define the extent of centres and primary shopping areas;
• Retain and enhance existing markets;
• Allocate a range of suitable sites to meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community and residential development needed;
• Allocate appropriate edge of centre sites for main town centre uses that are well connected to the town centre, where suitable and viable town centre sites are not available; and
• Recognise that residential development often plays an important role in ensuring the vitality of centres.

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

9.27.4 The CSA boundary has been amended, to include additional land at Princes Street and exclude the former police station at Elm Street. These changes respond to evidence in the Ipswich Retail and Commercial Leisure Study 2017. The Council considers that the boundary changes will help to strengthen the CSA's vitality and viability. Annual monitoring of town centre indicators such as shop vacancy will continue to be used to assess the CSA's health.

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

9.27.6 The CSA is therefore divided into three 'Shopping Zones'. The Primary Shopping Zone is the area where the greatest concentration of A1 retail uses is expected. It is a relatively small area which largely coincides with the 'prime pitch' for retailers and it has the highest rents and footfall. The Secondary Shopping Zones are generally characterised by lower rents and footfall than the Primary Shopping Zone. In these areas, the focus remains on A1 retailing, but a greater diversity of uses is permitted. The Specialist Shopping Zones contain the greatest diversity of uses. Shops tend to be in smaller units occupied by more specialist retailers. Some of the streets in this area consist of attractive historic buildings, which give them a special character, for example St Peters Street and Fore Street. For the purposes of the sequential approach to locating new retail development, only the Primary and Secondary Shopping Zones defined on the IP-One Area inset policies map would be considered 'in town centre' sites defined through the NPPF as the primary shopping area. The shops or units within each of the three zones in the CSA are broken down into groups. The groups usually consist of a collection of buildings located in close proximity fronting the street or pavement, segregated by intersecting streets.

9.27.7 The previous Local Plan assessed individual frontages within each zone, which were monitored and updated annually. In practice, however, the application of applying the thresholds of each zone to individual frontages resulted in a policy that was unable to respond to the changing make-up and retail experience of these zones. There were instances where the policy restricted empty retail (A1) units from being brought back into alternative uses due to concentrations of non-A1 uses on a particular street frontage being too high. In addition, the frontage measurement approach often made it difficult to apply flexibility to given frontages, as some uses had frontage lengths that were disproportionate to the length of the street.

9.27.8 To respond to the above issues, the frontages have now been amalgamated to support a greater degree of flexibility in the CSA. The Primary Shopping Zone is formed of one centralised area in the heart of the town. The Secondary Shopping Zones consist of Upper Westgate Street ('Sec4'); Lloyds Avenue ('Sec5'), Queen Street & Princes Street ('Sec3'); and Carr Street & Upper Brook Street ('Sec6'). The Specialist Shopping Zones are made up of the units to the south of the CSA in 'the Saints' and Fore Street ('Spec1'), and a small group at Providence Street ('Spec2'). These are demarcated on the map provided at Appendix 7.

9.27.9 In addition, the process for counting the percentages within each zone has been changed from a frontage measurement approach to a unit number approach to provide a more straightforward means of calculating the percentages. The zones will continue to be updated in the yearly Central Shopping Area Survey Report and this will form the basis of determining the proportion of units in a given area, unless more recent verified evidence is provided with applications.

9.27.10 In cases where applicants are proposing a change of use from an A1 to a non-A1 use that would fall above the defined thresholds, it is advised that they enter into pre-application discussions with the Council to determine the type of information that would be required to robustly demonstrate that it would add to the vitality and viability of the zone. In order to demonstrate that exceptional circumstances warrant the proposed non-A1 use, the following factors will be considered:

• The amount of time that the existing use has been vacant, including any information regarding the marketing of the unit;
• The presence of other vacant A1 units in the Shopping Zone, including any information regarding the marketing of these units;
• The contribution that the proposed non-A1 use would make to the vitality and viability of the Shopping Zone and wider Central Shopping Area;
• The active frontage of the proposed non-A1 use, taking into consideration the physical frontage, hours of use and type of use; and
• The size of the unit.

