Ipswich Borough Council Local Plan Site Allocations and Policies (incorporating IP-One Area Action Plan) DPD Review - Final Draft

Ended on the 2 March 2020

Part B The Policies

CHAPTER 4: Site Allocations

4.1 The Final Draft Core Strategy identifies targets for housing, jobs and retail growth through policies CS7, CS13 and CS14. This chapter sets out the site allocations to deliver some of that growth. Other Final Draft Core Strategy policies also address the matter, for example CS10 Ipswich Garden Suburb. Ipswich town centre retailing is dealt with in Chapter 5 'IP-One Area', but housing, employment, mixed use, open space and community facility site allocations are addressed below.

4.2 The threshold site size for making allocations is 0.1ha or 10 dwellings in the IP-One Area, and 0.2ha or 10 dwellings in the rest of the Borough. Sites below these thresholds are not usually allocated but may come forward. They are accounted for in supply calculations through small sites allowances (where they already have planning permission) or windfall allowances.

Policy SP1 The Protection of Allocated Sites

4.3 This policy introduces measures to reserve allocated sites for the uses proposed and thereby means any inappropriate alternative uses would be a departure from the development plan.

(1) Policy SP1 The protection of allocated sites

Sites will be safeguarded for the use(s) for which they have been allocated. The Council will only permit alternative uses on allocated sites if they are compatible with other plan objectives and policies, they do not harm the plan strategy and the applicant can demonstrate that the allocated use is:

a. No longer needed to meet planned development needs; or

b. Not viable or deliverable and likely to remain so during the plan period.

Where an allocated mix of uses is not viable or deliverable, the Council will prioritise the primary use and community uses (including open space) identified through the policies and the site sheet at Appendix 3A and negotiate the remainder of the mix.

4.4 The Council has specific requirements for the delivery of housing, jobs and retail development in the period up to 2036. Sites are allocated in this plan to enable the targets to be met. The allocations need to be backed by policy to ensure that they cannot easily be developed for alternative uses and thereby harm the Council's ability to achieve its growth targets. To demonstrate that the allocated use is not viable or deliverable in accordance with clause b., 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 the allocated use, in a manner consistent with the Council's marketing requirements set out in Appendix 6 of the Final Draft Core Strategy.

Policy SP2 Land Allocated for Housing

4.5 Through Final Draft Core Strategy policy CS7 'The Amount of Housing Required', the Council commits to allocating land to provide at least an additional 6,100 dwellings net to 2036. The following policy provides the detailed site allocations to deliver a proportion of that housing requirement.

(11) Policy SP2 Land allocated for housing

The following sites are allocated for residential development, or part residential development within mixed use developments as indicated in Table 1. Development will take into account appropriately the constraints identified through the site sheets contained in Appendix 3 of the plan.

