Draft Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document

Chapter 5: Site Allocations

5.1 The focused review 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 Core Strategy Policies also address the matter, for example CS10 Ipswich Northern Fringe. Ipswich town centre is dealt with in Chapter 6 ‘IP-One’, with the exception of housing, employment, mixed use and community facility site allocations which are addressed below.

5.2 The threshold 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 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.

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

5.4 The Council has specific requirements for the delivery of housing, jobs and retail development in the period up to 2031. 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 can not easily be developed for alternative uses and thereby harm the Council’s ability to achieve its growth targets.

5.5 Through focused review Core Strategy policy CS7 ‘The Amount of Housing Required’, the Council commits to allocating land to provide at least an additional 5,909 dwellings net to 2031. The following policies provide the detailed site allocations to deliver a proportion of that housing requirement.

5.6 The Council is required to ensure that the Ipswich Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area as far as is consistent with policies in the National Planning Policy Framework¹⁰. The focused review Core Strategy sets out the revised housing requirement for the Borough of 13,550. The sites allocated in this policy indicate how the Council intends to meet part of that requirement.

5.7 The indicative capacity of the sites listed in the policy above is 2,409 dwellings. These will contribute to meeting the housing target of 5,909 dwellings required as identified through Policy CS7 of the Core Strategy focused review. In addition, the Core Strategy allocates land for the development of 3,500 dwellings at Ipswich Garden Suburb (the Ipswich Northern Fringe) through policy CS10. The housing land requirement and supply figures are set out in Table 2 of the Core Strategy focused review.

5.8 Within mixed use schemes, the Council will expect the proportion of housing to be within + or -5% of the proportion indicated in the policy. Housing delivery will be closely monitored through the Authority Monitoring Report. Appendix 3 provides additional information about the sites allocated through this policy.

5.9 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.

5.10 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.

5.11 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. Two specific circumstances have led to the policy’s inclusion in the plan:

• The number of permitted schemes for student accommodation, some of which the Council considers unlikely to come forward; 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.

5.12 It is considered that these issues will have a marginal and/or temporary effect over the whole plan period. Nevertheless 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.

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

5.14 The success of University Campus 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.

5.15 Experience in Ipswich to date indicates that there are more student bed spaces with planning permission than the University needs. The sites with unimplemented planning permission for student accommodation have not been counted in the housing land supply, in accordance with government advice. However they would be counted as completions once built. 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. This is the source of some of the land included in housing calculations as a windfall allowance for years 3-15 of the plan period.

5.16 National Planning Policy for Traveller Sites 2012 requires local planning authorities to work together to set pitch targets for Gypsies and Travellers and plot targets for travelling showpeople, which address the likely permanent and transit site accommodation needs of Travellers in their area. The following policy addresses this requirement.

5.17 Ipswich currently contains two sites for Gypsies and Travellers, at West Meadow (41 pitches) and Henniker Road (2 pitches). These are shown on the policies map.

5.18 An assessment of the accommodation needs of Gypsies and Travellers (GTAA) in East Suffolk is being carried out jointly by Ipswich Borough Council, Mid Suffolk District Council, Suffolk Coastal District Council, Waveney District Council and Babergh District Council. The initial indications in the draft GTAA demonstrate there is a need for additional permanent pitches to be provided between 2012 and 2027. In order to meet this expected need, the Council has allocated a small family sized site providing 5 pitches to meet needs for the period 2012 to 2017. The pitches could be provided publicly or privately, but the Council is required to address the need through identifying sites to meet it.

5.19 For the period 2017-2027, need is expected to be met jointly with neighbouring authorities through the allocation of sites in the Ipswich Policy Area, in accordance with Core Strategy policy CS11. This cross-boundary approach gives flexibility in identification of sites, as there are limited opportunities within the Borough boundary to meet needs given its tight administrative boundaries and its high housing target. This approach accords with Government policy.

5.20 The Council is committed to delivering joint transit provision in accordance with Core Strategy policy CS11. This need requirement will be updated by the GTAA. Provision is also expected to be met beyond the Borough boundary, in order to meet need arising in the Felixstowe area and to accord with criteria to be located on a trunk road corridor.

5.21 The Council will seek to provide for the needs of Travellers requiring a mixed residential and business use site by allocating suitable sites, and where this is not possible by providing separate sites for residential and business purposes in close proximity.