9.27.11 The approach to land use within the CSA is to maintain a balance between A1 retail and other appropriate uses, through the control of units within the zones. The Town and Country Planning General Permitted Development Order 2015 introduced new permitted development rights for existing A1 units however the policy remains relevant due to size limitations contained within the new Order. Uses in the CSA are monitored and updated annually.

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

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

9.27.14 Mixed-use development will be supported in the Central Shopping Area only where a ground floor use in accordance with policy DM27 is provided. This reflects government policy to encourage diversification and mixed uses, and can help to create a vibrant centre including outside shopping hours. Main town centre uses as defined in the NPPF will only be permitted within the Central Shopping Area where specified criteria are met as set out in policy DM27.

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

9.27.16 The Council will seek funding opportunities to make environmental enhancements to the public realm of the centre and help it to remain competitive and attractive to users. The priority for improvements during the plan period will be the Cornhill, Tavern Street and Westgate Street. These enhancements should follow the key design principles set out in the Council's SPD "Ipswich Town Centre and Waterfront Public Realm Strategy" with a view to creating a dementia-friendly environment and a public realm fit for all. Where shopfronts are vacant and no longer providing an active frontage on the street, the Council will support opportunities to successfully use these frontages where they help to promote the vitality of the Town Centre. This could be through visual enhancements. Works to the shopfront which require advertisement consent and/or planning permission will need to also adhere to the principles of policies DM25 (shopfront) and DM26 (advertisements), as well as the Shopfront Design Guide SPD.

9.28.1 The town has a wealth of arts, cultural and heritage assets, which enrich the lives of Ipswich residents and bring in a significant number of visitors. There are approximately 2.6 million day visitors per year and 1.0 million longer stay visitors, including those from overseas and the rest of the UK (Ipswich Town Centre Master Plan, 2012). They support directly and indirectly a significant number of full and part-time jobs.

9.28.2 Focussing art, cultural and tourism uses within the town centre will aid in the delivery of the spatial strategy for sustainable growth through urban renaissance, by making the best use of previously developed land, by putting facilities in close proximity to those who need them, and by providing regeneration opportunities to key strategic town centre sites, thus enhancing the vitality and vibrancy of the central area. It also accords with national planning policy for 'main town centre uses'.

9.28.3 The Council's intention is to support the diverse nature of arts, cultural and heritage facilities in Ipswich, by allowing improvements to existing facilities. These assets support employment in a fast growing sector, and generate economic activity which in turn supports town centre regeneration, and provides cultural diversity and choice for those living in and visiting Ipswich. Arts, cultural and heritage assets contribute to the vitality and viability of the town centre by providing attractions and facilities which are complementary to the main retail and employment function, and can be easily accessed.

9.28.4 The English Tourism Board has indicated that Tourism is worth £5 billion a year to the Eastern Region, with the tourism sector now employing 185,000 people. Tourism is one of the main components of the visitor economy and it has been identified as one of the fastest growing sectors of the global economy. Visitor accommodation is integral to the provision of jobs growth in Ipswich, and as such the provision of quality accommodation for a wide variety of visitor needs will support the objectives of policy CS13.

9.28.5 Policy CS4 identifies the Council's commitment to protecting and enhancing the Borough's heritage of built, historic and natural assets including listed buildings, museums, parks and gardens and the river corridor. The cultural activity associated with these assets provides a crucial link with the visitor economy and should therefore be maintained and enhanced to ensure that this offer remains attractive. Retaining and enhancing existing facilities will benefit heritage assets that are currently used for arts, cultural and tourism purposes, while new facilities could also be beneficial provided they are appropriately design and located. Core Strategy Review policy DM13 deals with heritage assets and conservation. The Council's Town Centre Master Plan (2012) identifies improved facilities for performance arts, arts, museums and heritage, public art and events as areas to support.

9.28.6 The Council will therefore be supportive of:

• Improvements to Ipswich Museum and adjacent buildings, including Ipswich Art School, Wolsey Studio, and High Street Exhibition Gallery;
• the New Wolsey Theatre, Corn Exchange and Regent Theatre;
• Christchurch Mansion and Park; and
• the creation of a multi-purpose exhibition and conference facility, which could include a live entertainment venue, at the Waterfront.

