The primary allocation for this site should be residential - especially for sheltered and very sheltered accommodation. This reflects the aspirations for the town centre from Ipswich Central and SCC.

Comment - The site is adjacent to the New Wolsey Theatre.

New development adjoining cultural facilities such as your theatres, pubs and music venues, need to ensure that any new residents will not be disturbed by the usual operation of that facility to the extent that Council would be required to take action, e.g. issue a noise abatement order. Given the age and construction of many older community and cultural buildings, it is often difficult to install noise mitigation measures to deal with these issues, which affects the sustainability and viability of the cultural venue.

Item 123 of the National Planning Policy Framework makes it clear that the operation of existing businesses, such as cultural facilities, should not be restricted as a result of new development, supported by the PPG on Noise. The loss of a valued community or cultural facility as a result of changes in the area would conflict with NPPF guidance at item 70 which states that planning policy should protect existing cultural facilities.

There is a recent Planning Inspectorate decision (Reference APP/ X5990/A/12) to refuse consent for conversion of offices to residential adjacent to the London Palladium Theatre, and another decision (Reference APP/K5600/A/14/2222551) to dismiss an appeal for the creation three residential units on the upper levels of the building containing the Finborough Theatre, London (Royal Borough of Kensington and Chelsea).The Inspectors concluded in both cases that there would be harm to future residents living conditions in respect of disturbance from theatre activities and that the long term operation of the theatre would not be safeguarded, as per the NPPF.

The theatre should be noted as a constraint to ensure that noise, vibration and access issues are considered in the design.

The development constraints mention archaeology (if not the area of archaeological importance with covers over half of the site), and the nearby Central and Burlington Road Conservation Areas and the Grade II* Church of St Matthew to the west. Reference is also made to the development principles contained within Opportunity Area E. However, while the wording explains the implications for development in terms of archaeological matters, there is no explanation of the implications for development in terms of the conservation areas and listed church. The lack of clarity could affect proposals for this site. Other sites are clearer in terms of such matters (e.g. IP005).

As currently drafted, we consider the plan to be unsound as the site sheet is not effective or consistent with national policy. Paragraph 157 of the NPPF requires Local Plans to provide adequate detail with site allocations (fifth bullet), with the Planning Practice Guidance providing further emphasis (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Site IP040 and IP041 - this site should not be allocated for retail, but for primarily residential development.

IP040 and IP041 Civic Centre Area - this should not be designated as mainly a retail area and we believe that a shrinking of the town centre, by making both ends a mix of homes and small independent shops, as well as leisure facilities, would create footfall in the town centre and be a more attractive experience for shoppers.