5.22 National policy indicates that the number of pitches or plots should be related to the circumstances of the specific size and location of the site and the surrounding population’s size and density. The Ipswich Housing Strategy indicates that the preferred form of provision is pitches in small family groups – typically a site containing about 6 pitches. Thus the Council expects the provision to take the form of smaller site(s) over the plan period to 2027, located within Ipswich Policy Area.

5.23 The site(s) allocated will be considered against the criteria set out in Core Strategy policy CS11 and Planning Policy for Traveller Sites 2012.

5.24 Core Strategy Policy CS13 refers to the allocation of at least 30ha of employment land across the Borough to deliver jobs growth. The following policy addresses this requirement.

5.25 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.

5.26 The National Planning Policy Framework states that planning policies should avoid the long term protection of allocated employment sites where there is no reasonable prospect of the site being used for that purpose (paragraph 22). Several sites allocated above have been safeguarded for employment use since the Local Plan was adopted in 1997, but have not come forward.

5.27 All the allocated sites have been reviewed and only those included where the Council is confident development can be delivered over the plan period and where the Employment Land Review 2009 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.

5.28 A key vehicle to assist in delivery is the Suffolk Growth Strategy. This identifies sites including those at Ransomes, Hadleigh Road and Sandyhill Lane/Raeburn Road as strategic sites for the Borough. These will be targeted for assistance needed to overcome the barriers to their development.

5.29 Focused review Core Strategy Policy CS13 sets a target of 12,500 jobs to be provided 2011-2031 through a number of measures, including the allocation of at least 30ha of land for employment development.

5.30 The sectors forecast to grow in Suffolk¹¹ are: energy, advanced manufacturing, information and communication technology (ICT), finance, food, drink and agriculture, ports and logistics, tourism, creative and cultural industries and biotechnology. 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 and work with the Suffolk Growth Group and New Anglia Local Enterprise Partnership.

5.31 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 is specified in Table 3 above. Appendix 3 provides additional information about the sites allocated through this policy.

5.32 Open space is essential to the quality of life in Ipswich. Core Strategy policies CS16 and DM28 protect open spaces and the policy below adds further detail to this by identifying sites and allocating new open spaces.

5.33 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.

5.34 Paragraph 8.174 of the 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.

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

5.36 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 IP263 and within the Island Site redevelopment. Appendix 3 provides additional information about the sites allocated through this policy.

5.37 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.

5.38 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.

5.39 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 Core Strategy focused review, which will be supported by a separate Infrastructure Delivery Plan.

5.40 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. The Sports Park at Ravenswood is a proposal for an outdoor cycling facility, incorporating sports pitches. The former Odeon Cinema in the town centre is well placed next to the Regent for new leisure uses to complement the theatre.

5.41 The Appropriate Assessment to the adopted Core Strategy advised that visitor management measures were needed at Bridge Wood to protect the Orwell Estuary Special Protection Area. Pond Hall Farm offers the ideal opportunity to provide a visitor centre in the medium to long term, to raise visitor awareness of the potential impacts of disturbance on over wintering birds on the estuary and to draw visitors away from the foreshore.

5.42 The need for community infrastructure associated with the Northern Fringe development is dealt with through the Core Strategy and supplementary planning document. Appendix 3 provides additional information about the sites allocated through this policy.

5.43 It is important that provision is made for needed transport infrastructure within certain development sites. 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.

5.44 The park and ride site at Bury Road is currently disused, but the Council remains committed to bringing it back into service to intercept traffic entering the town east bound from the A14 in the north-west of the Borough. Park and ride fulfils an important role in supporting Travel Ipswich and providing public transport choices to those travelling into Ipswich from elsewhere.

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

5.46 Ipswich Port plays a significant role in the Ipswich economy, handling over 3 million tonnes of cargo a year. Since Ipswich Port Limited was bought by Associated British Ports in 1997, it has seen significant expansion. The extended West Bank handles primarily unitised cargo whereas the East Bank caters for bulk cargoes.

5.47 Ports have been identified by the New Anglia Local Enterprise Partnership as one of the key sectors which will drive the growth of the region in coming years. The Suffolk Growth Strategy 2013 also identifies that UK container traffic is likely to grow steadily over the next 15 years, as will opportunities arising through diversifying bulk-breaking and post-processing capabilities.

5.48 It is therefore important that land is safeguarded for the further expansion of the Port. The former Ash Tip site measures 3.12ha.

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¹⁰ NPPF paragraph 47 ¹¹ Suffolk Growth Strategy SCC March 2013