DM25 - Protection of Employment Land
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5230
Received: 05/03/2015
Respondent: Associated British Ports
Agent: Associated British Ports
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Support Policy DM25.
Whilst Policy DM25 will serve to safeguard existing employment areas, care should be exercised when development proposals are brought forward in the vicinity of these areas (consistent, perhaps, with other policies of the DPD) to ensure that this new development does not prejudice existing employment uses and business operations which are "appropriately located" (consistent with the key strategic challenges for Ipswich identified at paragraph 5.25). ABP requests, therefore, that the local planning authority does not apply the policies of the Core Strategy and Policies DPD Review uncritically and in isolation in exercising its development control functions.
ABP supports the safeguarding of the defined Employment Areas identified in Policy DM25 including, particularly, its land within the Ipswich Port estate at the West Bank (E9) and Cliff Quay (E12). In respect of this policy:
i) The Port estate comprises a large area of land situated within Ipswich, part of which (the Wet Dock) lies immediately adjacent to the central area and within the IP-One regeneration area where the Core Strategy seeks to focus the provision of a significant number of Ipswich's new homes. The Port operates 24 hours a day and normal port operations involve activities (for example, heavy good vehicle movements and lighting used to create a safe working environment) and intermittent noises (such as audible alarms and ships horns) which can potentially cause disturbance and nuisance to occupiers and residents outside but in close proximity to the port estate; and
ii) Within ABP's estate, a number of consents exist under both the Planning (Hazardous Substances) Act 1990 and the Dangerous Substances in Harbour Areas Regulations 1987. These consents/licences permit the handling and storage of explosive substances at Ro-Ro Berths 1 and 2 on the West Bank and at the Power Station Berth on Cliff Quay, and the handling and storage of hazardous substances including ammonium nitrate fertilizer at Cliff Quay and in the area around the former Vopak Terminal. The effect of these consents/licences is to potentially restrict the types of uses which are appropriate within defined limits of the areas in which these hazardous activities are permitted. These licenses/consents, and the activities they permit, are an important element of the infrastructure and facilities that the Port is able to offer to its customers and which, therefore, ABP would wish to vigorously safeguard.
In the context of the above, ABP welcomes and supports Policy DM25 and the supporting wording at paragraphs 9.153 and 9.154.
Whilst Policy DM25 will serve to safeguard existing employment areas, it is important that care is exercised when development proposals are brought forward in the vicinity of these areas (consistent, perhaps, with other policies of the DPD) to ensure that this new development does not prejudice existing employment uses and business operations which are "appropriately located" (consistent with the key strategic challenges for Ipswich identified at paragraph 5.25). ABP requests, therefore, that the local planning authority does not apply the policies of the Core Strategy and Policies DPD Review uncritically and in isolation in exercising its development control functions.
Support for Policy DM25.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5287
Received: 05/03/2015
Respondent: New Anglia LEP for Norfolk and Suffolk
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The County Council as Minerals and Waste Planning Authority considers the Ipswich Local Plan to be generally consistent with the Suffolk Minerals and Waste Plans. In order to support the provision of sustainable waste management facilities, e.g. Household Waste and Recycling Centres, amend DM25 to make it clear that, where compatible with adjacent uses, waste facilities can come forward on land allocated for employment. This amendment would better enable the delivery of employment-generating civic amenity sites, whilst still protecting other employment uses. Other policies, such as DM26, would ensure that sufficient weight is given to the protection of amenity
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5350
Received: 05/03/2015
Respondent: Legal and General Assurance Society Limited (L&G)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The policy potentially risks prejudicing the delivery of new retail and town centre floorspace in suitable locations. The Employment Areas defined on the policies maps and referenced in DM25 appear to be based on an out of date evidence base (Suffolk Haven Gateway Employment Land Review, October 2009). The Council must consider its stance in relation to the protection of employment sites in relation to the need for other uses. Retail and leisure capacity evidence demonstrates more sites are required. The Jewson site will be available for redevelopment in the plan period and should therefore be allocated to meet need.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5472
Received: 05/03/2015
Respondent: AquiGen
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
This Policy provides the basis for controlling the development of non B-class uses on Employment Sites. In addition to our comments above on the relationship of the employment definition with the NPPF, we consider the levels of control imposed in the policy to be far too strict and thus unsound.
See attached
Support
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 24218
Received: 05/03/2015
Respondent: EDF Energy Plc
Support the amendment to this policy which now contains clearer guidance around the grounds upon which the Council will accept evidence that there is no reasonable prospect of the site being used for employment purposes. The approach accords with paragraphs 51 and 52 of the NPPF.
See attachment