Draft Core Strategy and Policies Focused Review

CHAPTER 8: Development of the Strategy

(1) 8.1 The development of a spatial strategy is a vital component of this document and is central to the Council's Local DELETED: Development Framework INSERTED: Plan. It will form the basic framework that will guide the contents of the rest of the Local DELETED: Development Framework INSERTED: Plan.

8.2 This chapter is divided into six sections. The first provides a strategic spatial approach to the development of the town; the next four relate to the components of 'live, work, learn and play', and the final section relates to infrastructure to support growth and development.

A STRATEGIC SPATIAL APPROACH TO THE DEVELOPMENT OF THE TOWN

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

8.4 Six issues are addressed below. They are:

POLICY CS1:

Sustainable Development - Climate Change

POLICY CS2:

The Location and Nature of Development

POLICY CS3:

IP-One Area Action Plan

POLICY CS4:

Protecting our Assets

POLICY CS5:

Improving Accessibility

POLICY CS6:

The Ipswich Policy Area

8.5 Sustainable Development

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

8.7 In the following policies, Policy CS1 Sustainable Development - Climate Change covers the key areas of energy conservation, carbon reduction and water use; and Policy CS4 Protecting our Assets covers the conservation of the built and natural environment and the use of natural resources.

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

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

8.10 Achieving sustainable development is a fundamental aim of the planning system and lies at the heart of the vision and objectives set out earlier in this plan. The starting point for considering sustainable development is tackling climate change, because of the scale of the threat and the potential severity of its effects on ecosystems and human existence. The UK Climate Projections 2009 indicate the likelihood in the East of England of higher year round temperatures, higher winter rainfall, lower summer rainfall and sea level rise. Reducing carbon emissions, so as to reduce Ipswich's contribution to climate change, is an imperative of this plan. Not only is it required by national policy DELETED: (e.g. the Planning and Climate Change Supplement to Planning Policy Statement (PPS 1) and the Regional Spatial Strategy (e.g. Policy SS1)), but it is also in the direct interests of a town with a central area situated on low-lying land on an estuary subject to tidal flooding.

(1) 8.11 A consequence of climate change is likely to be increased winter rainfall and decreased summer rainfall (CRed Suffolk report INSERTED: Suffolk Climate Action Plan and UK Climate Projections 09) INSERTED: and the full impact on the natural ecosystem is largely unknown. Therefore, as well as reducing the impact of development on climate change, it is equally important to manage water resources through policies for the efficient use of water and minimisation of runoff from new development.

8.12 Ipswich has an estimated carbon footprint of INSERTED: 4.2 DELETED: 5.9 tonnes of carbon dioxide produced each year per head of population (DELETED: 2004 estimate from CRed 2011 data from Department for Energy and Climate Change). About INSERTED: 42% DELETED: 41% of those carbon emissions are estimated to come from people's homes, INSERTED: 20.5% DELETED: 19.5% from transport (less than the Suffolk and national averages, because of the urban nature of the Borough), INSERTED: 36% DELETED: 38% from industry and 1.5% from waste. Nationally about 60% of domestic carbon emissions result from space heating and hot water. Therefore improving the energy performance of existing and new domestic buildings is a key sector to target in order to reduce the climate change impacts of new development.

8.13 The Government DELETED: has published targets to achieve zero carbon homes by 2016 (INSERTED: in the previous PPS1 Supplement 2007 and Building a Greener Future 2007). A zero carbon home is currently defined as one that delivers zero net carbon over a year from all energy uses including heating and electrical appliances. In setting the date at 2016 for significant reductions, developers have time to develop appropriate approaches to design and building in order to achieve carbon neutrality in a cost effective way, and the price of energy saving technologies should fall as usage increases. Ipswich is INSERTED: planning for DELETED: identified as a growth point where high levels of housing and employment growth DELETED: are required by INSERTED: 2031 DELETED: 2021. The housing requirement alone represents an increase in the Ipswich dwelling stock of INSERTED: 23% DELETED: some 25% between INSERTED: 2011 DELETED: 2001 and INSERTED: 2031 DELETED: 2021. This represents a vital opportunity to ensure that this significant addition to the building stock of the Borough minimises its impacts on climate change.

8.14 Non-residential buildings also offer the opportunity to save emissions. The Government has recently adopted a target for non-residential development to be carbon neutral by 2019. Policy DM1 in Part C of this document provides more detail as to how these requirements would be implemented through the Code for Sustainable Homes for residential development, and BREEAM ratings for non-residential development. The Plan is not prescriptive about how developers should achieve these targets. There is a significant amount of existing advice available about sustainable construction⁴. DELETED: The Council plans to prepare a supplementary planning document on sustainable construction when the Core Strategy is adopted. This will also cover extensions to buildings.

8.15 There is also a social sustainability imperative to reduce carbon emissions from homes. INSERTED: Since 2005, the UK has become a net importer of fossil fuels causing energy DELETED: Fossil fuel prices DELETED: are expected to rise sharply DELETED: as the peak of oil and gas production passes. Therefore Ipswich needs to be reducing its dependence on these fuels.

8.16 DELETED: PPS1 encourages local planning authorities to set a target percentage for decentralised renewable or low carbon energy in new development, where feasible. INSERTED: The National Planning Policy Framework states that Local Authorities should recognise that it is the responsibility of all communities to contribute to energy generation from renewable or low carbon sources, and that they should have a positive strategy to promote energy from renewable and low carbon sources. The Planning and Energy Act 2008 also allows local planning authorities to adopt such targets and to require efficiency standards that exceed the Building Regulations. DELETED: RSS Policy ENG1 sets out an interim requirement that major developments should secure at least 10% of their energy from decentralised and renewable or low carbon sources, until Development Plan Documents could set local targets. Policy ENG2 sets a target for 17% of the region's energy to come from renewable sources by 2020. Because Ipswich is a growth point, setting a target higher than 10% for renewable and low carbon energy in new buildings will help to meet the regional target for energy from renewables. INSERTED: The National Planning Policy Framework requires local planning authorities to support the move to a low carbon future and when setting any local requirements for a building’s sustainability, to do so in a way consistent with the Government’s zero carbon buildings policy and adopted nationally described standards. Policies should be designed to maximise renewable and low carbon energy generation whilst addressing any adverse impacts satisfactorily, including cumulative landscape and visual impacts. Implementation of this policy DELETED: It will DELETED: also help to make a significant impact on reducing carbon emissions because buildings are a major source of emissions in Ipswich. Funding streams INSERTED: such as the Feed in Tariff and Renewable Heat Incentive will be INSERTED: promoted to increase DELETED: sought to make grants available for the addition of micro-generation equipment on private properties and Borough owned properties will also be equipped with micro-generation equipment where possible.

8.17 On 31^st March 2009, the Council's Executive agreed that three Council-owned sites should be put out to tender for the possible development of wind energy schemes. The turbines should be operational by 2014 if developers come forward to develop them. Developing sites for renewable energy generation is an action identified in the Ipswich Sustainable Community Strategy and would help to achieve the strategy outcome relating to an improved environment. Together with increased micro-generation, this should help to achieve targets for renewable energy in Ipswich homes.

8.18 The carbon reduction INSERTED: and climate adaptation scheme, Suffolk Climate Change Partnership, is a partnership project with Suffolk County Council and others to help with information sharing, advice and practical measures so that individuals and businesses can reduce their carbon emissions INSERTED: and adapt to a changing climate. This is an essential strand of the strategy in tackling existing buildings and helping people to choose more sustainable lifestyles.

8.19 The IMPACT Carbon Management Plan sets out how Ipswich Borough Council will achieve carbon reductions from its own operations. It was approved by the Council's Executive on 31^st March 2009. The Council also signed the Nottingham Declaration on Climate Change in 2008 and, as a result, is preparing a climate change strategy. The Council also applies the Ipswich Standard to its own dwelling stock. The standard includes the provision of energy efficient boilers, double-glazing and insulation.

8.20 A combination of the measures set out will help to achieve overall carbon reduction at least in line with national targets. The Climate Change Act 2008 calls for at least 26% reductions from 1990 levels to be achieved by 2020. The DELETED: draft Suffolk Climate Change Action Plan INSERTED: 2012 takes this a step further and sets a target of 60% reductions from 2004 levels, by 2025. 2004 is the first year for which there is a full set of emissions data for Suffolk and therefore may prove more practical for monitoring purposes.

8.21 Many buildings in Ipswich are at risk of flooding, some from tidal surges and many from heavy rain. This risk will continue to grow as a result of rising sea levels and increasingly heavy rainstorms that can overwhelm drainage systems and cause localised flooding unless mitigation measures are implemented. At the strategic scale, tidal flood risk will be tackled through the completion of the Ipswich Flood Defence scheme including a tidal surge barrier. However developments located within the flood plain will still need to address residual risk in accordance with INSERTED: the National Planning Policy Framework DELETED: Planning Policy Statement 25 (e.g. the risk of defences failing). Managing surface water runoff is also important. SuDS, rainwater harvesting, storage and where appropriate the use of green roofs or water from local land drainage will be required wherever practical. INSERTED: Such approaches shall be particularly mindful of relevant ecological networks. New buildings need to be more adaptable and resilient to climate change effects in future.

(1) 8.22 The Haven Gateway Water Cycle Study Stage 1 Report identified issues with water supply and sewerage in Ipswich. It advised that sustainable drainage and other demand management techniques are used to manage water demand and surface water runoff in the Borough. INSERTED: The Haven Gateway Water Cycle Study Stage 1 Report identified issues with water supply and sewerage in Ipswich. It advised that sustainable drainage (SuDS) and other demand management techniques are used to manage water demand and surface water runoff in the Borough. The Council’s Drainage and Flood Defence policy DFD10 has required SuDS wherever reasonable practicable since 2002⁵. In addition the Council has a surface water management plan and a strategic flood risk assessment, and there is also a Suffolk local flood risk management strategy and catchment flood management plan, and a National strategy for SuDS, all of which will be referred to in the Council’s Development and Flood Risk supplementary planning document. DELETED: It is likely that these measures will be made compulsory if the Floods and Water Management Bill is enacted.