Table 1 Land allocated for residential use or residential-led mixed use

Site ref.	Site name and development description		Site size ha (% residential on mixed use sites)	Indicative capacity (homes)	Capacity evidence	Likely delivery timescale (S, M, L)
IP003	Waste tip and employment area north of Sir Alf Ramsey Way Parts of the site are covered by facility retention policies of the Suffolk County Council Minerals and Waste Local Plan. Alternative sites will need to be agreed with the County Council and the site operators for the relocation of the Concrete Batching Plant and Household Waste Recycling Centre before the sites can be made available		1.41 (90%)	114	90dph (DM23a lower end of range)	L
IP004	Bus depot, Sir Alf Ramsey Way Allocated for mixed residential & B1 office use; historic depot to be retained and converted as part of B1.		1.07 (c. 50%)	48	90dph (DM23a lower end of range)	L
IP009	Victoria Nurseries, Westerfield Road		0.39	12	30dph (DM23c). Low density to reflect suburban location.	S
IP010a	Co-op Depot, Felixstowe Road Approximately 25% of the site is safeguarded for an extension to Rosehill School.		2.22 (c.75%)	75	45dph (DM23b)	M
IP010b	Felixstowe Road Current uses retained on c. 50% of site (including Hughes and BT).		2.79 (c. 50%)	62	45dph (DM23b)	L
IP011a	Lower Orwell Street former Gym & Trim (formerly listed as Smart Street/Foundation Street),		0.15ha	18	110dph on 100% of site DM23	M
IP011b	Smart Street, Foundation Street (South) Redevelopment is dependent on the appropriate relocation of existing uses.		0.62	56	90dph (DM23a lower end of range)	L
IP011c	Smart Street, Foundation Street (North) Allocated for residential development Site IP011b has been split to reflect the ownerships.		0.08	7	90dph (DM23a lower end of range)	M
IP012	Peter's Ice Cream		0.32	35	110dph (DM23a higher end of range)).	M
IP014	Hope Church Redevelopment is dependent on the appropriate relocation of existing uses.		0.21	23	110dph (DM23a, higher end of range)	M
IP015	West End Road Surface Car Park Primary allocation for long stay parking with secondary residential. The site is to be masterplanned with IP083 adjacent.		1.22 (c. 55%)	67	100dph (DM23a)	M
IP031a	Car Park, Burrell Road		0.44	20	45dph (DM23b).	M
IP031b	22 Stoke Street		0.18	18	100dph (reflective of highly accessible location. Maximum dph due to heritage constraints)	S
IP032	King George V Field, Old Norwich Road Allocated for 80% residential and 20% open space. The allocation is subject to the provision of replacement playing fields and ancillary facilities (e.g. changing rooms and spectator accommodation) in a suitable location.		3.7 (c. 80%)	99	35dph (Development Brief)	M
IP033	Land at Bramford Road (Stocks site) Allocated for 50% residential and 50% open space.		2.03 (50%)	55	55dph (DM23b / SHELAA)	S
IP035	Key Street / Star Lane / Burtons (St Peter's Port) Residential-led mixed use scheme. Additional uses could include office, leisure or small scale retail.		0.54 (80%)	86	DM23a at a higher density of around 200 dph – below the density of development on the northern quays to reflect the historic environment setting	M
IP037	Island Site Allocated for housing and open space alongside existing Marina and small commercial uses to support enterprise zone. These proportions will be firmed up through the preparation of a master plan. See also Opportunity Area development principles and guidelines in Part C. Additional vehicular and foot/cycle access (including emergency access) will need to be provided to enable the site's development.		6.02 (c. 70%)	421	100dph (DM23a midrange)	L
IP039a	Land between Gower Street & Gt Whip Street		0.48	45	95dph (DM23a lower-mid range)	L
IP040	Former Civic Centre, Civic Drive (Westgate) This site is allocated for 10% retail and leisure development at ground/first floor level but primarily residential use.		0.73 (90%)	59	90dph (DM23a)	S
IP041	Former Police Station, Civic Drive		0.52	58	110dph (DM23a) higher end of range).	S
IP043	Commercial Buildings, Star Lane		0.70 (80%)	50	90dph (DM23a lower end of range). 11/00267/FUL for 65 student rooms pending although unlikely to proceed.	S
IP047	IP047 Land at Commercial Road		3.11ha	173	55dph on 80% as part of a mixed use scheme of 80% housing, 5% hotel/ leisure/ retail, 5% public open space and 10% enhanced river path, Based on pending application (19/00148/OUT)	S/M
IP048a	Mint Quarter / Cox Lane East regeneration area Primary school and car parking development to the north of Upper Barclay Street, retaining the locally listed façade to Carr Street. Residential development to the south of Upper Barclay Street. Development to include new public open space and short stay parking in a medium sized multi-storey car park (location in relation to Cox Lane to be determined). A development brief for the whole site will be prepared but development will come forward incrementally.		1.33 (c. 40%)	53	100dph (DM23a mid-range)	M
IP048b	Mint Quarter / Cox Lane West regeneration area Residential and retail mix incorporating short stay car parking for shoppers and civic/open space. A development brief for the whole site (a and b) will be prepared but development will come forward incrementally.	1.34 (c. 30%)		36	90dph (DM23a lower end of range)	L
IP054b	Land between Old Cattle Market and Star Lane The site now excludes the former Archant site to the east of Turret Lane and is allocated primarily for residential use alongside small scale retail and leisure and an extended or replacement electricity sub-station.		1.08 (60%)	40	60dph. High density area (DM23a) but a mix of flats and town houses would fit the character of locality. Hence density higher than medium range.	L
IP061	Former School Site, Lavenham Road Allocated for part development (60%) on the basis of improving the remainder (40%) of the open space. The south-west corner of the land (0.18ha) is being developed (18/00991/FPC) as 4 general housing units and 4 respite care units and has been excluded from the site area.		0.9 (60%)	23	40dph (DM23 b.- c.)	M
IP064a	Land between Holywells Road and Holywells Park Redevelopment is dependent on the appropriate relocation of existing uses		1.20	66	45 dph (DM23b within IP-One area and close to Waterfront	M
IP066	JJ Wilson and land to rear at Cavendish Street Redevelopment is dependent on the appropriate relocation of existing uses		0.85	55	65dph (DM23b higher than average density as adjacent to IP-One).	M
IP067a	Former British Energy Site This is the northern section only and is subject to resolving odour issues to the satisfaction of IBC		0.38ha	17	45dph	L
IP080	240 Wherstead Road		0.49	27	55dph (DM23b). Linear layout would allow for slightly higher than average density.	S
IP089	Waterworks Street		0.31	23	90dph less 5 existing units (DM23a lower end of range)	L
IP096	Car Park Handford Road East		0.22	22	100dph (DM23a lower end of range)	M
IP098	Transco, south of Patteson Road		0.57	62	110dph (DM23 higher end of range)	M
IP105	Depot, Beaconsfield Road		0.33	15	45dph (DM23b)	M
IP119	Land east of West End Road Redevelopment is dependent on the appropriate relocation of existing uses		0.61 (45% to avoid development directly opposite sub station)	28	125dph (DM23a lower end of range)	L
IP120b	Land west of West End Road Redevelopment is dependent on the appropriate relocation of existing uses		1.03 (80% to avoid development adjacent to sub station)	103	125dph (DM23a lower end of range)	L
IP125	Corner of Hawke Road and Holbrook Road		0.25	15	60dph	S
IP132	Former St Peters Warehouse Site, 4 Bridge Street	0.18ha		73	73 dwellings as part of a mixed use scheme (with B1a office use, leisure or small scale retail)	M
IP133	South of Felaw Street	0.37		45	120dph (DM23Based on 10/00418/VC for 47 dwellings expired Feb 2014 & pre-application discussion)	M
IP135	112-116 Bramford Road, Application for car wash approved 17/00266/FUL. Temp permission expires 01.10.2019		0.17ha	19	110dph based on location within Local Centre)	M
IP136	Silo, College Street This site is primarily allocated for residential with secondary uses to include offices, leisure and/or small scale retail.		0.16 (c. 80%)	48	Assume 6 flats per floor within 10 storey development with commercial on lower two floors (DM23a and higher than average density consistent with other schemes along Quay).	L
IP143	Former Norsk Hydro, Sandyhill Lane		4.51	85	17/00769/OUT	S
IP150d	Land south of Ravenswood – Sports Park (part adjacent to Alnesbourn Crescent only – to be master planned)		1.8	34	DM23 c. low density as part of mixed use with sports park	M
IP150e	Land south of Ravenswood (excluding area fronting Nacton Road) – to be master planned		3.6	126	DM23 c. low density as part of mixed use with B1 employment uses	M
IP172	15-19 St Margaret's Green		0.08	9	DM23110dph. Planning permission for student accommo-dation lapsed and unlikely to proceed (08/00511/FUL)	M
IP188	Websters Saleyard site, Dock Street		0.11	9	As per permission (19/00173/FUL).	S
IP221	Flying Horse PH, 4 Waterford Road		0.35 (c. 50% retaining the public house)	12	35dph (DM23c). Application for 12 dwellings in application 06/01007/FUL expired.	L
IP279B(1)	Land north of Former British Telecom Office, Bibb Way	0.44		18	Based on master planning work with IP279A	S
IP279B(2)	Land south of Former British Telecom Office, Bibb Way	0.61		29	Based on master planning work with IP279A	S
IP307	Prince of Wales Drive		0.27	12	DM23 b.	S
IP309	Former Bridgeward Social Club, 68a Austin Street		0.28	15	54dph DM23 b. (Higher end based on proximity to local centre)_	S
IP354	72 (Old Boatyard) Cullingham Road		0.34	24	70dph (Less than 90dph due to site constraints)	S
IP355	77-79 Cullingham Road Site needs to safeguard capacity for a footpath and cycle path through the site to connect Cullingham Road with Bibb Way.		0.06	6	100dph (based on location in Portman Quarter)	S
Total				2,750