9.28.7 The Council will also support street performance and 'pop-up' temporary facilities related to cultural events and festivals in appropriately located public spaces and vacant premises, where they do not prejudice other Local Plan policies.

9.28.8 High quality arts and cultural facilities play an important role in attracting and retaining residents to the town. The IBC Culture and Leisure Needs Study 2010-2025 found that quality provision and a thriving arts and cultural scene can help to increase a town's appeal to students selecting a university and retain graduates on completion of their degree due to their positive experiences. It is seen that the encouragement of street theatre and performance in the town centre would help to develop awareness of, and exposure to, the arts, and therefore be of benefit to the visitor economy.

9.29.1 Evening activities that take place after 5pm can help maintain a strong and successful town centre vibrancy, as they extend activity and movement beyond the normal working hours. This makes town centres more attractive places to live and work. It is, however, important to maintain the right balance with the town centre's primary function as a shopping and commercial centre. The evening uses must therefore be complementary to, rather than conflict with, other town centre uses. The evening and night-time economy in Ipswich has developed over many years. If managed well a successful evening and night-time economy becomes an important part of the town's character. The economy can be boosted by the creation of jobs, increased visitor numbers and providing the right atmosphere to enhance the town's offer of arts and cultural events. The council will plan positively for a range of complementary evening and night-time uses including the arts, culture and entertainment uses that can appeal to a wide cross-section of the population and a variety of age groups.

9.29.2 The promotion of an evening and night time economy in Ipswich needs to be appropriately managed to ensure that community safety is protected and anti-social behaviour is not increased. Proposals should be sited in appropriate locations, and should consider the cumulative impact on the character and function of the town centre, crime and local amenity.

9.29.3 In some town centre locations the clustering of evening and night-time uses has led to an adverse impact on local amenity. Proposals which exacerbate existing problems, such as anti-social behaviour, will be resisted by the council.

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

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

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

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

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

9.30.5 The policy will help focus community development in the Local and District Centres. The community facilities are defined in Appendix 2.

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

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

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

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

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

9.30.10 The policy allows change of use to take place from retail to proposals for community uses where certain criteria apply. Residential uses will be encouraged on upper floors in the centres and in the vicinity of the centres to maximise access to shops and facilities. Accessible under clause f of policy DM30 relates to community facilities being accessible by a range of transport modes including for those without a car.

9.30.11 The boundaries of the District Centres are shown on the policies map and, within them, policy DM30 applies to development proposals. Developers of new properties will be expected to comply with policy DM28 and the Shopfront Design Guide SPD.

9.31.1 The National Planning Policy Framework (NPPF) defines a town centre as an area defined on the policies map, which includes the primary shopping area and areas predominantly occupied by main town centre uses within or adjacent to the primary shopping area. The main town centre uses are defined in the following paragraph. In the Ipswich Local Plan, the primary shopping area consists of the Primary and Secondary Shopping Frontage Zones (see policy DM27).

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

9.31.3 The non-retail main town centre uses which are managed through this policy are predominantly focused away from the Central Shopping Area, with the exception of a small element permitted in the Secondary and Specialist Shopping Areas or as part of certain mixed use developments as described in policy DM27, in order to maintain A1 retail use as the predominant use in the Central Shopping Area. For the development of non-retail town centre uses outside the Town Centre, the NPPF shall apply.

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

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

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

9.32.2 Out of town retail parks, sole retail warehouses and large foodstores (such as supermarket and superstores) are not defined as centres and therefore policy DM31 should apply to proposals within these locations. Retail warehouses are large stores specialising in the sale of household goods (such as carpets, furniture and electrical goods), DIY items and other ranges of bulky goods, generally selling goods that would require transportation by car.