8.26 This policy implements plan objectives 1 and 2.

(4) 8.27 The second vital element of sustainable development is where to locate new development so that people can easily access the jobs, goods and services they want and need, by the most sustainable modes of travel. This benefits individuals by encouraging cycling and walking, which are cheap and healthy ways to get around. It benefits communities by enabling facilities to be accessed by as many people as possible and providing opportunities for people to meet. It benefits the environment and health by reducing vehicular emissions, and the economy by reducing congestion.

(2) 8.28 This approach to the location of development is centred primarily on the town centre (which includes Ipswich Village and the Waterfront), and secondly on the town's district centres. The strategy is illustrated in the key diagram. The exact boundaries of these areas will be defined on the INSERTED: policies DELETED: Proposals Map through the INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan INSERTED: ) DELETED: and Site Allocations and Policies development plan document. The town centre, including the Ipswich Village and Waterfront, will receive the highest densities of development in the town - including high-density housing developments. Medium-density and locally focused facilities would then be provided elsewhere in IP-One and within and around district centres (defined in paragraph INSERTED: 8.34 DELETED: 8.31), with lower density development elsewhere. Developments at higher densities will require special attention being paid to their urban design INSERTED: and greening qualities. Residential densities are defined in Policy DM30.

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

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

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

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

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

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

8.31 The central urban focus to the location of development also reflects the sequential approach to site selection required by INSERTED: the National Planning Policy Framework DELETED: Planning Policy Statement 3 (PPS3) Housing (which DELETED: prioritises INSERTED: encourages the use of previously developed land) DELETED: and Planning Policy Statement 4 (PPS4) Planning for Sustainable Economic Growth, and maximises the chances of making central Ipswich an increasingly vibrant and dynamic place. Chapter 6 of the plan sets out flood risk considerations.

8.32 The approach to locating employment uses focuses office activity into the town centre, in accordance with INSERTED: the National Planning Policy Framework DELETED: PPS4, to support its vitality and viability. It also provides a strategic employment site DELETED: as required by Regional Spatial Strategy Policy E3, located where it can build on the success of Ransomes Europark. It directs other employment uses, particularly B2 and B8 uses, which tend to be more extensive and less suited to central locations, to the town's outlying employment areas. These are accessible from residential areas, yet sufficiently segregated from them to minimise the possibility of conflicts between residential uses and potentially noisy or odorous industrial activities. The boundaries of employment areas will be delineated in the Site Allocations and Policies INSERTED: (incorporating IP-One Area Action Plan) development plan document.

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

8.34 The district centres referred to in the policy and identified in the Key Diagram are as follows:

• Meredith Road;
• Norwich Road INSERTED: (1-91, 2-110) / Bramford Road;
• Hawthorn Drive;
• Stoke Park;
• Wherstead Road;
• Cauldwell Hall Road / Woodbridge Road INSERTED: (418-787);
• Felixstowe Road INSERTED: (55-201, 120-190);
• Nacton Road INSERTED: (270-374);
• Ravenswood;
• Woodbridge Road INSERTED: East (27-53) / Heath Road;
• Sproughton Road / Eastway (to be developed);
• Duke Street DELETED: (being developed).

8.35 DELETED: Any Northern Fringe development (see Policy CS10) INSERTED: will DELETED: should also contain a district centre that would join the above list. DELETED: This would provide a range of facilities and operators in line with the definition in PPS4.

8.36 Within a 400m straight line distance from district centres, the Council would support the provision of identified community facilities (see Appendix 4). Within a wider zone of 800m, the Council would support in principle medium density housing provision to try to increase the proportion of people living near to shops and community facilities.

8.37 It should be noted that many of the centres above already have some of the community facilities mentioned within 400m of their centres. Zonal maps of the above centres INSERTED: are shown on plan 3 DELETED: will be included in the IP-One Area Action Plan and the Site Allocations and Policies documents.

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

8.39 Delivering high quality change, which safeguards the best of the town's urban character and neighbourhoods and secures positive improvements, is not just confined to the IP-One Area and Conservation Areas. INSERTED: The NPPF advises that sustainable development ‘involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people’s quality of life’. DELETED: PPS1 advises that local planning policies and decisions should be based on up-to-date information on the environmental characteristics of the area and ensure that these enhance the areas in which they are located. To facilitate this, an Urban Characterisation Study INSERTED: supplementary planning document will be undertaken to define the environmental characteristics of the Borough as a whole.

(1) 8.40 As the spatial strategy focuses development to a significant degree on central Ipswich and particularly on the areas that ring the historic core, the Council is preparing an area action plan for the area - known as IP-One - to guide its delivery INSERTED: , which will be incorporated into the Site Allocations and Policies development plan document (DPD). The IP-One area has been defined by the Council. It is slightly larger than the town centre and includes the central shopping area, Ipswich Village, the Waterfront and the Education Quarter. The IP-One area is indicated broadly on the key diagram. It INSERTED: is DELETED: will be defined on the INSERTED: policies DELETED: Proposals Map.

8.41 Area action plans are intended as a tool to guide development in areas where change is expected and/or conservation policies apply. IP-One includes both types of area, encompassing as it does the medieval core of the town, which now forms the focus for the Central Shopping Area; the Waterfront and Village where regeneration activities are focused at present; and the Education Quarter where University Campus Suffolk is taking shape. The IP-One Area Action Plan DELETED: will build INSERTED: builds on earlier work that resulted in the publication of a non-statutory area action plan in 2003.

(1) 8.42 Ipswich has a rich and varied heritage of built, historical and natural assets, including more square miles of park per thousand population than anywhere else in the UK. The Borough contains:

• Over 600 listed buildings and structures;
• 14 conservation areas;
• A Ramsar Site and Special Protection Area for Birds (part of the Stour and Orwell Estuaries site);
• 4 Sites of Special Scientific Interest – three for wildlife and one for geology;
• 19 County Wildlife Sites;
• 10 scheduled ancient monuments;
• An area of archaeological importance for its Anglo-Saxon remains in central Ipswich; and
• 3 registered parks and gardens INSERTED: and 518 hectares of parks and open spaces.

There is also a Suffolk Biodiversity Action Plan (BAP), which identifies certain habitats and species of particular importance to Ipswich, and a small part of the Borough lies within the Suffolk Coast and Heaths Area of Outstanding Natural Beauty.

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

8.44 The Ipswich asset base also includes all the finite natural resources that the Borough depends on, such as minerals used in construction and land itself. The concept of ‘one planet’ living illustrates the issue of resource use and the impacts of our lifestyles on the environment. Currently our lifestyles in Europe are such that, if everyone worldwide lived in the same way, we would need three planets Earth. This is unsustainable. We therefore need to take opportunities to use natural resources more sparingly and efficiently, to re-use and recycle materials and to source materials locally where possible.

8.45 Most of the built, historical and natural assets are protected by one or more of the following pieces of legislation, INSERTED: policy documents DELETED: national planning policy statements, planning policy guidance notes or circulars:

• EU Habitats Directive;
• Wildlife and Countryside Act 1981;
• INSERTED: The National Parks and Access to the Countryside Act 1949;
• INSERTED: Countryside and Rights of Way Act 2000;
• INSERTED: Ramsar Convention on Wetlands;
• INSERTED: Hedgerows Regulation 1997;
• INSERTED: Plant Health Act 1967 and orders;
• INSERTED: Forestry Act 1981;
• Natural Environment and Rural Communities Act 2006;
• The Town and Country Planning Act 1990;
• Planning (Listed Buildings and Conservation Areas) Act 1990;
• Ancient Monuments and Archaeological Areas Act 1979;
• National Heritage Act 1983;
• DELETED: Planning Policy Statement (PPS) 9 Biodiversity INSERTED: The National Planning Policy Framework (2012);
• INSERTED: The Localism Act 2011 DELETED: Planning Policy Statement 5 Planning for the Historic Environment 2010⁶; and
• Central Govt Circular 9/95; Culture Circular 1/97; Environment Circular 14/97.

8.46 This framework of legislation, guidance and policy currently provides comprehensive protection for the assets. Considering first listed buildings, the Council will rely on this national legislation, policy and guidance to guide their protection, as a local policy would not add to or strengthen the protection they already receive. However, INSERTED: national policy has been consolidated into the National Planning Policy Framework with the guidance produced by English Heritage to accompany Planning Policy Statement 5⁷ remaining applicable to ensure that policy and guidance are properly inter-related and DELETED: aspects relating to heritage assets are under review without it being clear how future legislation, guidance and policy will inter-relate or if they will be integrated to ensure that listed buildings, conservation areas and other heritage assets will be DELETED: as adequately protected as at present. INSERTED: As the English Heritage guidance is described as a ‘living draft’ and has been the subject of a draft revision to coincide with the NPPF, the Council is preparing a supplementary planning document to protect the special local distinctiveness of Ipswich heritage assets if necessary. DELETED: When the review is complete, the Council will if necessary prepare a supplementary planning document to ensure that there is no loss of protection of heritage assets.

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

8.48 All conservation areas have been the subject of detailed Conservation Area Character Appraisals. Those for areas designated by 1994 were the subject of public consultation and Council approval during 1994-5. Subsequently three additional conservation areas were declared in 1995, 2003 and 2005 for which appraisals were also prepared. Periodic reviews of all conservation areas are required by heritage legislation and these have been undertaken at approximately five yearly intervals since 1994 involving a review of boundaries, the descriptive content of the appraisals and the area specific policies and proposals. DELETED: The most recent review and publication was concluded for all Conservation Areas in 2007-8 with the exception of the Wet Dock Conservation Area where the pace of regeneration and development within, and to the immediate surroundings, was such that the impact of this in terms of conservation policy and proposals remains under review. The Local INSERTED: Plan DELETED: Development Framework anticipates major change in or adjacent to parts of the Central Conservation Area but this is not expected or proposed to the same extent for the remainder of conservation areas.