Policy SP4 allocates land for residential development, or part residential development within mixed use developments, to be known as 'opportunity sites'. These are sites which the Council wishes to see redeveloped and regenerated but where constraints may result in later delivery.

4.6 The Council is required to support the Government's objective to significantly boost the supply of homes and, through the Local Plan, identify a sufficient supply and mix of sites, taking into account their availability, suitability and viability.^[4]

4.7 The indicative capacity of the sites in table 1a listed in the policy above is 2,750 dwellings. These will contribute to meeting the minimum housing requirement of 8,010 dwellings by 2036, as identified through Policy CS7 of the Final Draft Core Strategy. In addition, the Final Draft Core Strategy allocates land for the development of approximately 3,500 dwellings at Ipswich Garden Suburb (the Ipswich Northern Fringe) through policy CS10, with delivery expected to start in 2019 and end in 2036. The Core Strategy review also identifies a cross-border allocation for future development (within Ipswich Borough and Suffolk Coastal Local Plan area) for housing delivery, appropriately phased with the delivery of the Ipswich Garden Suburb and its associated infrastructure at the northern end of Humber Doucy Lane adjacent to Tuddenham Road, through policy ISPA4.

4.8 The housing land requirement and supply figures are set out in Table 2 of the Final Draft Core Strategy. The likely delivery timescale shown in the policy shows the Council's expectation based on current knowledge; sites could come forward sooner than indicated.

4.9 The Government considers that small and medium sized sites can be built out relatively quickly. Therefore, the Council is required to ensure that 10% of the housing requirement will be delivered on sites of under 1ha (NPPF paragraph 68). In the supply as identified, 26% of the capacity is on sites of under 1ha.

4.10 Within mixed use schemes, the use proportions indicated in the policy represent the Council's preferred outcome and form the basis of supply calculations. However, the figures are indicative other than in the case of open space requirements and community facilities, to help ensure that developments can be viably delivered. Housing delivery will be closely monitored through the Authority Monitoring Report.

4.11 Appendix 3 provides additional information about the sites allocated through this policy. Information on development constraints contained in the site sheets must be taken into account in development proposals, in accordance with the Ipswich Local Plan Development Management policies. An Urban Archaeological Database for Ipswich has been established, to make available desk-based information on known heritage assets.

4.12 In allocating sites for development the Council has followed the sequential approach, to ensure that sites are not allocated in areas with a greater probability of flooding if sites in lower risk areas are available. It has also applied the exception test to ensure that the benefits to the community of development outweigh flood risk, and ensure that development will be safe. Planning applications for sites which lie within Flood Zones 2 and 3 will need to be supported by a Flood Risk Assessment. The Council's supplementary planning document on Development and Flood Risk provides more guidance.