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

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

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

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

• to prevent developments from being sub-divided into a number of smaller shops or units;

• to ensure that ancillary elements remain ancillary to the main development, by allowing up to 10% or 200 sq. m of net floorspace (whichever is the smaller) to be devoted to ancillary and incidental goods taken together;

• to limit any internal alterations to increase the amount of gross floor space by specifying the maximum retail floor space permitted; and

• to limit the range of goods sold, and control the mix of convenience and comparison goods.

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

9.32.6 Policy DM32 applies to proposals which give rise to more than 200 sq.m net floorspace, either from a single unit or the aggregation of units within the proposed development. Retail proposals that are over 525 sq. m net will be required to undertake an impact assessment on all Defined Centres (including the Central Shopping Area) in the catchment area. Retail proposals that are over 200 sq. m net will be required to undertake an impact assessment on District and Local Centres in the catchment area. All impact assessments will need to consider the impact of the proposal on existing, committed and planned public and private investment in Defined Centres in the catchment area of the proposal, taking account of cumulative impact. The impact assessment should consider the impact of the proposal on the vitality and viability of Defined Centres.

9.32.7 The Retail and Commercial Leisure Study 2017, indicates that there is no need or justification for further major out-of-town retailing in Ipswich.

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

• firstly, to consider whether there are sites available in the Primary Shopping Area, comprising Primary and Secondary Shopping Frontage Zones and in the District and Local Centres only where the scale of the proposed development is appropriate to the catchment areas the centres serve;

• secondly, to consider sites in edge of centre locations as defined in the NPPF; and

• thirdly, to consider sites in out of centre locations.

9.33.1 The established Employment Areas across the Borough represent very significant clusters of employers providing jobs and therefore need to be safeguarded. The jobs growth target set out in policy CS13 means that protecting against the loss of employment areas is important. Protecting employment areas for employment use also retains choice of locations across the Borough for businesses to locate in. As consolidated employment areas, operational requirements such as 24 hour working or heavy goods access are also more likely to be capable of being met without adversely affecting the amenity of residential areas. Where compatible with adjacent uses, waste facilities could come forward on land within employment areas.

9.33.2 The loss of employment land, whether in existing employment use or within a defined Employment Area, could affect the Council's ability to achieve its employment objectives and job targets. Land and buildings in employment use may also come under pressure from other forms of development that tend to have higher values such as retail, leisure and housing. As a general principle therefore, such land needs to be protected.

9.33.3 Retail uses will not be permitted other than as small scale retailing ancillary to the main B class use. Ancillary uses are defined in terms of size of floorspace and there being a functional relationship with the main B class use. Ancillary retailing should be less than 10% of the floorspace or 200 sq. m net, whichever is the smaller.

9.33.4 To demonstrate no reasonable prospect of re-use for employment purposes over the plan period in accordance with the policy, applicants will be required to produce evidence that the site has been marketed actively for a continuous period of at least twelve months from the date of the first advertisement for employment uses as appropriate to the site. Further information on the marketing requirement are set out in appendix 6.

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

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

9.33.7 References to employment uses in this policy and reasoned justification exclude retail uses. Appropriate employment-generating sui generis uses referred to in the policy include uses such as car showrooms with accompanying workshops and waste facilities and excludes any sui generis use which includes retail orleisure as anything other than an ancillary use. Small scale services could include small gyms or cafes (use classes D2 or A3) providing facilities targeted at people working in the area. All uses, whether temporary or permanent, will be expected to provide appropriate facilities on the site for employees.

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

9.34.1 The Council is committed to securing a high-quality communication infrastructure. The lack of such infrastructure would potentially hold back on the Borough's competitiveness and economic well-being. The installation of digital infrastructure can also help to mitigate air quality impacts by reducing the need to travel through initiatives such as home working. Developers for all new sites (residential and non-residential) should engage with broadband providers to ensure that communications network infrastructure, capable of delivering at least superfast broadband, is installed as part of the build process. New properties should be provided with the internal infrastructure to ensure that they can be connected to the broadband communication network or the most up to date technology. The broadband should be installed on an open access basis allowing for use by a number of internet service providers, and cables should be threaded through resistant ducting to enable easy access to the fibre optic cable for future repair, replacement or upgrading.

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