8.49 The Orwell Estuary provides an important INSERTED: ecological network and landscape setting for Ipswich and helps define its history. It is characterised by its broad expanse of water and its gently rolling, wooded banks. The transition between the built-up character of Ipswich and open countryside is quite sharply defined around most of the present Borough boundary, with the transition from urban to rural appearance and uses being clearly appreciable.

8.50 For wildlife habitats INSERTED: , an ecological network approach has been adopted in accordance with the National Planning Policy Framework. Ecological networks are an effective way to conserve wildlife and biodiversity where habitats have become fragmented. They support its resilience to pressures such as urban development and climate change. The network includes internationally, nationally and local designated sites which are protected in accordance with the National Planning Policy Framework. DELETED: and geology, the protection to designated sites set out in Planning Policy Statement 9, Biodiversity and Geological Conservation, is considered comprehensive and will be used to guide the consideration of activities that could harm designated wildlife or geological sites of international, national, county or local significance, which will be identified on the proposals map. Development in the vicinity of areas with nature / wildlife and geological designations must take into account the wider effects on those sites. The Council also recognises its biodiversity responsibility under the Natural Environment and Rural Communities Act 2006. This Act introduced the requirement for public bodies, in exercising their functions, 'to have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity’.

8.51 Ipswich DELETED: has growth point status and will see significant new building over the plan period. It is therefore essential that opportunities be taken through development to conserve and enhance the biodiversity INSERTED: and canopy cover that is essential to life. This will include in some cases providing and enhancing strategic green space, such as the existing INSERTED: ecological networks DELETED: network of wildlife corridors, with biodiversity features, and in all cases incorporating provision for biodiversity. This could include green roofs or walls for insects and birds, wood piles for beetles, DELETED: or nest boxes for birds INSERTED: , and in ecological networks can increase permeability of wildlife in new development through biodiversity enhancements. Therefore the policy will apply to all new developments in the Borough. Development at the Northern Fringe will provide an opportunity to contribute to biodiversity.

8.52 The plan has been subject to an Appropriate Assessment under the Habitats Directive. This concluded that visitor numbers to the Orwell Estuary will increase as a result of growth in the Ipswich Policy Area and could adversely affect the Estuary's Special Protection Area for birds. Measures to avoid and mitigate any such potential impacts are included in the plan. INSERTED: An update of this Appropriate Assessment is being undertaken alongside this plan.

(2) 8.53 Scheduled Ancient Monuments are designated by the Secretary of State INSERTED: who must approve any works that might affect them, having consulted English Heritage as the body responsible for national policies on their maintenance and recording. DELETED: and the records are held by the national agency, English Heritage. English Heritage also develops policies to protect the monuments. Consent is required to undertake works that could affect them. This national protection INSERTED: National policy obviates the need for a local policy on this matter. INSERTED: Proposals affecting Ipswich heritage assets should be informed by the Historic Environment Record for Suffolk maintained by the County Council which is also DELETED: Suffolk County Council holds the Historic Environment Record for Suffolk including Ipswich and they are consulted on planning applications that could affect archaeology. Ipswich's archaeological legacy is important in helping to tell the town's story and will therefore be protected and managed in accordance with INSERTED: the NPPF DELETED: Planning Policy Statement 5.

8.55 English Heritage also has a role registering historic parks and gardens. Whilst registration offers no additional statutory protection, it is a material consideration in development management.

8.56 In addition to protected Listed historic buildings, there are many buildings of local townscape interest INSERTED: (on ‘local lists’) that are not just confined to conservation areas but are located throughout Ipswich. Some of these buildings INSERTED: may be DELETED: are the main architectural landmarks of distinction in the local area. Many such buildings were designed DELETED: by local architects during the 19^th and 20^th Centuries INSERTED: by local architects. DELETED: The government's proposed heritage protection reforms encourage local planning INSERTED: Local authorities INSERTED: are encouraged to prepare inventories of INSERTED: such buildings DELETED: of local interest (“Local Lists”) and add these to INSERTED: the Historic Environment INSERTED: Record DELETED: Records. INSERTED: It is government policy that these non-designated heritage assets should be taken into account when determining planning applications to ensure DELETED: that proper consideration is given to their retention so INSERTED: as to DELETED: that these help DELETED: to maintain local distinctiveness and a sense of place. DELETED: There is already an INSERTED: An Ipswich Local List dating from 1977 DELETED: , which INSERTED: has been DELETED: will be updated and adopted as a supplementary planning document during INSERTED: 2013 DELETED: 2011.

8.57 All the designated sites or areas will be listed in the INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan INSERTED: ) DELETED: and Site Allocations and Policies development plan INSERTED: document DELETED: documents and will be identified on the INSERTED: policies DELETED: Proposals Map.

8.58 The Council will encourage the conservation and efficient use of natural resources in order to work towards sustainable 'one planet' living in Ipswich. This will be implemented through a development management policy in Part C of this document that applies the framework provided by the Code for Sustainable Homes and BREEAM rating. In addition, new development will be required to minimise waste generated.

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

8.60 This policy supports plan objective 1.

8.62 Ipswich is INSERTED: planning for growth DELETED: a growth point and ways therefore need to be found to optimise the accessibility of new developments without increasing congestion. The town benefits from being relatively compact, which lends itself to cycling and walking.

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

8.64 If people are to be encouraged to walk, cycle and use public transport, to help the town achieve environmental and health objectives, then developments must be located and designed such that these modes rival the car for cost and convenience INSERTED: and that routes are more pleasant in the surroundings such as along avenues or ecological networks.

(1) 8.65 The INSERTED: Travel Ipswich scheme DELETED: proposed Major Scheme ‘Ipswich - Transport Fit for the 21^st Century' has been developed over recent years to support regeneration objectives through an integrated package of sustainable transport measures. It will include changes to the town centre bus interchanges; expansion and improvement of other bus facilities; an Urban Traffic Management and Control system; a Real Time Passenger Information system; and a detailed programme of improvements to walk/cycle routes and crossings in and around the town centre.

8.66 The INSERTED: Travel Ipswich INSERTED: scheme DELETED: Major Scheme will deliver wide-ranging improvements for users of these modes DELETED: if funding is forthcoming from the Government.

8.67 This policy is also aimed at ensuring the accessibility of buildings and developments by people whose mobility is impaired.

8.68 Ipswich has relatively tight administrative boundaries and clearly there are cross boundary issues that are relevant to the development and future of DELETED: both the Borough INSERTED: , DELETED: and the urban area of Ipswich INSERTED: and surrounding areas.

(1) 8.69 This has long been recognised within the INSERTED: former Suffolk Structure Plan via the identification of the 'Ipswich Policy Area'. INSERTED: The Ipswich Policy Area consists of Suffolk County Council, Babergh District Council, Ipswich Borough Council, Mid Suffolk District Council and Suffolk Coastal District Council and the Ipswich Policy Area Board consists of councillors and is a key vehicle for cross boundary planning.

8.72 DELETED: Regional Spatial Strategy Policy H1 also refers to the need for coordination and consistency of approach between neighbouring authorities. In planning strategically for housing, employment and infrastructure provision, the Council will need INSERTED: to continue to work closely with neighbouring local authorities to ensure a coordinated approach INSERTED: in line with the Duty to co-operate.

(2) 8.73 The Council recognises the importance of joint working on Ipswich Policy Area matters, but at present considers that this can best be achieved through means other than the preparation of formal joint development plan documents INSERTED: at present. DELETED: This position will be reviewed when the Council comes to review the Core Strategy.

(1) 8.74 In the meantime the Borough Council will have the opportunity to comment on key strategic planning applications in neighbouring authorities as well as work on their respective Local INSERTED: Plans DELETED: Development Frameworks. Neighbouring authorities, including parish councils, will have the opportunity to comment at all stages of the production of the Ipswich Local INSERTED: Plan DELETED: Development Framework.

8.75 As a starting point the Borough Council has been instrumental in setting up an Ipswich Policy Area Board involving Councillors from the Borough Council, the neighbouring authorities (Suffolk Coastal, Mid Suffolk and Babergh) and the County Council to focus on and discuss development issues. More details on this are provided within Chapter 10.

LIVE

8.76 The strategic planning of new homes is a key part of the Local INSERTED: Plan DELETED: Development Framework. This section addresses the strategic issues associated with delivering new homes.

8.77 It is divided into the following six policies:

POLICY CS7:

The Amount of New Housing Required

POLICY CS8

The Balance between Flats and Houses

POLICY CS9

Previously Developed Land Target

POLICY CS10

Ipswich Northern Fringe

POLICY CS11

Gypsy and Traveller Accommodation

POLICY CS12

Affordable Housing

8.78 These are addressed in turn below:

(3) 8.79 DELETED: The Regional Spatial Strategy gives the INSERTED: The Council INSERTED: had DELETED: a INSERTED: an adopted target to allocate land to accommodate INSERTED: at least DELETED: 15,400 INSERTED: 14,000 additional residential INSERTED: dwellings DELETED: units between 2001 and 2021 INSERTED: (at 700 dwellings per annum) and a further 700 dwellings per annum thereafter to 2027. Following updated population and household projection modelling work, the Council has an objectively assessed housing need of 13,550 dwellings at 677 dwellings per annum between 2011 and 2031. However given the capacity constraints of housing land supply in the Borough, there will be a need to engage with neighbouring authorities through the Ipswich Policy Area to meet future population and household needs. DELETED: This is equivalent to 770 dwellings per year. However, the Council revised this figure to 700 dwellings per annum (14,000 from 2001 to 2021) in the light of additional local evidence.

(1) 8.80 INSERTED: Since 2001 DELETED: In the nine years that have elapsed since 2001, various developments have been built or received planning permission INSERTED: and 6,903 dwellings were completed between 2001 and 2011. INSERTED: A number of developments continue to have unimplemented planning permissions and some remain under construction. Therefore, the number of dwellings that the Council will need to allocate land for through the Local INSERTED: Plan DELETED: Development Framework process is DELETED: now fewer than INSERTED: 13,550 DELETED: 14,000 INSERTED: required to 2031. Table 2 below sets out the housing land supply and requirement figures as at April INSERTED: 2013 DELETED: 2010 INSERTED: , looking forward to 2031.