4.13 Housing is a key issue for older people. There is a need to ensure a suitable mix of housing for older people, whether market housing or types of supported housing. The Council encourages new housing to be built to be accessible and adaptable, which makes it easier for people to remain in their own homes as their mobility needs change. In order to create an environment which enables older people to have a good quality of life, the Council supports the implementation of the 'Lifetime Neighbourhoods' principle in new development. This concept covers the built environment, access to services and resident empowerment in addition to housing mix and design.

Policy SP3 Land with Planning Permission or Awaiting a Section 106

4.14 There are sites in the Borough which currently:

have planning permission for schemes that have not commenced to date; or
have planning permission for residential schemes that have commenced and stalled; or
have a committee resolution to grant planning permission but await the signing of a Section 106 Agreement; or
have planning permission for student accommodation but have not commenced to date.

4.15 Such sites form an important potential supply of housing land, but given changes in the market the schemes originally envisaged may not come forward. Therefore, policy needs to be put in place to guide the potential future development of the sites and safeguard or allocate them for residential use, should the planning permissions fail to be issued or implemented or the development fail to be completed as originally envisaged.

(1) Policy SP3 Land with planning permission or awaiting a Section 106 Agreement

As at 1^st April 2019, the sites listed in Table 2 below have planning permission for residential development, student accommodation or mixed use development including residential use, which has not been implemented or has started and then stalled, or are awaiting the completion of a Section 106 Agreement. Should the permissions fail to be issued or implemented and lapse during the plan period or the development fail to come forward or be completed in accordance with the permission, the Council will protect the sites for residential use or residential-led mixed use.

Table 2 Sites with planning permission or awaiting a Section 106 Agreement

Site	Address and current situation	Site area ha (% for residential)	Capa-city	Evidence	Time-scale
IP005	Former Tooks Bakery, Old Norwich Road 80% residential and c. 20% is safeguarded for the provision of a new health centre.	2.8 (c. 80%)	60	45dph (Development Brief) Capacity in line with draft proposals) (16/00969/FPI3)	S
IP042	Land between Cliff Quay and Landseer Road	1.64	222	15/01040/OUT awaiting a S106	M
IP048C	6-10 Cox Lane and 36-46 Carr Street (upper floors)	0.2	33	18/00740/P3JPA	S
IP054a	30 Lower Brook Street	0.56	62	16/01037/FUL	S
IP059a & b	Arclion House and Elton Park, Hadleigh Road	2.63	103 within IBC	16/01220/OUT	S/M
IP074	Land at Upper Orwell Street	0.07	9	16/01179/FUL approved 03.02.17	S
IP088	79 Cauldwell Hall Road	0.30	17	17/01115/VC approved 22/02/18	S
IP106	391 Bramford Road	0.33	11	19/00045/FUL	S
IP109	R/O Jupiter Road & Reading Road	0.42	13	12/00192/FUL (pending)	S
IP116	St Clement's Hospital Grounds	11.85	108	14/00721/OUT 108 dwellings outstanding at 01/04/2019	S
IP131	Milton Street	0.28	9	15/01158/FUL (& 18/00552/FUL)	M
IP142	Land at Duke Street Allocation to provide for public open space (25%).	0.39 (75%)	44	90dph (DM23a lower end of range) (17/00570/FUL)	M
IP150a	Ravenswood U, V, W	2.23	94	07/00765/OUT for part of outline site	S
IP161	2 Park Road	0.35	14	19/00065/FUL (pending)	S
IP165	Eastway Business Park, Europa Way	2.08	78	As per approved scheme (13/00943/OUT) and now on site. Under construction 78 outstanding.	S
IP169	23-25 Burrell Road	0.08	4	12/00087/FUL approved 22.03.2012. Under construction 4 outstanding.	S
IP200	Griffin Wharf, Bath Street	0.79	113	17/00382/FUL pending. Previous pps: 11/00507/FUL approved 01.09.2011 (132 flats) 05/00819/FUL.	S
IP205	Burton's, College Street	0.19	14	02/01241/FUL (196 in total, 71 completed April 2014). Application 19/00624/FP13 on part of site for 14 self-contained flats)	S/M
IP206	Cranfields, College Street	0.71	134	04/00313/FUL (337 in total, 197 completed April 2014) 16/00092/VC (replaced 16 of the flats with 43 (29 studios + 14 one-beds)	S
IP211	Regatta Quay, Key Street	0.85	156	09/00130/FUL (pending) 05/00296/FUL added 25 extra units. 150 (at winerack) and 6 at 16/00346/FUL	S
IP214	300 Old Foundry Road	0.02	12	10/00805/VC expired Dec 2013. 17/00144/FUL	S
IP245	12-12a Arcade Street	0.06	14	18/00899/FUL	S
IP256	Artificial hockey pitch, Ipswich Sports Club, subject to the requirements of policy DM5 being met.	0.6 (excludes access road)	28	16/00987/FUL. Awaiting S.106	S
IP279a	Former British Telecom, Bibb Way	0.63	104	18/00470/P3JPA	S
IP283	25 Grimwade Street. Student Union Club and adjacent car park, Rope Walk	0.27	14	17/00049/FUL	S
	Total		1,470

Comment on sites

IP005 – Former Tooks Bakery, Old Norwich Road

IP042 – Land between Cliff Quay and Landseer Road

IP048c - 610 Cox Lane and 36-46 Carr Street (Upper Floors)

IP054 - 30 Lower Brook Street

IP059b – Arcilion House and Elton Park, Hadleigh Road

IP074 – Church and land at Upper Orwell Street

IP088 – 79 Cauldwell Hall Road

IP106 - 391 Bramford Road

IP109 – R/O Jupiter Road & Reading Road

IP116 – St Clement’s Hospital Grounds

IP131 – Milton Street

IP142 – Land at Duke Street

(2) IP150a – Ravenswood S & T (Adjacent Fen Bright Circle)

IP161 - 2 Park Road

IP165 - Eastway Business Park Europa Way

IP169 - 23-25 Burrell Road

IP200 – Griffith Wharf, Bath Street

IP205 – Burton’s College Street

(1) IP206 – Cranfields, College Street

(1) IP211 – Regatta Quay, Key Street

IP214 – 300 Old Foundary Road

IP245 – 12-12a Arcade Street

IP256 – Artificial Hockey Pitch, Ipswich Sports Club

IP279 - Former British Telecom Bibbs Way

IP283 - 25 Grimwade Street Student Union Club and Adjacent car park, Rope Walk

4.16 Sites with planning permission or a resolution to grant planning permission would not normally be allocated through a development plan, as the expectation is that in normal market conditions they would come forward for development in due course. However, it is considered necessary to include this policy in the plan because of:

The residential capacity of the Borough taking into account the tightly drawn boundary; and
The number of schemes for high density flats within IP-One, which have been affected by weak market conditions and may be revised to slightly lower density schemes. The trend towards lower densities has been observed on other sites within the Ipswich housing market, for example at Griffin Wharf.

4.17 The Council's concern is to retain the principle of residential or residential-led mixed use on the sites, which form an important element of the housing land supply. Information about constraints affecting the sites is set out in Appendix 3B.

4.18 The sites with planning permission for residential development listed in the policy above have already been included in supply calculations in Final Draft Core Strategy Table 2 and, therefore, are not counted again here. The delivery of the sites will be closely monitored through the Authority Monitoring Report.

4.19 The success of the University of Suffolk is a priority for the Council. Sufficient student accommodation is needed to support the University's targets for student numbers and ensure that potential impacts on residential neighbourhoods can be managed. The University is not a direct provider of bespoke student accommodation, but relies on the market to make provision, which the University accredits if appropriate. Therefore the University's approach to provision by developers is to accredit accommodation up to the number of bed spaces needed, but not beyond.

4.20 Experience in Ipswich to date indicates that there are more student bed spaces with planning permission than the University needs. If planning permissions for student accommodation are not implemented, the Council will encourage the alternative development of the sites for housing use not limited to students, on the basis that the market for student accommodation is saturated.

Policy SP4 Opportunity Sites

(1) Policy SP4 Opportunity Sites

Four opportunity sites have been identified within IP-One that have potential for housing-led redevelopment and would contribute to the regeneration of the Waterfront and Town Centre. These are listed below and described in Appendix 4. The Council will work with land owners and other interested parties to investigate opportunities and bring them forward through the development management process, taking into account constraints set out in the Appendix 4 site sheets.

IP028b Jewsons, Greyfriars Road

Potential mix: residential, leisure (A3-A5/D2), office

Indicative capacity: 40 dwellings

Regeneration role: a site with potential for a more efficient and appropriate town centre use than the current builders' yard, which would continue the regeneration of Greyfriars Road achieved through the residential redevelopment adjacent at Wolsey Street and improve pedestrian routes from Cardinal Park to the Central Shopping Area by reducing 'dead' frontage.

IP045 Land bounded by Toller Road, Cliff Lane and Holywells Road

Potential mix: residential and employment, community, arts, open space or tourism

Indicative capacity: 148 dwellings

Regeneration role: a key site for the regeneration of the eastern quays, lying between IP226 to the west (see below) and residential allocation IP064 to the east. The site would provide opportunities to improve pedestrian linkage from the eastern quays to open space at Holywells Park.

IP052 Land at Star Lane/Lower Orwell Street

Potential mix: residential, employment, leisure

Indicative capacity: 29 dwellings

Regeneration role: an important site for the regeneration of Lower Orwell Street and improvements for pedestrians and cyclists on Star Lane, with residential and mixed-use allocations across Lower Orwell Street at IP011a and IP011b.

IP226 Helena Road/Patteson Road

Potential mix: residential and uses appropriate at the Waterfront (policy SP11)

Indicative capacity: 337 dwellings

Regeneration role: a key site for the regeneration of the eastern quays providing a bookend to the Waterfront development and linking through to the brewery site IP042 to the south, with residential allocation IP098 adjacent.

4.21 The opportunity sites are in locations suitable for development and important for regeneration, but current uses raise deliverability issues which have deterred the Council from allocating them. The sites are suitable for development and potentially achievable, but their availability is uncertain. The Council's ambition and preference is to see them redeveloped for residential-led uses.