TABLE 2 HOUSING LAND SUPPLY AND REQUIREMENT AT APRIL INSERTED: 2013 DELETED: 2010

		Number of dwellings	Discounted Numbers	Cumulative Numbers
1	INSERTED: Dwellings DELETED: Units completed between INSERTED: 2011 DELETED: 2001 and INSERTED: 2013 DELETED: 2010	DELETED: 6,566 INSERTED: 379	-	DELETED: 6,566 INSERTED: 379
2	INSERTED: Dwellings DELETED: Units under construction	DELETED: 673 INSERTED: 574	-	DELETED: 7,239 INSERTED: 953
3	INSERTED: Dwellings DELETED: Units with planning permission	DELETED: 2,137 INSERTED: 1,654	DELETED: 1,923 INSERTED: 1,489	DELETED: 9,162 INSERTED: 2,442
4	INSERTED: Dwellings DELETED: Units with a resolution to grant planning permission (subject to the prior completion of a Section 106 agreement)	DELETED: 836 INSERTED: 653	DELETED: 752 INSERTED: 588	DELETED: 9,914 INSERTED: 3,030
5	Number of INSERTED: dwellings DELETED: units required on new site allocations INSERTED: , in a broad location and on windfall sites to INSERTED: 2031 DELETED: 2022 (@ 700 dwellings p.a.)	DELETED: 4,786 INSERTED: 10,520		DELETED: 14,700 INSERTED: 13,550
6	DELETED: Requirement for years 2022-2027 @ 700 p.a.	DELETED:3,500		DELETED:18,200

TABLE NOTES

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

Line 1: Actual numbers of dwellings built between 1^st April 2001 and 31^st March INSERTED: 2013 DELETED: 2010. INSERTED: Note that although 6,903 dwellings were completed to 2011 and not 7,000 as required, the Council is beginning from 0 dwellings in 2011.

Line 2: INSERTED: Dwellings DELETED: Units under construction at 31^st March INSERTED: 2013 DELETED: 2010 - assumed that all will be completed over the plan period.

Line 3: Other INSERTED: dwellings DELETED: units with planning permission at 31^st March INSERTED: 2013 DELETED: 2010 - assumed that 10% of these will not be completed. DELETED: Note 150 dwellings reduction reflects site IP038: Great Whip Street planning permission being revised from 351 to 307 dwellings, and 47 Key Street disappearing from the housing land supply resulting in a reduction of 106 dwellings.

Line 4: INSERTED: Dwellings DELETED: Units with a resolution to grant planning permission from the Council's Planning and Development Committee but which are awaiting completion of a Section 106 Agreement before planning permission is issued, at 31^st March INSERTED: 2013 DELETED: 2010 - assumed that 10% of these will not be completed.

Line 5: To reach the INSERTED: local DELETED: regional target of INSERTED: 13,550 dwellings DELETED: 14,700 units by INSERTED: 2031 DELETED: 2022 INSERTED: together with windfall sites, further land will need to be allocated INSERTED: , and a broad location identified, for at least INSERTED: 10,520 DELETED: 4,786 new homes.

8.81 National guidance in INSERTED: the National Planning Policy Framework DELETED: Planning Policy Statement 3, Housing, is that Local Planning Authorities should set out their policies and strategies for delivering the level of housing provision, including identifying broad locations and specific sites that will enable continuous delivery of housing for at least 15 years from the date of adoption of the relevant development plan document.

(1) 8.82 This should include identifying a specific supply of developable sites for years 1-10 from adoption and, where possible, for years 11-15. Where it is not possible to identify specific sites for years 11-15, broad locations for future growth should be indicated. INSERTED: In the case of Ipswich this will be within the Borough boundary at this stage but future discussions will be required with neighbouring authorities within the Ipswich Policy Area due to capacity constraints. DELETED: (i.e. in the case of this Ipswich Core Strategy, for housing growth to about 2027). INSERTED: Windfall sites will also contribute to the housing supply and these are defined in the National Planning Policy Framework as sites not specifically identified as available in the Local Plan process and normally comprise previously-developed sites that have unexpectedly become available.

(1) 8.84 Table 2 shows that, as a result of housing completions between INSERTED: 2011 DELETED: 2001 and INSERTED: 2013 DELETED: 2010, DELETED: just under 7,500 units INSERTED: 13,121 dwellings remain to be delivered between INSERTED: 2013 DELETED: 2010 and INSERTED: 2031 DELETED: 2022 in order to meet the requirement.

(1) 8.85 Taking account of the known supply at April INSERTED: 2013 DELETED: 2010, and assuming that 10% of the units with planning permission or awaiting the signing of a planning agreement will not actually be built within the plan period, it is suggested that the Council should allocate land for at least INSERTED: 5,909 DELETED: 4,786 dwellings. Sites will be allocated through the Site Allocations and Policies INSERTED: (incorporating DELETED: and IP-One Area Action Plan INSERTED: ) development plan INSERTED: document DELETED: documents, having regard to the strategy set out within this document INSERTED: and in CS10. The Council has undertaken DELETED: a INSERTED: an update to the 2010 Strategic Housing Land Availability Assessment (SHLAA) and is satisfied that sites within the Borough are capable of delivering the housing requirement INSERTED: in the ten years to 2023.

(2) 8.86 The phasing of housing sites will be informed by the findings of the SHLAA, infrastructure delivery and the preparation of master plans. The SHLAA informs the Council’s housing trajectory DELETED: , which is summarised below. It is based on recent contact with developers and landowners. DELETED: The SHLAA at March 2010 shows an indicative capacity of about 9,400 dwellings, and will be updated on an annual basis. It is from this potential supply that site allocations INSERTED: are DELETED: will be drawn. Within the tightly drawn boundary of Ipswich, options for the housing land supply are inevitably limited INSERTED: , hence the need to consider future development opportunities beyond the Borough boundaries. Table 3 below provides a breakdown of the housing land supply whilst Table 4 provides a breakdown by delivery period. Delivery will be monitored closely through the Council's INSERTED: Authority DELETED: Annual Monitoring Report.

8.87 This policy supports plan objective 3.

TABLE 3 ESTIMATED HOUSING DELIVERY FOR INSERTED: 2013-2031 DELETED: 2010-2027 EXCLUDING CURRENT PERMISSIONS AS AT 1^ST APRIL INSERTED: 2013 DELETED: 2010

Area of Ipswich	%age (dwellings) Previously developed land	Additional dwellings INSERTED: 2013-2031 DELETED: 2010-2022	DELETED: Additional dwellings 2022-2027
IP-One	100%	DELETED: 1,699 INSERTED: 999
Rest of built up area	DELETED: 71% INSERTED: 75.8%	DELETED: 1,511 INSERTED: 1,458 (PDL: DELETED: 1,080 INSERTED:1,105)
Northern Fringe DELETED: south of railway line, west of Westerfield Road INSERTED: (see Policy CS10)	0%	INSERTED: 3,500 DELETED: 1,500
DELETED: Northern Fringe north of railway line east of Henley Road, and east of Westerfield Road (see Policy CS10)	DELETED:0%	DELETED:300
Total DELETED: 2010-2022 INSERTED: 2013-2031 (excluding windfall and broad locations)	DELETED: 55% INSERTED: 35.3%	DELETED: 5,010 INSERTED: 5,957 (PDL: 2,104)
Small windfall sites INSERTED: 2013-2031	100%	INSERTED: 1,080	DELETED:300
Large unidentified brownfield sites INSERTED: 2023-2031	100%	INSERTED: 1,600	DELETED:1,650
DELETED: Northern Fringe north of railway line east of Henley Road, and east of Westerfield Road (see Policy CS10) INSERTED: Residual need later in plan period	0%	INSERTED:1,972	DELETED:1,500
Total DELETED: 2022-2027 INSERTED: 2013-2031	DELETED: 57% INSERTED: 45.1%	INSERTED: 10,609 (PDL: 4,784)	DELETED:3,450

TABLE 4 ESTIMATED HOUSING DELIVERY AND PREVIOUSLY DEVELOPED LAND (PDL) TRAJECTORY (INCLUDING SITES WITH PLANNING PERMISSION AND UNDER CONSTRUCTION INSERTED: BUT NOT INCLUDING WINDFALL SITES)

Time period	2001- DELETED: 2009 INSERTED: 2011	DELETED: 2009-2010 INSERTED: 2011-2013	DELETED: 2010-2022 INSERTED: 2013-2031	DELETED: 2022-2027
Housing Delivery	DELETED: 6,177 INSERTED: 6,903	DELETED: 389 INSERTED: 379	DELETED: 8,518 INSERTED: 8,546	DELETED:3,533
PDL%	DELETED: 95% INSERTED: 94.5%	DELETED: 95% INSERTED: 69.1%	DELETED: 71% INSERTED: 52.5%	DELETED:57%

8.88 National policy in INSERTED: the National Planning Policy Framework DELETED: PPS3 calls for a variety of housing to be provided in terms of tenure, type and size in order to support the creation of mixed and sustainable communities. This demands an understanding of the existing dwelling stock, and the nature and needs of existing and projected future households. It also requires some understanding of the Ipswich housing market. A Strategic Housing Market Assessment (SHMA) of the Ipswich housing market area was published in November 2008 and provides evidence to support policy preparation on this matter. INSERTED: The SHMA has subsequently been updated with the most recent version published in August 2012.

8.89 It identifies key housing issues for Ipswich as follows:

• Ongoing need for significant affordable housing, primarily small homes reflecting decreasing household size;
• Ipswich's cheapest housing stock for sale is dominated by small, two and three bedroom terraced homes, but this stock is ageing and often in poor repair;
• Meeting the housing needs of an ageing population;
• Responding to demographic changes - Ipswich is seeing growth in its student population, and in Black and Minority Ethnic communities;
• Reconciling a constrained land supply and decreasing household size with a current oversupply of flats and poor perceptions of flats; and
• Matching the jobs to be created with the housing workers will want and need.

8.90 The affordable housing need is primarily for small homes including smaller family homes, whilst for market housing, provision will need to match aspirations for job creation and improved qualification levels.

8.91 Creating sustainable communities requires the Council to compare the stock with the need for both market housing and affordable housing and the likely profile of household types requiring housing (e.g. do they contain children, are they single person households?).

8.92 The main drivers for change identified in the SHMA are:

• The growth of employment and housing DELETED: in the Haven Gateway;
• Investment aimed at raising qualification and income levels in Ipswich;
• An ageing population;
• The growing presence of students; and
• Fast growing BME groups in Ipswich.

8.93 A balance of types of properties is need across the plan period, rather than a significant majority of one type at one time. The approach set out in this policy will help to ensure a variety of provision.

8.94 The market has a key role to play in this issue. INSERTED: Between 2001 and 2011 the DELETED: The recent housing supply in Ipswich DELETED: has consisted mainly of flats. DELETED: About 75% of the dwelling units approved or built between 2001 and 2006 in Ipswich were flats (although at 2005, flats still only represented 18.7% of the Ipswich dwelling stock). More recently flats have proved vulnerable to changing market conditions, demonstrating the speed with which the market view can change.

8.95 In the wider Ipswich housing market however, the DELETED: recent growth in the provision of flats in central Ipswich has been complemented by housing development elsewhere in the Borough, such as at Ravenswood, and on residential sites outside the Borough but within the Ipswich Policy Area.

8.96 The approach to mix on major sites reflects the fact that larger schemes can best integrate a variety of housing types and can do so whilst still achieving appropriate densities, according to their location. DELETED: Of the major residential developments on which completions took place during 2007-2008, 50% of the sites contained a mix of dwelling types. Of planning permissions for major residential development at 1^st April 2009, nearly 50% of the schemes include a mix of dwelling types.

8.97 This policy links closely with Policy CS2, which sets out a locational approach to development density, Policy CS7 INSERTED: in setting out the housing requirement, and Policy DM30 which covers housing density. Density is inextricably linked with the dwelling types and sizes that a development can incorporate together with the amount of land needed to meet the housing requirement. Central sites should be high-density developments (containing a higher proportion of flats); sites in or close to district centres should be medium-density developments (a mix of flats and houses or town houses); and sites elsewhere should be low-density developments (containing a higher proportion of houses).

8.98 It is important to strike an appropriate balance between providing freedom and flexibility for the housing market to operate and ensuring that a range of sites are available for different areas of the housing market. The exceptions in this policy allow a degree of flexibility in controlled conditions.

8.100 The Council will check the mix of housing being provided on large sites through the INSERTED: Authority DELETED: Annual Monitoring Report.

8.101 This policy supports plan objectives 3 and 4.

(1) 8.102 INSERTED: The Government encourages the use of previously developed land known as brownfield land through the National Planning Policy Framework and enables local planning authorities to consider setting locally appropriate targets. DELETED: Planning Policy Statement 3 ‘Housing’, requires 60% of all new residential development to be provided on previously developed land. The Regional Spatial Strategy takes this target and incorporates employment development also, so that 60% of all development is to take place on previously developed land (Policy SS2).

(1) 8.103 Between 2001 and INSERTED: 2013 DELETED: 2010, INSERTED: 93% DELETED: 95% of new residential development in Ipswich took place on previously developed land. The Council is proud of its very strong record in this area. However, as previously developed sites become redeveloped and regenerated, it will become more difficult to sustain this proportion of development on previously developed land over the plan period. INSERTED: The twin approach adopted of urban regeneration plus greenfield urban extension ensures that the Council can address its objectively assessed housing need.

8.105 In terms of employment development, between 2001 and INSERTED: 2013 DELETED: 2008, quite a high proportion has taken place on greenfield land, largely because of the role that Ransomes Europark has played in meeting demand. This will decline now as Ransomes Europark nears completion. Of the Borough's employment land supply at April INSERTED: 2013 DELETED: 2009, INSERTED: the majority of DELETED: all the supply is on previously developed land, except the remaining land at Ransomes Europark INSERTED:, land north of Whitton Lane and land at Airport Farm Kennels.

8.106 It does not necessarily follow that previously developed land is less biodiverse than greenfield land. For example, in some instances former industrial processes can create conditions suitable for certain communities of plants INSERTED: and animals to flourish that would not normally be found in INSERTED: such a locality. Therefore policy DM31 will apply to all sites.

(2) 8.107 The Council needs to INSERTED: meet the full, objectively assessed needs for housing in the Borough DELETED: identify broad locations and specific sites that will enable the continuous delivery of housing for at least 15 years from the date of adoption INSERTED: (National Planning Policy Framework paragraph 47) DELETED: (PPS3 paragraph 53). Specific sites will need to be identified for the first INSERTED: five DELETED: ten years of the plan period. For the INSERTED: following ten years DELETED: last five years, specific sites or broad locations can be indicated.

(1) 8.108 Urban regeneration objectives have led the Council to focus development into central Ipswich over recent years. This has supported the successful regeneration of the Waterfront and Ipswich Village, introducing a greater range of uses into each, thereby adding to their diversity and vibrancy. This strategy has seen significant redevelopment of previously developed sites within the town (including INSERTED: 93% DELETED: 95% of all housing between 2001 and INSERTED: 2013 DELETED: 2009). It has benefited from rationalisation and restructuring in the employment sector away from more land intensive activities such as manufacturing, so that sites such as that on Ranelagh Road (formerly Compair Reavell) have come forward for mixed use redevelopment. However, the manufacturing sector has shrunk significantly and therefore it raises the question as to how far into the future the rationalisation of land uses in the centre of Ipswich will sustain a supply of brownfield sites.

(2) 8.109 The tight urban boundary to Ipswich Borough means that there is only one area of extensive greenfield land still available on the periphery of the town and within the Borough. The land is located on the northern edge of the urban area and is known as the Northern Fringe. Development of the Northern Fringe would represent a major urban extension to the town. This could work against the plan's spatial strategy set out in policy CS2 by undermining urban regeneration efforts INSERTED:, however to meet objectively assessed housing need, developing the whole Northern Fringe is required. DELETED: Therefore, the questions as to whether the Northern Fringe land is needed as part of the fifteen year land supply, and how or when it would be released if so, are strategic issues to be determined through the Core Strategy.

8.110 The indicative capacity at the Northern Fringe identified in the Strategic Housing Land Availability Assessment INSERTED: has been reduced to 3,500 DELETED: is about 4,500 dwellings INSERTED: following early capacity work on the Northern Fringe Area Development Brief supplementary planning document. The Council has identified a need for 13,550 dwellings between 2011 and 2031, and the Northern Fringe forms a key component of meeting this need. DELETED: When determining its views on the precise number and timing of delivery of dwellings needed at the Northern Fringe, the Council will use a range of evidence including the Ipswich Housing Needs Study projections for the whole of Ipswich Policy Area, projections for employment demand, demand for Ipswich Borough housing stock and for other Social Housing, together with an estimate of the level of existing vacant property and other relevant factors to assist it in reaching its view on the appropriate household and dwelling growth numbers for the Policy Area and the Borough area.

(3) 8.111 The Council will work with Babergh, Mid Suffolk and Suffolk Coastal District Councils to ensure optimum sustainable distribution of housing within the Ipswich Policy Area, bearing in mind the amenity INSERTED: and ecological value of the countryside outside the Borough boundary as well as within it, and the increased congestion effects of any development outside the Borough boundary.

(1) 8.112 The policy provides for residential led development at the Northern Fringe. DELETED: This would include some or all of the areas between Henley Road in the west, and Tuddenham Road in the east and north of Valley Road/Colchester Road. The County Council's Structure Plan in 2001 concluded that of all major greenfield sites around the edge of Ipswich, the north Ipswich area was the most appropriate next one to build on. This conclusion was reached following an independent examination of various options.

(1) 8.113 In practical terms there are no other areas within the Borough boundary that the Council could realistically identify as having the potential as a broad location of future growth for the final INSERTED: ten years of the DELETED: phase of the 15 year plan period.

(1) 8.115 DELETED: In developing an area even for 1,000 to 1,500 dwellings, the INSERTED: The infrastructure requirements INSERTED: at the Northern Fringe will DELETED: are likely to be significant and include new roads INSERTED: , ecological networks and green INSERTED: corridors DELETED: routes, new public transport routes and services, green infrastructure such as allotments and sports facilities, new schools, new recreation provision, DELETED: new healthcare provision and local shopping facilities. This infrastructure can also deliver benefits to the existing communities in the area and help to sustain them. The proper planning and delivery of this infrastructure is most likely to result from a comprehensive approach to development in the area. INSERTED: The detailed infrastructure requirements of the development of approximately 3,500 dwellings at the Northern Fringe and trigger points for the delivery of the items of infrastructure are identified in Table 8B in Chapter 10 of the Core Strategy. Prior to development on the Ipswich School Playing Fields site, replacement sports facilities will be required to be first provided in accordance with Policy DM28. INSERTED: The site for replacement playing fields is allocated to the west of Tuddenham Road and north of the railway line. DELETED: Infrastructure requirements were considered during the appeal by Mersea Homes against the Council’s refusal of outline planning permission for major residential led development at the Northern Fringe (application reference IP/09/00465/OUT). The Secretary of State dismissed the appeal on 30^th September 2010. Key conclusions about infrastructure provision from the letter and the Inspector’s report are reflected in the policy above.

8.116 The total number of dwellings likely to be accommodated at the Northern Fringe DELETED: could be as much as INSERTED: is up to 3,500 DELETED: 4,500 in the longer term, but this will be determined through a review of the Core Strategy. The Council will commence a review of the Core Strategy in 2012/13. This will provide plenty of opportunity for interested parties – be they developers, landowners, local residents or others – to get involved and have their say prior to the extent of Northern Fringe development being determined. However, INSERTED: In order to ensure that any development proposed for this area DELETED: prior to 2021 conforms to a coherent plan, work on the supplementary planning document INSERTED: commenced in early 2012 following the adoption of the Core Strategy in December 2011. Any planning application for the development of the area, which is submitted before the adoption of the Core Strategy Focused Review or the Supplementary Planning Document, will be required to have regard to the content of emerging policy and guidance in Policy CS10 and the Supplementary Planning Document respectively. This is to ensure the proper long term planning of the Northern Fringe area to deliver sustainable, integrated development. Key conclusions about infrastructure provision at the Northern Fringe from the Secretary of State’s dismissal of the appeal by Mersea Homes in September 2010 are reflected in the policy above. DELETED: will commence as soon as the Core Strategy has been adopted. The work on the supplementary planning document will incorporate sufficient flexibility to allow for a wide range of housing numbers for the Northern Fringe.