4.22 Two of the sites – IP052 and IP226 -were allocated through the 2017 Ipswich Local Plan. However, through the process of updating the Strategic Housing and Employment Land Availability Assessment (SHELAA) 2018-19, the Council has not been able to ascertain with certainty that the sites will come forward over the plan period.

Policy SP5 Land Allocated for Employment Use

4.23 Final Draft Core Strategy policy CS13 refers to the allocation of at least 23.2ha of employment land across the Borough to deliver jobs growth. The following policy addresses this requirement.

(3) Policy SP5 Land allocated for employment use

The following sites are allocated for employment development within Use Classes B1, B2 or B8, either in their entirety or as part of mixed use developments as specified in Table 3. Appropriate employment-generating sui generis uses, defined through policy DM33, will also be permitted where specified.

Table 3 Land allocated for employment uses

Site	Address	Site Area ha	Notes
IP029	Land at Bramford Road	2.26ha (45%) = 1ha	Suitable for employment uses B1(c), B2 and B8 and appropriate employment-generating sui generis uses as defined through policy DM33.
IP067b	Former British Energy Site	4.18	Suitable for B1 (excluding office use B1a) or B8 and appropriate employment-generating sui generis uses as defined through policy DM33 – residential use is proposed on the northern section and therefore uses should be compatible with residential
IP094	Land to rear of Grafton House	0.31	Suitable for B1a office
IP140	Land north of Whitton Lane	6.93	Suitable for B1, B2 and B8 and appropriate employment-generating sui generis uses as defined through policy DM33. Delivery expected in the medium to long term. Should be planned comprehensively as part of a larger scheme with adjacent land in Mid Suffolk but the two areas could come forward in phases. Subject to suitable access being provided.
IP141a	Land at Futura Park, Nacton Road	4.78	Suitable for employment uses B1b, B1c, B2, B8 and appropriate sui generis uses as defined through policy DM33.
IP150c	Land south of Ravenswood	1.18	Suitable for B1 (excluding office use B1a) and appropriate employment-generating sui generis uses as defined through policy DM33
IP152	Airport Farm Kennels	7.37	A site for longer term development subject to access improvements. Suitable for B1 (excluding office use B1a), B2 or B8 and appropriate employment-generating sui generis uses as defined through policy DM33. Development will be subject to the preparation of a development brief to address matters including the nationally designated Area of Outstanding Natural Beauty. The Council will explore the feasibility of park and ride being incorporated into this site.
IP004	Bus depot Sir Alf Ramsey Way	1.07 (50%) = 0.53	50% employment as part of mixed use scheme with housing
IP043	Commercial Buildings & Jewish Burial Ground Star Lane	0.70 (20%) = 0.14	Suitable for B1 / leisure as within the town centre boundary, as part of a mixed use development with housing
IP051	Old Cattle Market Portman Road	2.21 (80%) = 1.77	Prime town centre site for new B1a office development 80% B1a and 20% main town centre uses such as hotel / leisure (excluding retail). Numerically like for like replacement of existing long-stay car parking provision in this area will be required prior to the parking being lost. Offices with large floor plates in an office campus design approach are likely to be developed.
IP119	Land east of West End Road	0.61ha (15%) = 0.1ha	Suitable for employment uses B1(c), B2 and B8 and appropriate employment-generating sui generis uses as defined through policy DM33.
IP132	Former St Peters Warehouse Site, 4 Bridge Street	0.18ha / 0.05ha	B1a office, leisure, small scale retail as part of a mixed use scheme of 73 dwellings
	TOTAL	28.34.ha

4.22 The availability of land and buildings is an important factor in economic development and job creation, not just in terms of quantity but also the range of sites available and choice offered in terms of quality and location.

4.23 Final Draft Core Strategy policy CS13 sets a target of approximately 9,500 jobs to be provided 2018-2036 through a number of measures, including the allocation of at least 23.2ha of land for employment development. In the interest of ensuring a range and choice of sites across the Borough and the plan period, this policy allocates land for employment equivalent to 28.34ha.

4.24 All the employment sites allocated through the adopted Local Plan 2017 have been reviewed and only those included where the Council is confident development can be delivered over the plan period and, in the vast majority of cases, where the Employment Land Supply Assessment 2018 concludes that the sites are of good quality. The Council has investigated the constraints affecting such sites and will be proactive in supporting their delivery. The constraints are identified on the site sheets included at Appendix 3A and need to be taken into account by prospective developers.

4.25 The Suffolk Growth Strategy and the New Anglia Local Enterprise Partnership's (NALEP) Economic Strategy for Norfolk and Suffolk 2017 identify the economic sectors which are already significant in Suffolk (and Norfolk) and those which are forecast to grow^[5]: energy, advanced manufacturing and engineering, information and communication technology (ICT), tech and digital creative, financial services and insurance, advanced agriculture food and drink, transport freight and logistics, visitor economy - tourism and culture, life sciences and biotech and construction and development. Several of these sectors have a strong base in Ipswich. As well as allocating land for employment development, the Council is encouraging jobs growth in Ipswich through its Economic Strategy, the Ipswich City Deal and work with the Suffolk Growth Group and NALEP. Through the Economic Strategy, NALEP are providing focused support for business and innovation, improved skills and targeted infrastructure investment.

4.26 The sites allocated are reserved for Class B uses as identified in the Use Classes Order 1987 (as amended and updated), other than where a mix of uses or appropriate employment-generating sui generis uses are specified in Table 3 above. On those sites allocated for a mix of uses including employment, the proportions indicated in the policy represent the Council's preferred outcome and form the basis of supply calculations. However, the figures are indicative other than in the case of open space requirements and community facilities, to help ensure that developments can be viably delivered. Appropriate employment-generating sui generis uses are defined through policy DM33 and will need to comply with other plan policies including DM18. Appendix 3 provides additional information about the sites allocated through this policy.

Policy SP6 Land Allocated and Protected as Open Space

4.27 Open space is essential to the quality of life in Ipswich. Core Strategy Review policies CS16 and DM5 protect open spaces and the policy below adds site specific detail to this by identifying sites and allocating new open spaces.

(1) Policy SP6 Land allocated and protected as open space

Existing open spaces are defined on the policies map. Within the defined open spaces, Core Strategy Review policy DM5 shall apply.

Site IP083 Banks of the river upriver from Princes Street is allocated for public open space. Any development shall retain the river path and its setting.

Development of the following sites shall include more than the minimum amount of on-site public open space provision required through policy DM6, as specified in Table 4 below:

Table 4: Sites proposed for a mix of uses including open space

Site	Address	Preferred Options Ref	%Open Space	%Other Uses
IP029	Land opposite 674-734 Bramford Rd	UC030	67% Open Space	33% Employment; also potential link road
IP032	King George V Field, Old Norwich Rd	UC033	20% Open space/playing pitches	80% Housing
IP033	Land at Bramford Rd (Stocks Site)	UC034	50% Open Space	50% Housing
IP037	Island Site	UC038	15% Open Space	70% Housing, 5% existing boat-related uses, small scale retail/café/restaurant
IP047	Land at Commercial Road	UC048	15% Public Open Space and enhanced river path	80% housing, 5% retail.
IP048	Mint Quarter / Cox lane Regeneration Area	UC051	20% open space – could span the parts of the site east & west of Cox Lane (and car parking).	80% Housing, primary school on east side, retail on west side, car parking.
IP061	Former school site Lavenham Road	UC064	40% Open Space	60% Housing – development to deliver improvement to remainder of open space
IP142	Land at Duke Street	UC259	25% open space	75% Housing

4.28 On some sites there is a requirement to provide more than the standard amount of open space. This may be because the land is currently used as open space and therefore the loss needs to be compensated through improvements to what remains, or because the land is in effect used as open space even though it has previously been earmarked for development, and is in an area of open space deficit. Improvements to the remainder of the open space could include making it more usable, accessible, biodiverse or multi-functional.

4.29 Paragraph 8.184 of the Final Draft Core Strategy indicates broadly which areas of the Borough are short of open space against the current standards. There are no parts of the Borough which currently have a surplus of all types of open space. Site IP083 is located at the boundary of the Central and South West areas. The Central area currently has a significant deficit of natural and semi-natural green space.

4.30 The open spaces protected by this policy include all the different types shown on the policies map including playing fields, allotments and country parks.

4.31 The Waterfront does not currently have public open green space provision. This is addressed through the policy by allocating land for this use at site IP047 and within the Island Site redevelopment. Appendix 3 provides additional information about the sites allocated through this policy.

Policy SP7 Land Allocated for Leisure Uses or Community Facilities

(4) Policy SP7 Land allocated for leisure uses or community facilities

Land is allocated for leisure uses or community facilities as specified in Table 5 below, on stand alone sites or as part of larger development sites:

Table 5: List of sites proposed for leisure uses or community facilities

Site	Address	% Com-munity facilities / leisure	Community or leisure use	Other Uses
IP005	Former Tooks Bakery, Old Norwich Rd As part of a residential-led mixed use redevelopment	20%	Health centre	Housing
IP010a	Co-op Depot, Felixstowe Rd As part of a residential development	25%	Primary school extension	Housing
IP037	Island Site	To be determined through Masterplanning	Early Years and leisure	Housing, Employment, Restaurant/ small retail and amenity green space
IP048a	Mint Quarter / Cox Lane East regeneration area	60%	Primary School	Housing and Car Parking
IP129	BT Depot, Woodbridge Road	100%	SEND Free School
IP150b	Land at Ravenswood (7.8ha)	100%	Sports park	Housing adjacent

4.32 It is essential that community facilities are provided to keep pace with the growth in Ipswich's population. Ipswich Borough Council liaises closely with infrastructure and services providers, including Suffolk County Council and the Health Trusts, in order to identify the need for facilities for which land may need to be identified and safeguarded.

4.33 The Borough is seeing a rapid rise in the number of primary school aged children and therefore it is important to make adequate provision for new and expanded education facilities over the plan period. Sites have not been allocated for all the early years provision, but Final Draft Core Strategy policy CS15 promotes co-location with primary schools or location within district and local centres to promote linked trips. The need for early years provision in association with new development should be discussed with the County Council at an early stage in the planning process.