8.117 This policy supports plan objective 3.

8.118 Ipswich has 43 permanent pitches for Gypsies and Travellers at present, but a INSERTED: future Gypsy and Traveller Accommodation Assessment (GTAA) DELETED: single issue review of the Regional Spatial Strategy INSERTED: will identify the DELETED: has concluded that the Borough needs to INSERTED: 2027. DELETED: provide an additional 15 permanent pitches by 11, and a further 3% per year thereafter to 2021. In addition, national guidance requires the Core Strategy to include a criteria based policy to guide the siting and location of sites for Gypsies and Travellers. The accommodation needs of Gypsies and Travellers need to be considered alongside those of the 'settled' population.

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

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

8.121 Sites will be sought to meet the joint needs of Ipswich and neighbouring authorities for permanent pitches within the Ipswich Policy Area. All neighbouring local planning authorities INSERTED: will have DELETED: had needs identified by the DELETED: RSS and Gypsies and Travellers Accommodation Assessment (GTAA) carried out in INSERTED: 2013 DELETED: 2007. The joint GTAA 2007 INSERTED: previously identified needs and is currently being updated and is expected to be published INSERTED: in 2013. DELETED: towards the end of 2011. The identified need will inform the site allocations in the subsequent DPDs and a future review of the Core Strategy.

8.122 The Council will work with Suffolk authorities to meet the joint transit needs and the needs of travelling showpeople. The DELETED: GTAA update will review needs and the Council will demonstrate through the Site Allocation INSERTED: and Policies (incorporating DELETED: and IP-One INSERTED: Area Action Plan) DELETED: AAP INSERTED: development plan document DELETED: DPDs where and when this need will be met.

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

8.124 The Council will work with the Gypsy and Traveller communities to ascertain need in particular locations, prior to the identification or allocation of sites.

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

8.126 This policy supports plan objectives 3 and 10.

(1) 8.127 Affordable housing is defined in INSERTED: the National Planning Policy Framework DELETED: Planning Policy Statement 3, Housing, as 'including social rented⁸, INSERTED: affordable rented⁹ and intermediate housing¹⁰, provided to specified eligible households whose needs are not met by the market'. National policy requires local planning authorities to set an overall target for the amount of affordable housing to be provided. DELETED: Regional Spatial Strategy sets a target for 35% of housing coming forward across the region to be affordable.

(1) 8.128 he Ipswich Housing Needs Study 2005 looked at housing needs across the Borough. It has been partly updated through the Strategic Housing Market Assessment INSERTED: (SHMA) in 2008 INSERTED: , which has further been updated through a SHMA in 2012. Combined findings of the INSERTED: three DELETED: two studies indicate that:

• around 66% of households are owner occupiers, 22% live in the social rented sector and 12% in the private rented sector;
• one quarter of households consist of older persons only, and such households account for 37% of all Council accommodation;
• around 12% of the net affordable housing requirement comes from key worker households;
• nearly 2% of households live in overcrowded homes, whilst 34% under occupy their dwelling;
• when households were asked in 2005, around two thirds of their previous house moves had been within the Borough;
• Ipswich has lower than average property prices;
• INSERTED: there is a need for an additional 584 affordable homes per year;
• DELETED: there is a shortfall of affordable housing 2005-2010 of 798 units per annum and ongoing need thereafter;
• the need is most acute for small properties, notably 2 bedroom homes, and is geographically widespread; and
• 80% of any affordable target should be social rented housing.

8.129 The targets will be subject to viability testing on a site by site basis, using a recognised toolkit.

8.130 The targets will guide the requirement for affordable housing on allocated sites and windfall sites, but actual provision on each site will be determined through negotiation having regard to:

• development size;
• site development costs;
• the requirement to deliver new housing;
• scheme viability including the availability of Social Housing Grant; and
• costs associated with other planning objectives such as planning to reduce carbon emissions.

8.131 If the Council agrees that provision at 35% or 20% is not viable on a specific site, then a lower percentage, to be agreed, will still be expected. In agreeing any lower provision through Section 106 Agreements, the Council will look to build in the flexibility to increase the amount in a rising market.

8.132 Because of the extent of housing need in Ipswich, the Council considers it appropriate to set a threshold for affordable housing provision at 10 dwellings. The lower target at 20% reflects the reduced capacity for economies of scale in smaller developments.

8.133 The Council wishes to see at least 80% of affordable housing provision as housing for social rent. The Housing Needs Study indicated that need amounts to 80% of provision. The Council has to balance need with the requirements of the development industry and the need to ensure schemes are delivered. Recent practice in Ipswich INSERTED: prior to 2011 has been based on 65% of provision for social renting and the remainder mainly shared ownership. However, difficulty in disposing of shared ownership units, together with ongoing high levels of need for rented housing, support an increase in this proportion.

8.134 The Ipswich 2005 Key Worker Study recognised the need for appropriate housing for key workers, but also found that key workers' wage rates compared well with other pay levels in the local economy. For this reason, we believe that current Homebuy arrangements meet the needs of key workers locally and we would not wish to encourage development of specific housing for key workers. This will be kept under review.

8.135 Policy CS17 sets out the approach to planning standard charges and clearly states that affordable housing will remain outside the standard charge system. A more detailed affordable housing policy is set out in Part C.

8.136 The INSERTED: NPPF DELETED: PPS3 definition of affordable housing will apply in implementing this policy.

8.137 The policy implements plan objective 3.

WORK

(1) 8.138 It is equally important that the Council plans for employment issues as well as for new housing. This section addresses the strategic issues INSERTED: for jobs growth within the Ipswich Policy Area to 2031 DELETED: associated with the Regional Spatial Strategy requirement to provide for an additional 30,000 jobs between Ipswich Borough, Babergh and Suffolk Coastal between the years 2001 and 2021.

8.139 It is divided into the following two Policies:

Policy CS13: Planning for Jobs Growth

Policy CS14: Retail Development.

8.140 These are addressed in turn below.

(704) 8.141 DELETED: Ipswich is a growth point and a key centre for development and change. INSERTED: The wider Ipswich area is identified as a principal economic growth location in the Suffolk Growth Strategy 2013. Whilst the focus of monitoring and meeting delivery targets is generally on residential development at a national level, it is essential that housing growth in Ipswich is INSERTED: supported DELETED: matched by employment growth. DELETED: The town cannot support a growing population without commensurate change in the level of accessible jobs provision.

8.142 DELETED: The East of England Plan sets a target of 30,000 jobs to be provided in the Suffolk Haven Gateway (excluding Mid Suffolk District) between 2001 and 2021. Ipswich is a key economic driver of the INSERTED: Ipswich Policy Area within the Suffolk Economy DELETED: Haven Gateway area and will therefore provide a significant proportion of these. The Haven Gateway Employment Land Study 2005 forecast growth of 17,800 jobs in Ipswich between 2001 and 2021 (see Table 5).

(1) 8.143 A DELETED: more recent (2009) joint Employment Land Review INSERTED: was undertaken in 2009 DELETED: has been carried out by Ipswich Borough Council, Suffolk Coastal District Council and Babergh District Council through the Haven Gateway Partnership and in conjunction with Suffolk County Council. It recommended that a cross boundary approach be taken within the Ipswich Policy Area to ensure jobs provision. INSERTED: The Council is working in partnership with local authorities on the Suffolk Growth Strategy as agreed in February 2013 and also DELETED: The Council will therefore seek to work through the Ipswich Policy Area Board INSERTED: and DELETED: or other joint working forums INSERTED: as they arise to ensure that sustainable economic growth is achieved.

8.144 The INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan INSERTED:) DELETED: and Site Allocations and Policies development plan INSERTED: document DELETED: documents will translate the overall land requirement into sites. The Council will ensure that enough land is available, including a variety of site sizes and locations to suit different employment-generating activities. The 16.7ha of land allocated at the former Crane’s site is additional to the 30ha specified in clause a. of the policy.

(699) 8.145 It should be noted that the jobs INSERTED: growth aspiration DELETED: target in the Regional Spatial Strategy covers all sectors and not just the employment use classes of B1 office, B2 general industry and B8 warehousing and distribution. INSERTED: The jobs figure is lower than that previously identified to reflect more recent evidence from the East of England Forecasting Model in 2012 and covers the period 2011 to 2031. The previous figure was derived from an indicative target of 30,000 jobs for the Suffolk Haven Gateway area including Suffolk Coastal and Babergh District Councils between 2001 and 2021 as identified in the East of England Plan.

(2) 8.146 In allocating sites for employment development, the Council will take account of the sectors projected to have the highest jobs growth INSERTED: over the plan period as identified in the Suffolk Growth Strategy DELETED: between 2006 and 2026 as identified in the Suffolk Haven Gateway Employment Land Review (2009) INSERTED:, and those growth sectors identified in the New Anglia Local Enterprise Partnership Plan for Growth. These include:

(1) 8.148 The Regional Spatial Strategy INSERTED: required DELETED: requires that readily serviceable regionally significant strategic sites are identified within the Haven Gateway to support regeneration at Ipswich including its role in communications technology, and development associated with port expansion at Felixstowe. INSERTED: The Suffolk Growth Strategy identifies these in conjunction with local authority Local Plans.

8.149 The Employment Land Review investigated both demand/need for and the possible supply of strategic employment sites in the Ipswich area. It concluded that there is capacity for a site in Ipswich, in addition to other possible sites within the Ipswich Policy Area. The former Crane’s site will function as Phase II of the Ransomes Europark development and help to consolidate an important employment corridor. DELETED: Any additional greenfield employment land provision in the vicinity of Crane’s will need to be resisted until Crane’s has been substantially developed, in order to ensure its delivery. Only when the Crane’s site is substantially complete will options for a possible Phase III be considered. The site's location is indicated on the Key Diagram. A detailed site boundary is defined on the INSERTED:policiesDELETED: Proposals Map.

8.150 The site is allocated for B1, B2 and B8 uses under the Use Classes Order. Office uses are directed to the town centre through the approach to the location of development set out in policy CS2. This will further be reflected in site allocations to be made in the INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document DELETED: IP-One Area Action Plan and is in accordance with INSERTED: the National Planning Policy Framework DELETED: PPS4, which defines offices as a town centre land use. However, B1 office uses may exceptionally be considered acceptable at the former Crane’s site, if they are linked to other on-site activities such as research and development that require a large site, or are directly related to the key growth sectors identified DELETED: in the Regional Spatial Strategy and/or Employment Land Review and are therefore performing a strategic role. The site could also be suitable for the provision of some starter units to support new businesses.

8.152 The former Crane’s site has good public transport accessibility with four bus routes passing it.

(1) 8.153 The tourism sector is a significant sector in Ipswich. DELETED: In 2006, direct tourist spend in Ipswich amounted to £140m and overnight stays numbered 974,000. Policies elsewhere in the plan set out the approach to INSERTED: arts, cultural and tourism DELETED: cultural and leisure provision in the town. The Council will support University Campus Suffolk by safeguarding the campus for uses needed to deliver the university and college developments.

8.154 The Council will not be able to deliver the required jobs growth working alone. It will work with partners and the market to aid delivery. Particularly important will be joint work through the INSERTED: Suffolk Growth Strategy and with the New Anglia Local Enterprise Partnership DELETED: Haven Gateway Partnership to deliver the infrastructure needed for jobs; DELETED: work with the oneipswich partnership to address local issues and ensure that the benefits of job creation reach those who most need them; and work with the Homes and Communities Agency to explore the need and opportunities for direct intervention to support the land supply e.g. through land purchase or remediation.

8.155 The Council will also work through other areas of service delivery to support jobs growth, for example through marketing, DELETED: and promotion INSERTED: and investment activity DELETED: , and using its own land holdings to support employment, where appropriate.

(1) 8.156 DELETED: The Regional Spatial Strategy identifies Ipswich town centre as a regional centre of strategic importance for retail and other town centre purposes (RSS Policy E5). Ipswich town centre is ranked 35^th nationally. As the county town serving a significant rural hinterland, and relatively isolated from competing centres, it is an important focus for shopping, working, sport, culture, leisure, education and civic life for Ipswich residents and a wider population.

8.157 Within the Ipswich Policy Area the population is forecast to grow over the plan period, which will generate new retail expenditure. However, neighbouring centres such as Colchester and Bury St Edmunds have both enjoyed more recent investment in town centre retailing, and there are other pressures on the centre such as the general economic downturn, nearby out of town retail parks largely outside the Borough, and Internet shopping. Therefore there is no room for complacency in planning to maintain and enhance Ipswich's role as a regional centre.

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

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

8.160 The policy responds to the findings of the Ipswich Retail Study 2005, as confirmed by the Retail and Commercial Leisure Study 2010, and Ipswich's role and status as a county town and a regional centre DELETED: defined in the East of England Plan.

8.161 The Ipswich Retail Study 2005, as confirmed by the Retail and Commercial Leisure Study 2010, identified gaps in the retail offer of Ipswich town centre as follows:

• significant capacity for new town centre comparison goods (non-food) retailing;
• a need for a better balance of 'higher end' retailers;
• limited capacity for additional convenience (food) retailing;
• a need for an additional department store to anchor the town's retail offer;
• a need for a more flexible approach to food and drink uses within the primary and secondary shopping areas;
• a need to boost the evening economy through considering more leisure activity within the centre; and
• a need for large and modern shop units to satisfy the needs of major retail and leisure operators.

8.162 An extended Central Shopping Area with additional retail site allocations will go some way to addressing these gaps in the offer, subject to general market conditions. DELETED: The floor space set out in the policy is a minimum. Sites will be allocated through the INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan INSERTED: ) development plan document. Clearly delivery will be the key to success, and the Council will work with others and through its own land holdings and as local planning authority to achieve it. In addition the Council will evaluate the practicalities of improving evening access in the principal pedestrianised streets after normal trading hours, to encourage the use of facilities in the evening. The Council is working with the BID and others to implement a scheme of way marking in the town centre.

8.163 The Council will work with Ipswich Central, landowners and other partners to develop an active strategy to bring vacant premises in the town centre back into active use or, at a minimum, to introduce a scheme to make vacant premises look more visually attractive.

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

8.165 The INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan INSERTED: ) development plan document will extend the Central Shopping Area boundary from that shown in the 1997 Local Plan and will allocate new sites for additional retail development within it. It will also extend the wider town centre boundary as the focus for other 'town centre' uses such as leisure, offices, cultural uses and hotels. Enhancing the town centre forms an important part of the strategy for urban renaissance in Ipswich over the plan period.

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

8.167 This policy implements plan objective 5.

LEARN

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

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

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

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

(1) 8.172 DELETED: As a consequence the 14 - 19 centre will take some of the pressures off secondary school accommodation issues. It is not considered by the County Council that a new secondary school site is required within the Borough boundary although if a Northern Fringe development were to take place (see Policy CS10) in the future, INSERTED: then DELETED: it is possible that a new secondary school INSERTED: will DELETED: may be needed as part of it due to the scale of development and the capacity in the nearby schools.

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

8.174 At primary level, whilst local issues will be set out within the INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan INSERTED:) DELETED: and Site Allocations and Policies development plan INSERTED: document DELETED: documents, the specific growth related development pressures and the need to improve facilities are considered to necessitate new INSERTED: or extended primary DELETED: schools INSERTED: school provision within DELETED: on the eastern and western sides of the town. These should be facilitated within the INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan INSERTED:) DELETED: or Site Allocations and Policies development plan document and are included within the list of strategic projects in Part D.

8.175 At pre-school level the Council recognises the importance of nursery and children's centre provision and the importance of these being located in sustainable locations. Thus these uses should be encouraged within or adjacent to the district centres listed in paragraph INSERTED: 8.34 DELETED: 8.31.

8.176 This policy supports objectives 5 and 9.

PLAY

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

8.178 The Government in INSERTED: the National Planning Policy Framework DELETED: Planning Policy Guidance Note 17 (PPG17) points out how open space, sport and recreation can support many different objectives, including INSERTED: making an important contribution to the health and well-being of communities DELETED: supporting regeneration and promoting healthier lifestyles and community cohesion. There is one key policy under this heading, which is Policy CS16.

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

(1) 8.180 As the Borough grows, it is essential to protect, enhance and extend the network of open spaces, INSERTED: ecological networks, canopy cover DELETED: green corridors, and sports and recreation facilities. This is important in order to: allow people access to green space and nature; strengthen ecological networks that enable wildlife to migrate more easily around the town; link inner and outer parts of the Borough by providing walking and cycling routes; provide opportunities for formal and informal recreation; and to enhance the appearance of the town. The potential benefits are many - for example improved biodiversity, health and fitness, flood attenuation and better air quality.

(2) 8.181 The INSERTED: former Regional Spatial Strategy INSERTED: required DELETED: requires the identification, protection, creation, enhancement and management of areas and networks of green infrastructure in local development documents. INSERTED: The National Planning Policy Framework DELETED: Planning Policy Guidance Note 17 Planning for Open Space, Sport and Recreation requires local authorities to set local standards for open space, sport and recreation facilities, based on a local assessment of needs. It also states that existing sites and facilities should not be built on unless they have been shown to be surplus.

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

8.183 A development management policy in Section C of this document and Appendix 6 set out the local standards of provision of open spaces, sport and recreation facilities, based on the Ipswich PPG17 Study INSERTED: , which has been updated by the Council’s Parks and Open Spaces team. The infrastructure plan in Section D of this document sets out the strategic green infrastructure needs. The Council recognises that it will need to work with neighbouring local authorities to implement this, as realistically parts of any such network will be outside the Borough boundary. Strategic needs were identified by the Haven Gateway Green Infrastructure Strategy and the Council will consider the recommendations in planning future provision.

8.184 Open spaces can perform more than one function. An important role for some open spaces will be to act as flood water storage areas or flood paths. Flood risk assessments should where possible and appropriate, identify areas in valley bottoms at risk of flooding as flood management assets and keep them open.

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

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

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

8.189 This policy implements plan objective 8.

INFRASTRUCTURE

8.190 DELETED: The Regional Spatial Strategy proposes significant growth for the town. To enable DELETED: this development to take place in an appropriate manner it is essential that proper consideration is given to the infrastructure needs associated with the levels of development proposed. Whilst many infrastructure issues will just relate to individual developments, the Council believes that there are four areas where there is a need for strategic consideration of relevant issues within this document. These are:

Policy CS17: Delivering Infrastructure

Policy CS18: Strategic Flood Defence

Policy CS19: Provision of Health Services

Policy CS20: Key Transport Proposals

(1) 8.191 DELETED: As a growth point, it It is critical that Ipswich receives the infrastructure it needs to support the delivery of both housing and jobs growth, and to ensure that existing communities can be sustained. It is important that growth should bring benefits to, and not adversely affect the quality of life of, existing communities. The DELETED: recent development at Ravenswood has shown how a new urban community can be developed, such that housing is delivered alongside schools, shops, open space, bus services and other facilities.

8.192 There are a number of ways to ensure infrastructure delivery INSERTED: through the planning system. DELETED: The Government brought into force Community Infrastructure Levy (CIL) Regulations in April 2010, which were further amended in April 2011, and which indicate that CIL is optional for councils. The existing system in Ipswich is that of INSERTED: developer DELETED: planning obligations INSERTED: secured in Section 106 Agreements, which cover on- and off-site requirements including affordable housing, open space provision, transport measures, and education provision. DELETED: Planning obligations are legal agreements with the Council, entered into by developers. However, this system has not adequately picked up more strategic infrastructure impacts or needs, and can be accused of lacking transparency for developers INSERTED: when providing for standard off-site infrastructure in particular.