4.34 The full infrastructure needs of the Borough are being identified and costed in an Infrastructure Delivery Plan as a stepping stone towards putting in place a Community Infrastructure Levy for Ipswich. Key infrastructure is identified through Chapter 10 of the Final Draft Core Strategy, which will be supported by a separate Infrastructure Delivery Plan.

4.35 It is also important to plan for leisure uses that will be delivered over the plan period, whether they are on Council–owned or private land.

4.36 The need for community infrastructure associated with the Ipswich Garden Suburb development is dealt with through the Core Strategy Review and supplementary planning document. Appendix 3 provides additional information about the sites allocated through this policy.

Policy SP8 Orwell Country Park Extension

Site IP149 Land at Pond Hall Carr and Farm is allocated as an extension to Orwell Country Park, to provide better management of visitors to this part of the Orwell Estuary Special Protection Area.

4.37 The Orwell Estuary is designated as a Special Protection Area for birds. It is an important over-wintering site for wading birds, however, the birds can be easily disturbed by recreational activity including dogs running loose off leads.

4.38 The Appropriate Assessment to the adopted Core Strategy advised that a range of measures were needed including visitor management measures at Bridge Wood, to protect the Orwell Estuary Special Protection Area. A management plan for the whole of the Orwell Country Park is being prepared, but the adjacent Pond Hall Farm provides an opportunity to extend the Country Park and, in doing so, to provide a better network of footpaths and viewpoints over the estuary for visitors. Information could also be provided about the Special Protection Area, in order to raise awareness and discourage access to the foreshore. A visitor survey of Orwell Country Park undertaken during March 2015 concluded that the extension of the park into land at Pond Hall Carr and Farm is not likely to have harmful impacts on the Special Protection Area. The Council is currently in discussion with Natural England about the England Coast Path route in this area. The England Coast Path will be subject to its own Habitats Regulations Assessment.

Policy SP9 Safeguarding Land for Transport Infrastructure

(2) Policy SP9 Safeguarding land for transport infrastructure

Development of the following sites for the uses allocated through other policies in this plan shall incorporate provision for transport infrastructure, as specified in Table 6 below.

The park and ride site at Anglia Parkway is safeguarded for future re- use for park and ride. The Council will investigate the feasibility of park and ride on part of IP152 Airport Farm Kennels

Table 6: List of development sites which will include provision for transport infrastructure

Site	Address	Site Area (ha)	Allocation
IP010a or b	Felixstowe Road	5.01	Land reserved for a pedestrian and cycle bridge over the railway to link the District Centre with housing areas to the north.
IP059a	Land at Elton Park Works	2.63	Land reserved for a pedestrian and cycle bridge over the river to link to the river path on the northern bank.
IP037	Island Site	6.02	Additional vehicular access needed to enable the site's development. Additional cycle and pedestrian connections also required in accordance with policy SP15. Development layout should not prejudice future provision of a Wet Dock Crossing.
IP029	Land opposite 674-734 Bramford Road	2.26	Link road through the site joining Europa Way and Bramford Road (subject to impact testing).

4.40 It is important that provision is made for needed transport infrastructure within certain development sites. The aspiration to provide a pedestrian and cycle bridge over the railway at site IP010 (a or b) to link residential areas to the north with the District Centre is not a firm proposal at present in the Local Transport Plan, but the Highway Authority has identified the potential benefits of a link and the opportunity presented by the two IP010 sites. Therefore, pending further work on its deliverability, development at the IP010 sites should not preclude its possible future provision.

4.41 The River Strategy identifies the aim of providing a river crossing between Hadleigh Road and Boss Hall for pedestrians and cyclists. The Elton Park site is considered the most suitable location to link up with future development at the Former Sugar Beet Factory site in Babergh.

4.42 The Island site is an outstanding development opportunity at the Waterfront. Access improvements will be needed to enable its redevelopment.

4.43 The provision of a road link through site IP029, land opposite 674-734 Bramford Road, to join Bramford Road and Europa Way could help to ease pressure on the Bramford Road/Sproughton Road junction. It was included as a proposal in the 1997 Ipswich Local Plan, but has not to date been implemented. The potential impacts of the link on the traffic network are subject to testing and need to be clearly understood. However, in the interim, development of the site should not preclude its future provision.

4.44 The park and ride site at Anglia Parkway, Ipswich is currently disused. However, it remains laid out as a park and ride facility and is safeguarded for that use in future. Once lost, sites are difficult to replace. The need for and deliverability of additional park and ride at IP152 Airport Farm Kennels will be explored as a potential measure to address congestion, accessibility and air quality.

4.55 The Council is working with the Highway Authority and neighbouring authorities to agree a Transport Mitigation Strategy and detailed action plan to support modal switch and sustainable travel choices in the Ipswich area, which is needed to support growth. Core Strategy policy CS20 outlines the potential measures the action plan will draw from.

^[4] NPPF paragraph 59 and 67

^[5] Suffolk Growth Strategy SCC March 2013 and NALEP Economic Strategy for Norfolk and Suffolk 2017

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Ipswich Borough Council Local Plan Site Allocations and Policies (incorporating IP-One Area Action Plan) DPD Review - Final Draft

CHAPTER 4: Site Allocations

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