(1) 8.193 Therefore the Council will adopt a standard charge approach to the delivery of infrastructure INSERTED: alongside Section 106 Agreements, which was brought into force by the Community Infrastructure Levy (CIL) Regulations in April 2010. This will permit the Council to pool developer contributions raised through the levy and spend on infrastructure requirements for both the neighbourhood in which the development forms a part and the whole of Ipswich. This will likely be adopted in DELETED: run until 2014 INSERTED: /15 at which time INSERTED: Section 106 Agreements will secure only affordable housing, on-site infrastructure and specifically identified off-site infrastructure items that will not require the pooling of more than five obligations DELETED: pooled contributions will not be possible under CIL regulations. At this time the Council will move to a CIL-type approach.

8.194 Infrastructure can take many different forms. Appendix 5 to this plan lists the types of infrastructure referred to in this policy.

8.195 Growth requirements across the Borough will place additional pressure on existing infrastructure and will therefore require improvements to be made to existing infrastructure, and the provision of new infrastructure. A number of pressures can be relieved through site-specific provision such as open space, children's play areas and the provision of affordable housing. However, there are other infrastructure improvements and requirements that cannot always be accommodated on-site, or that relate to strategic off-site facilities serving the whole neighbourhood or Borough. It is therefore appropriate to pool INSERTED: developer contributions towards off-site provision to help ensure its delivery.

8.208 Responsibility for the delivery of infrastructure will be shared between developers, Ipswich Borough Council and key partners such as the INSERTED: New Anglia Local Enterprise Partnership, DELETED: Local Strategic Partnership, Haven Gateway Partnership, utilities companies, Highways Agency, Suffolk County Council INSERTED: , neighbouring local authorities, DELETED: and the Environment Agency INSERTED: , the Homes and Communities Agency, Natural England and local community groups.

8.209 Much of central Ipswich lies within the tidal floodplain of the River Orwell. Existing flood defences do not meet modern standards and will be inadequate to resist rising sea levels in the future. Thus many existing communities in the vulnerable areas do not or will not have adequate flood defences, and further regeneration in central Ipswich at the Waterfront and in Ipswich Village depends on the delivery of improved defences.

(1) 8.210 The Environment Agency, DEFRA and Ipswich Borough Council have agreed a Strategic Flood Defence Management Plan for Ipswich, which is in the process of being implemented. Its implementation is occurring in three phases:

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

2. raising the river walls on the east and west banks to the south of the Island Site - this commenced in 2009; and

3. installing a tidal flood barrier in the New Cut at the southern end of the Island Site - due INSERTED: 2018 DELETED: 2014.

The strategy is for the next 100 years and will include repairs to existing tidal and fluvial defences upstream of the barrier. The strategy is being planned to avoid the need to raise the level of these defences.

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

8.212 It is recognised that the tidal surge barrier is unlikely to be in place until INSERTED: 2018 DELETED: 2014, but the Council will work with the Environment Agency to ensure it is implemented as soon as possible and that, in the short term, as much preparatory work as possible is undertaken to enable the third phase (installation of the barrier) to be delivered as soon as the funding is secured.

8.213 The INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document DELETED: IP-One Area Action Plan will need to have particular regard to the flooding issues and the need to phase some developments to relate to the delivery of the tidal surge barrier. The DPD DELETED: Area Action Plan will identify those sites at risk. The DELETED: outcome of the INSERTED: Ipswich Strategic Flood Risk Assessment (SFRA) DELETED: SFRA Level 2 will inform allocations in this area and identify residual risks.

8.214 Part C of this document includes policies relating to flooding to reflect INSERTED: the NPPF DELETED: PPS25 and the detailed findings of the Ipswich Strategic Flood Risk Assessment.

8.215 In the interim period it is recognised that the Council needs to work with its partners to put in place better arrangements to cope with emergency planning scenarios associated with flooding.

8.216 The Council is reasonably certain that the funding for the final phase of the flood defences will be forthcoming. It has already obtained Growth Point funding via the Haven Gateway Partnership to contribute to the overall cost of the project INSERTED:, and has secured funding via the Growing Places Fund through the New Anglia Local Enterprise Partnership. The Council has made this project its top priority for the Community Infrastructure Levy.

8.217 If it were not completed at all, then the Council would need to review urgently the spatial strategy and housing delivery in the Borough. It is the Council's belief that, without the barrier, even if all possible land at the Northern Fringe were brought forward for earlier development, the Borough may not be able to meet its growth targets to INSERTED: 2031 DELETED: 2027. In addition, the completion of regeneration at the Ipswich Waterfront and in INSERTED: the part of the town centre near the railway station DELETED: Ipswich Village would not be possible. If the Flood Defence Management Strategy were not completed, the Level 2 SFRA would need to be based on the existing situation with the current defences to ascertain the flood risk to the town.

8.218 This policy implements objective 7.

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

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

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

8.223 The St Clement's Hospital site consists of a number of buildings and open spaces, including the Victorian hospital building, and grounds to the front and rear. It excludes the St Clement's Golf Course. DELETED: Part of the site is to be retained for continued mental health care provision, but a substantial proportion of the site is expected to become vacant in 2010. The Strategic Housing Land Availability Assessment INSERTED: update identifies DELETED: 2009 identified this as a site that would be appropriate (in part at least) for a housing allocation for approximately INSERTED: 227 DELETED: 350 homes INSERTED: following discussions with the landowner’s representatives. Accordingly, the reallocation of the site for these purposes will be dealt with through the Site Allocations and Policies INSERTED: (incorporating IP-One Area Action Plan) development plan document.

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

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

8.226 This policy supports plan objectives 9 and 10.

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

(2) 8.228 Public transport is an important part of the current and future transport packages and therefore the Council continues to support the INSERTED: Travel Ipswich DELETED: 'Ipswich: Transport Fit for the 21^st Century' scheme. More details on these proposals will be included in the INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan) development plan document. The Council will look to close the Waterfront Northern Quays route to general traffic but retain limited access, e.g. for public transport and appropriate operational use by Waterfront businesses. The reduction in cars using the route along the Northern Quays will help to enhance the area as a pedestrian environment and a visitor attraction.

8.229 The Felixstowe to Nuneaton rail line is part of the Trans-European Network and there are long-standing proposals to upgrade this route - particularly to enable greater rail based freight movements from Felixstowe port. DELETED: Currently all freight trains from Felixstowe need to come into or go through Ipswich station. The 'Bacon Chord' near Hadleigh Road, would be a short piece of new track that would enable trains to go direct from Felixstowe onto the Peterborough line without having to go into Ipswich station.

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

8.231 The Council supports the thrust of current national and local policy on transport which is on travel demand management.

8.232 There are concerns about highway capacity in the town centre, particularly within the Star Lane area. These capacity implications are closely linked to issues associated with the wider transport network – including the A14 and the Orwell Bridge.

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

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

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

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

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

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

8.235 Detailed proposals, including those for the Star Lane gyratory, INSERTED: are DELETED: will be included in the INSERTED: Site Allocations and Policies (incorporating IP-One Area Action Plan INSERTED: ) development plan document.

8.236 The delivery of a Wet Dock crossing (i.e. a new road linking Holywells Road/Duke Street with Hawes Street) is a long term prospect and it is as yet uncertain. It is recognised that it would only be likely to happen if the Island site comes forward for redevelopment. Potential funding sources include:

• LTP funding;
• Growth DELETED: Point funding DELETED: - the possibility of the route is flagged up in the Haven Gateway Integrated Development Plan;
• developer contributions DELETED: through standard charges for infrastructure delivery (see Policy CS17); and
• part funding from any Island Site development.

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

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

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

8.240 This alternative capacity could also be provided via a northern bypass of the town. The Council will actively encourage key partners to investigate the possibility of a northern bypass, to address the issue of:

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

The Council will work with neighbouring authorities and Suffolk County Council to ensure that the merits and delivery options for some form of northern bypass are fully investigated. It is recognised that any such route would be within the Suffolk Coastal District Council and Mid Suffolk District Council areas (i.e. not between any possible Northern Fringe development - Policy CS10 - and Westerfield village) and therefore it is not practical to include such a route within this Strategy. However, the Council will encourage those authorities, together with Suffolk County Council and other interested parties, to actively investigate such a route, and would be prepared to contribute to any such investigation.

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

8.242 This policy supports objective 6 of the plan.

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³ For example those policies relating to sites protected under the Birds and Habitats Directives (NPPF paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Local Green Space; and Area of Outstanding Natural Beauty; designated heritage assets and locations at risk of flooding or coastal erosion. ⁴ Examples include By Design, CABE Building for Life ⁵ Ipswich Borough Council Drainage and Flood Defence policy (May 2002, updated August 2009) ⁶ DELETED: Planning Policy Guidance Notes 15 and 16 have now been replaced by a new combined Planning Policy Statement. ⁷ INSERTED: Subject to the Taylor Review in 2013. ⁸ Rented housing owned and managed by local authorities and INSERTED: private registered providers DELETED: registered social landlords for which guideline target rents are determined through the national rent regime, or by other persons and provided under equivalent rental arrangements as agreed with the local authority or INSERTED: with the Homes and Communities Agency DELETED: Housing Corporation as a condition of grant. ⁹ INSERTED: Rented housing let by local authorities or private registered providers of social housing to households who are eligible for social rented housing. Affordable Rent is subject to rent controls that require a rent of no more than 80% of the local market rent (including service charges, where applicable). ¹⁰ INSERTED: Homes for sale and rent provided at a cost above social rent DELETED: Housing at prices and rents above those of social rent, but below market INSERTED: levels DELETED: price or rents, and which meet certain criteria. It can include shared equity products, other low cost homes for sale and intermediate rent INSERTED: , but not affordable rented housing.